Response Records Part 1

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ASHLU CREEK INVESTMENTS LIMITED PARTNERSHIP

1200 1067 West Cordova Street, Vancouver, B.C. V6C 1C7 Telephone: 604-681-7500 Fax: 604-646-2481
April 17, 2009 Ministry of Environment Water Stewardship Division 10470-152 Street, Surrey, BC V3R 0Y3 Attention: Re: Timothy Bennett, Section Head, Water Allocation
Ashlu Creek Green Power Project 2009 Environmental Monitor
Dear Tim: The Ashlu Creek Investments Limited Partnership (ACILP) is pleased to present our rationale for the continued use of Cascade Environmental Resource Group Ltd. ("Cascade") as the Independent Environmental Monitor (the EM) for the duration of the 2009 construction period of the Ashlu Creek Green Power Project (the Project) near Squamish. Mr. Tom Cleugh of TRC Biological Services (TRC) was originally retained by ACILP to fulfill the EM role for the course of construction of the Project. A service agreement was signed in August 2006 at the start of the construction activities, which at that time were expected to be completed by January 2009, and to end in mid-February 2009. The progress of construction has been slower than initially foreseen and the currently anticipated completion date is now scheduled for November 2009. Therefore, a new service agreement was required to complete the EM role to late 2009. TRC maintained a secondary residence near the project site from the start of construction in 2006 to November 2008 and was on site on average of three to four days a week, subject to the actual construction activities and requirements under the permits (e.g. on site full-time during all instream work). After this period, once the instream construction activities ceased and the majority of the site work was non-riparian related, TRC ceased to use the secondary residence and TRC typically S22 visited the site for a period S22
S22
Cascade was pre act as interim EM
S22
ironment (MOE) and the Department of Fisheries and Oceans (DFO) to , and has since then acted as the EM for the Project.
Due to the completion of the existing service agreement, ACILP had requested TRC to submit a proposal for the balance of the project. TRCs proposal allowed for an average presence on site for two, full-time consecutive days per week with an emergency response time of two to three hours when off site. At the same time, ACILP solicited a request from Cascade and other qualified companies and a total of three proposals were received. ACILP evaluated the proposals based on professional qualification, experience as EM for hydroelectric projects, proposed presence on site and anticipated emergency response time.
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Cascades proposal was considered the most beneficial to the Project for the following reasons: Cascades personnel has, in ACILPs opinion, a high level of education and training, experience and credentials, and have been accepted by MOE and DFO for work as interim EM; Cascade is currently acting as the EM on the Project, as well as on the Fitzsimmons Creek Hydroelectric Project near Whistler, B.C.; Cascade allows the highest number of days on site (average four days per week); Cascade has an emergency response time of 30 to 45 minutes with an average of three people on call; In direct comparison to TRCs proposal, Cascades presence on site is less regular and more spontaneous.
Based on the above criteria, ACILP believes that Cascade is in the best available option to fulfill the role as EM for the balance of the Project. ACILP notes that it has requested a proposal from TRC to act as a consultant with regards to new fisheries habitat compensation works, and will update both MOE and DFO regarding this once an agreement is reached. Sincerely, Ashlu Creek Investments Limited Partnership
By its General Partners, Ledcor Power Inc. and 675729 British Columbia Ltd.
Richard Blanchet Vice President

Encl. CC: Mike Nelson, Cascade Environmental (via email) Kelly Boychuk, Ashlu Creek Investments Limited Partnership (via email)
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Construction of the Ashlu Creek Waterpower Project

Scope of Information and Reports by the Environmental Monitor A. Preamble
Ashlu Creek Investments Limited Partnership (the Licensee) is proceeding with the construction of the Ashlu Creek Waterpower Project (the Project). The Project, located on Ashlu Creek, is authorized by Conditional Water Licence 102203 (the Licence), which forms part of this document. The works of the Project are described under clause (h) of the licence. The Licensee is required under clause (i) 5) of the Licence to prepare an environmental management plan (the EMP) for the management and mitigation of construction impacts, which plan is to be to the satisfaction of the Engineer under the Water Act (the Engineer). The Licensee is required under clause (i) 6) of the Licence to retain a person with professional qualifications (the Environmental Monitor) who will provide information and reports under the direction of the Engineer on compliance of the construction with the EMP. The Licensee is also required to retain a Design Engineer, a Construction Engineer and an Independent Engineer as set out in the Licence. The EMP are the provisions that meet the collective requirements of Fisheries and Oceans Canada (DFO), Environment Canada, Transport Canada (Canadian Coast Guard), Ministry of Environment and the Engineer under the Water Act ( the Engineer) to mitigate the effects of the construction activities. The information and reports by the Environmental Monitor will be provided to Fisheries and Oceans Canada, Environment Canada, Transport Canada, Ministry of Environment and the Engineer. Each agency will take action on the information and reports provided by the Environmental Monitor in accordance with the jurisdiction of the agency. The current distribution list is as follows: Name Steve Rochetta Mike Willcox Scott Babakaiff Sandra Jensen Ron Wallace Stuart McDonald Vince Busto Jim Schellenberg Vivian Au George Steeves Richard Blanchet Robert Kulka Kelly Boychuk Organization Ministry of Environment Ministry of Environment Ministry of Environment Ministry of Environment Integrated Land Mgmt Bureau Ministry of Forests Fisheries and Oceans Canada Transport Canada Environment Canada Independent Engineer Proponent Proponent Proponent Email Address steve.rochetta@gov.bc.ca michael.willcox@gov.bc.ca Scott.Babakaiff@gov.bc.ca Sandra.Jensen@gov.bc.ca Ron.Wallace@gov.bc.ca stu.mcdonald@gov.bc.ca BustoV@pac.dfo-mpo.gc.ca schellj@tc.gc.ca Vivian.Au@ec.gc.ca gsteeves@ameresco.com rblanchet@innergex.com rkulka@innergex.com kelly.boychuk@ledcor.com
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B.
Regulation of the Construction of Works

The Engineer has the power to regulate the construction of works, which regulation may consider the construction activities that may adversely affect the public, the environment and the interests of licensees, riparian owners and owners of land adjacent to the works. When the Engineer is satisfied that the construction activities may be hazardous to the interests of licensees, riparian owners and owners of land adjacent to the works and the environment, the Engineer may issue an order that directs the Licensee to change the manner in which the works are constructed to remove the hazardous condition.
C.
Information and Reports

The Environmental Monitor is responsible for observing the construction and testing of the works and preparing information and reports on the compliance of the construction activities with the EMP. The information and the reports to be provided by the Environmental Monitor to Fisheries and Oceans Canada, Environment Canada, Transport Canada, Ministry of Environment and the Engineer and must include the following: 1. A work plan the sets out the following:
The frequency of inspecting the construction activities. The manner in which notice is to be given to the parties for a construction activity that is not in compliance with the EMP. A process for escalating enforcement of compliance of construction activities with the EMP.
2.
The format and frequency for the preparation of reports on the compliance of the construction activities with the EMP. Reports on meetings with the Licensee and the Construction Engineer to develop a strategy to communicate to the workers on the construction site the following:
3.
4.
the authority of the Environmental Monitor. Reports on matters that arise during the construction and testing of the works that are not described in the EMP, and obtain direction from the Engineer and Fisheries and Oceans Canada, Environment Canada, Transport Canada and Ministry of Environment for the mitigation of these matters. Provide any other information or advice required by the Engineer and Fisheries and Oceans Canada, Environment Canada, Transport Canada and Ministry of Environment that is required to ensure that the construction and commissioning of the works is in accordance with the EMP.
the requirements of the EMP, the potential environmental impacts, and
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D.
Independent Engineer
The Licensee is required under clause (i) 4) of the Licence to retain an Independent Engineer who will provide information and reports under the direction of the Engineer regarding the design and construction of the works. The Environmental Monitor and the Independent Engineer will communicate with each other during the construction and testing of the works to provide consistent and concise information to the Engineer.
E.
Delegation of Duties of Environmental Monitor

When the Environmental Monitor is unable to personally observe and report on the construction activities, the persons who have the same authority as the Environmental Monitor to observe and report on construction activities are: 1. 2. 3. 4. Mike Nelson, R.P. Bio. Hilary Lindh, M.Sc., R.P. Bio Christine Cunliffe, B.Sc. Environmental Technician. Sara Baker, B.A., Environmental Technician
F.
Testing the Operation

When the Licensee submits a schedule for testing the operation of the works, the Environmental Monitor will inspect the site and report to Fisheries and Oceans Canada, Environment Canada, Transport Canada, Ministry of Environment and the Engineer on any matters that would make the works a hazard to the public and the environment. The Environmental Monitor will observe the testing of the operation of the works to determine if the operation poses a hazard to the public and the environment, and submit to the Engineer a report on the outcome of the monitoring.
G.
Authority to Stop Construction Activities

The plan prepared by the Environmental Monitor for escalating the enforcement of compliance of construction activities with the EMP includes a provision that the Environmental Monitor may direct the Construction Engineer to stop a construction activity. The authority of the Environmental Monitor to stop a construction activity pertains only to those matters under the jurisdiction of Fisheries and Oceans Canada, Environment Canada, Transport Canada and Ministry of Environment. An order to stop a construction activity that affects the interests of licensees, riparian owners and owners of land adjacent to the works may only be given by the Engineer.
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H.
Acceptance
The scope of services to be provided by the Environmental Monitor as set out above is acceptable to:
Name: ______________________________________ Environmental Monitor, supervisor Mike Nelson, R.P. Bio.
Date: April 22, 2009
Name: ______________________________________ Environmental Monitor, field personnel Hilary Lindh, M.Sc., R.P. Bio
Date: : April 22, 2009
Name: ______________________________________ Environmental Monitor, alternate field personnel Christine Cunliffe, B.Sc. Environmental Tech.
Date: : April 22, 2009
A N D Name: ______________________________________ Date: : April 22, 2009 Environmental Monitor, alternate field personnel T Sara Baker, Environmental Technologist h e TThe Licensee agrees to retain the Environmental Monitor to provide the scope of services set out above.
Name: ______________________________________ Ashlu Creek Investments Limited Partnership Richard Blanchet, P.Eng.
Date: ______________
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Appendix A - Contact List

Engineer under the Water Act Name: Timothy Bennett, M.Sc., P.Eng. Position Title: Section Head, Water Allocation, Water Stewardship Division Office Phone Number: (604) 582-5227 Alternate Phone Number or email: Timothy.Bennett@gov.bc.ca Mailing Address: 10470 - 152nd Street, Surrey, BC V3R 0Y3 Independent Engineer George Steeves Principal True North Energy o/a 1169417 Ontario Inc. 416-512-7700 ext 3322 416-452-4715 c/o Ameresco Canada, 7th Floor, 90 Sheppard Avenue East, Toronto, Ontario Licensee Representative Richard Blanchet Senior Vice President Ashlu Creek Investments Limited Partnership 604-681-8200 ext 225 rblanchet@innergex.com 407-1112 West Pender Street, Vancouver, BC V6E 2S1 Design Engineer Claude Chartrand Vice-President Hydroelectric Developments and Civil Works RSW Inc. (514) 878-2621 claude.chartrand@rswinc.com 1010, De La Gauchetire West, Suite 500, Montreal, Quebec H3B 0A1 Construction Engineer Tim Ellis Senior Project Manager Ledcor CMI Ltd. 604-699-2466 tim.ellis@ledcor.com 1200-1067 West Cordova Street, Vancouver, BC V6C 1C7
Name: Position Title: Company Office Phone Number: Alternate Phone Number or email: Mailing Address:
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Exova #104, 19575-55 A Ave. Surrey, British Columbia V3S 8P8, Canada
T: +1 (604) 514-3322 F: +1 (604) 514-3323 E: Surrey@exova.com W: www.exova.com
Report Transmission Cover Page

Bill To: Cascade Environmental Report To: Cascade Environmental #203 - 38026 2nd Avenue Squamish, BC, Canada V8B 0C3 Attn: Christine Becker Sampled By: MN Company: CERG Project: ID: Name: Location: LSD: P.O.: Acct code: Lot ID: Approval Status: Invoice Frequency: COD Status: Control Number: Date Received: Date Reported: Report Number:
413-01-01 Ashlu IPP Ashlu IPP
710095
Approved by Lot
Oct 27, 2009 Oct 29, 2009 1267258
Contact & Affiliation Lesley Nelson Cascade Environmental Resource
Address #203 - 38026 2nd Avenue Squamish, British Columbia V8B 0C3 Phone: (604) 815-0901 Fax: (604) 815-0904 Email: lnelson@cerg.ca #203 - 38026 2nd Avenue Squamish, British Columbia V8B 0C3 Phone: (604) 815-0901 Fax: (604) 815-0904 Email: cbecker@cerg.ca
Delivery Commitments On [Lot Approval and Final Test Report Approval] send (Invoice) by Post M
Christine Becker Cascade Environmental Resource
On [Lot Verification] send (COA) by Email - Single Report On [Report Approval] send (COC, Test Report) by Email - Merge Reports
Notes To Clients:
The information contained on this and all other pages transmitted, is intended for the addressee only and is considered confidential. If the reader is not the intended recipient, you are hereby notified that any use, dissemination, distribution or copy of this transmission is strictly prohibited. If you receive this transmission by error, or if this transmission is not satisfactory, please notify us by telephone.
Terms and Conditions: www.exova.ca/terms&conditions.html
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Sample Custody
Bill To: Cascade Environmental Report To: Cascade Environmental #203 - 38026 2nd Avenue Squamish, BC, Canada V8B 0C3 Attn: Christine Becker Sampled By: MN Company: CERG Project: ID: Name: Location: LSD: P.O.: Acct code: Lot ID: 710095 Control Number: Date Received: Oct 27, 2009 Date Reported: Oct 29, 2009 Report Number: 1267258
Sample Disposal Date: November 28, 2009

All samples will be stored until this date unless other instructions are received. Please indicate other requirements below and return this form to the address or fax number on the top of this page.
Extend Sample Storage Until The following charges apply to extended sample storage: Storage for an additional 30 days Storage for an additional 60 days Storage for an additional 90 days
(MM/DD/YY)
S. 21
per sample per sample per sample
Return Sample, collect, to the address below via: Greyhound DHL Purolator Other (specify) Name Company Address Phone Fax Signature
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Page 1 of 14
Analytical Report
Reference Number Sample Date Sample Time Sample Location Sample Description Matrix Analyte Metals Dissolved Titanium Aluminum Antimony Arsenic Barium Beryllium Bismuth Boron Cadmium Chromium Cobalt Copper Iron Lead Lithium Manganese Molybdenum Nickel Selenium Silver Strontium Sulfur Tellurium Thallium Thorium Tin Uranium Vanadium Zinc Zirconium Metals Total Aluminum Antimony Arsenic Barium Beryllium Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Total Total Total Total Total Units mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L
710095-1 Oct 26, 2009 10:05 Tailrace / Surface Water Results <0.01 0.063 <0.0002 0.0070 0.006 <0.00004 <0.001 0.109 <0.00001 0.0005 0.00005 <0.001 <0.01 <0.0001 0.005 0.0039 0.0005 <0.001 <0.0006 <0.00001 0.034 1.3 <0.0001 <0.00001 <0.0004 <0.0001 0.0004 0.0008 <0.001 <0.0001 0.621 0.0004 0.0155 0.012 <0.00004 Results Results
Nominal Detection Limit
0.01 0.005 0.0002 0.0002 0.001 0.00004 0.001 0.004 0.00001 0.0004 0.00002 0.001 0.01 0.0001 0.001 0.0002 0.0001 0.001 0.0006 0.00001 0.001 0.2 0.0001 0.00001 0.0004 0.0001 0.0004 0.0001 0.001 0.0001 0.005 0.0002 0.0002 0.001 0.00004
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Analytical Report
Reference Number Sample Date Sample Time Sample Location Sample Description Matrix Analyte Metals Total - Continued Bismuth Boron Cadmium Calcium Chromium Cobalt Copper Iron Lead Lithium Magnesium Manganese Molybdenum Nickel Phosphorus Potassium Selenium Silicon Silver Sodium Strontium Sulfur Tellurium Thallium Thorium Tin Uranium Vanadium Zinc Zirconium Routine Water Calcium Magnesium Phosphorus Potassium Silicon Total Total Total Total Total Total Total Total Total Total Total Total Total Total Total Total Total Total Total Total Total Total Total Total Total Total Total Total Total Total Dissolved Dissolved Dissolved Dissolved Dissolved Units mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L
710095-1 Oct 26, 2009 10:05 Tailrace / Surface Water Results <0.001 0.122 0.00001 9.11 0.0008 0.00029 0.002 0.557 0.0005 0.006 0.92 0.0158 0.0005 <0.001 0.011 0.6 <0.0006 2.80 <0.00001 6.71 0.040 1.6 <0.0001 <0.00001 <0.0004 <0.0001 0.0005 0.0018 0.011 0.0002 8.1 0.6 <0.01 0.5 1.76 Results Results
0.001 0.004 0.00001 0.05 0.0004 0.00002 0.001 0.01 0.0001 0.001 0.05 0.0002 0.0001 0.001 0.01 0.1 0.0006 0.05 0.00001 0.02 0.001 0.1 0.0001 0.00001 0.0004 0.0001 0.0004 0.0001 0.001 0.0001 0.1 0.1 0.01 0.1 0.05
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Analytical Report
Reference Number Sample Date Sample Time Sample Location Sample Description Matrix Analyte Routine Water - Continued Sodium Dissolved Hardness as CaCO3 Extractable Petroleum Hydrocarbons - Water EPHw10-19 EPHw19-32 Units mg/L mg/L ug/L ug/L
710095-1 Oct 26, 2009 10:05 Tailrace / Surface Water Results 6.2 23 <100 <100 Results Results
0.1 5 100 100
Approved by: Marie England Consulting Scientist

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Quality Control
Metals Dissolved
Certified Reference Material Aluminum Antimony Arsenic Barium Beryllium Boron Cadmium Chromium Cobalt Copper Iron Lead Manganese Molybdenum Nickel Selenium Silver Strontium Thallium Vanadium Zinc Date Acquired: Replicates Titanium Sulfur Date Acquired: Units mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L Measured 0.288 0.0742 0.0618 0.193 0.0729 0.087 0.05390 0.0641 0.07690 0.055 0.27 0.157 0.3490 0.0556 0.214 0.1080 0.01320 0.048 0.06370 0.7350 0.118 Target 0.301 0.0750 0.0650 0.201 0.07500 0.087 0.05800 0.0680 0.08000 0.057 0.32 0.1530 0.3760 0.06000 0.221 0.1100 0.01500 0.050 0.06500 0.75000 0.130 Lower Limit 0.257 0.0558 0.0530 0.183 0.06540 0.070 0.04960 0.0563 0.07010 0.053 0.28 0.1308 0.3448 0.04980 0.198 0.0935 0.01260 0.042 0.05270 0.66390 0.115 Upper Limit 0.345 0.0942 0.0770 0.219 0.08460 0.104 0.06640 0.0797 0.08990 0.062 0.36 0.1752 0.4132 0.07020 0.244 0.1265 0.01740 0.058 0.07730 0.83610 0.145 Passed QC yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes
October 27, 2009 Units mg/L mg/L October 27, 2009 Replicate 1 <0.01 1.3 Replicate 2 <0.01 1.3 % RSD Criteria 30 30 Absolute Criteria 0.012 3.0 Passed QC yes yes
Metals Total
Blanks Calcium Iron Magnesium Manganese Phosphorus Potassium Silicon Sodium Date Acquired: Calcium Iron Magnesium Units mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L October 28, 2009 mg/L mg/L mg/L <0.05 <0.010 <0.05 -0.13 -0.029 -0.09 0.17 0.031 0.09 yes yes yes Measured <0.05 <0.010 <0.05 <0.005 <0.01 <0.1 <0.05 <0.02 Lower Limit -0.08 -0.030 -0.06 -0.0098 -0.033 -0.30 -2.55 -0.23 Upper Limit 0.10 0.030 0.06 0.0022 0.027 0.30 3.15 0.19 Passed QC yes yes yes yes yes yes yes yes
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Quality Control
Metals Total - Continued

Blanks Manganese Phosphorus Potassium Silicon Sodium Date Acquired: Calibration Check Calcium Iron Magnesium Manganese Phosphorus Potassium Silicon Sodium Date Acquired: Units mg/L mg/L mg/L mg/L mg/L October 28, 2009 Units mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L October 28, 2009 Units mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L Measured 0.566 0.149 0.131 0.39 0.155 0.19 0.112 51.2 0.133 0.160 0.12 0.582 0.314 30.7 0.780 0.114 0.44 25 0.214 0.0287 10.3 0.099 0.131 1.50 Target 0.601 0.1500 0.1310 0.401 0.15100 0.175 0.11600 0.1350 0.16100 0.114 0.3050 Lower Limit 0.502 0.1116 0.1067 0.365 0.13210 0.135 0.09920 46.23 0.1119 0.14090 0.104 0.560 0.2603 26.50 0.6846 0.09960 0.396 21.30 0.1870 0.02550 8.02 0.085 0.10640 1.32780 Upper Limit 0.700 0.1884 0.1553 0.437 0.16990 0.225 0.13280 54.21 0.1581 0.18110 0.125 0.722 0.3497 33.70 0.8214 0.14040 0.486 28.50 0.2530 0.03450 11.98 0.115 0.15560 1.67220 Passed QC yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes % Recovery 99.55 73.80 99.86 99.80 99.26 93.00 100.09 100.40 Lower Limit 90 85 90 90 90 85 80 90 Upper Limit 110 115 110 110 110 115 120 110 Passed QC yes yes yes yes yes yes yes yes Measured <0.005 <0.01 <0.1 <0.05 <0.02 Lower Limit -0.0098 -0.033 -3.83 -2.40 -0.23 Upper Limit 0.0022 0.027 4.09 3.00 0.19 Passed QC yes yes yes yes yes
Certified Reference Material Aluminum Antimony Arsenic Barium Beryllium Boron Cadmium Calcium Chromium Cobalt Copper Iron Lead Magnesium Manganese Molybdenum Nickel Potassium Selenium Silver Sodium Strontium Thallium Vanadium
0.12000 0.441 0.2200 0.03000 0.100 0.13100 1.50000
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Quality Control

Certified Reference Material Units Zinc mg/L Date Acquired: Replicates Calcium Iron Magnesium Manganese Phosphorus Potassium Silicon Sodium Sulfur Date Acquired: October 28, 2009 Units mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L October 28, 2009 Replicate 1 9.11 0.557 0.92 0.013 0.011 0.6 2.80 6.71 1.6 Replicate 2 9.02 0.549 0.89 0.013 0.013 0.5 2.78 6.66 1.6 % RSD Criteria 20 20 20 20 20 20 20 20 20 Absolute Criteria 0.05 0.050 0.05 0.0050 0.050 0.10 0.10 0.10 0.0 Passed QC yes yes yes yes yes yes yes yes yes Measured 0.26 Target 0.260 Lower Limit 0.230 Upper Limit 0.290 Passed QC yes
Routine Water
Blanks Calcium Iron Magnesium Manganese Phosphorus Potassium Silicon Sodium Date Acquired: Calcium Iron Magnesium Manganese Phosphorus Potassium Silicon Sodium Date Acquired: Calibration Check Calcium Iron Magnesium Manganese Phosphorus Units mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L October 27, 2009 mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L October 27, 2009 Units mg/L mg/L mg/L mg/L mg/L % Recovery 98.71 73.80 98.33 100.60 94.22 Lower Limit 90 85 90 90 90 Upper Limit 110 115 110 110 110 Passed QC yes yes yes yes yes <0.1 <0.005 <0.1 <0.001 <0.01 <0.1 <0.05 <0.1 -0.13 -0.024 -0.07 -0.009 -0.14 -0.8 -1.76 -0.3 0.16 0.025 0.08 0.002 0.16 0.8 2.02 0.4 yes yes yes yes yes yes yes yes Measured <0.1 <0.005 <0.1 <0.001 <0.01 <0.1 <0.05 <0.1 Lower Limit -0.05 -0.031 -0.05 -0.008 -0.04 -0.4 -0.20 -0.2 Upper Limit 0.05 0.029 0.07 -0.000 0.04 0.4 0.25 0.2 Passed QC yes yes yes yes yes yes yes yes
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Quality Control
Routine Water - Continued

Calibration Check Potassium Silicon Sodium Date Acquired: Units mg/L mg/L mg/L October 27, 2009 Units mg/L mg/L mg/L mg/L mg/L mg/L Measured 24.4 0.285 14.4 0.372 12.0 4.8 Target 25.11 0.321 15.04 0.376 12.4 5.0 Lower Limit 21.93 0.281 13.00 0.342 10.6 4.3 Upper Limit 28.29 0.359 17.08 0.410 14.3 5.6 Passed QC yes yes yes yes yes yes % Recovery 97.28 102.58 101.54 Lower Limit 85 80 90 Upper Limit 115 120 110 Passed QC yes yes yes
Certified Reference Material Calcium Iron Magnesium Manganese Potassium Sodium Date Acquired: Replicates Calcium Iron Magnesium Manganese Phosphorus Potassium Silicon Sodium Date Acquired: Hardness Date Acquired:
October 27, 2009 Units mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L October 27, 2009 mg CaCO3/L October 28, 2009 26.5 26.2 20 1.000 yes Replicate 1 8.1 0.013 0.6 <0.001 <0.01 0.5 1.76 6.2 Replicate 2 8.0 0.008 0.6 <0.001 <0.01 0.5 1.76 6.2 % RSD Criteria 30 30 30 30 30 30 30 30 Absolute Criteria 1.00 0.060 1.00 0.015 0.10 1.0 0.15 1.0 Passed QC yes yes yes yes yes yes yes yes
Extractable Petroleum Hydrocarbons Water

Blanks EPHw10-19 EPHw19-32 Date Acquired: Calibration Check EPHw10-19 EPHw19-32 Date Acquired: Replicates EPHw10-19 EPHw19-32 Units ug/L ug/L October 27, 2009 Units ug/mL ug/mL October 27, 2009 Units ug/L ug/L Replicate 1 400 400 Replicate 2 500 500 % RSD Criteria 60 60 Absolute Criteria 500 500 Passed QC yes yes % Recovery 101.99 101.99 Lower Limit 85 85 Upper Limit 115 115 Passed QC yes yes Measured <100 <100 Lower Limit -100 -100 Upper Limit 100 100 Passed QC yes yes
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Quality Control
Extractable Petroleum Hydrocarbons Water - Continued

Replicates Date Acquired: Matrix Spike EPHw10-19 EPHw19-32 Date Acquired: Units October 27, 2009 Units ug/L ug/L October 27, 2009 % Recovery 105 105 Lower Limit 79 81 Upper Limit 128 136 Passed QC yes yes Replicate 1 Replicate 2 % RSD Criteria Absolute Criteria Passed QC
Trace Metals Dissolved

Blanks Aluminum Antimony Arsenic Barium Beryllium Bismuth Boron Cadmium Chromium Cobalt Copper Iron Lead Lithium Manganese Molybdenum Nickel Selenium Silver Strontium Tellurium Thallium Thorium Tin Titanium Uranium Vanadium Zinc Zirconium Date Acquired: Aluminum Antimony Units g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L October 27, 2009 g/L g/L <5 <0.2 -6 -0.4 6 0.3 yes yes Measured <5 <0.2 <0.2 <1 <0.04 <1 <4 <0.01 <0.4 <0.02 <1 <10 <0.1 <1 <0.2 <0.1 <1 <0.6 <0.01 <1 <0.1 <0.01 <0.4 <0.1 <0.4 <0.4 <0.1 <1 <0.1 Lower Limit -10 -0.4 -0.5 -0 -0.10 -1.0 -6 -0.03 -0.1 -0.07 -1 -7 -0.1 -1 -1.0 -0.31 -1 -1.7 -0.05 -0 -0.7 -0.03 -1.5 -3.0 -0.2 -0.03 -0.35 -2 -0.0 Upper Limit 10 0.2 0.5 0 0.10 1.0 5 0.03 0.2 0.07 1 13 0.1 1 1.1 0.29 1 1.3 0.05 0 0.7 0.03 1.5 3.0 0.2 0.03 0.35 4 0.0 Passed QC yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes
Page 49 FNR-2011-00265/ Part 1
Page 9 of 14
Quality Control
Trace Metals Dissolved - Continued

Blanks Arsenic Barium Beryllium Bismuth Boron Cadmium Chromium Cobalt Copper Iron Lead Lithium Manganese Molybdenum Nickel Selenium Silver Strontium Tellurium Thallium Thorium Tin Titanium Uranium Vanadium Zinc Zirconium Date Acquired: Calibration Check Aluminum Antimony Arsenic Barium Beryllium Boron Cadmium Chromium Cobalt Copper Iron Lead Manganese Units g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L October 27, 2009 Units g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L % Recovery 97.76 97.72 98.20 95.06 98.80 94.04 100.24 92.92 94.94 96.98 91.12 104.76 91.44 Lower Limit 70 85 90 90 90 70 90 90 90 90 80 90 90 Upper Limit 130 115 110 110 110 130 110 110 110 110 120 110 110 Passed QC yes yes yes yes yes yes yes yes yes yes yes yes yes Measured <0.2 <1 <0.04 <1 <4 <0.01 <0.4 <0.02 <1 <10 <0.1 <1 <0.2 <0.1 <1 <0.6 <0.01 <1 <0.1 <0.01 <0.4 <0.1 <0.4 <0.4 <0.1 <1 <0.1 Lower Limit -0.4 -0 -0.10 0.0 -18 -0.03 -0.1 -0.30 -1 -12 -0.3 -0 -0.5 -0.95 -1 -1.7 -0.67 -8 -0.7 -0.06 -0.7 -3.8 -0.3 -0.04 -0.30 -58 -0.0 Upper Limit 0.3 1 0.10 0.0 19 0.03 0.2 0.30 1 18 0.4 0 0.7 0.85 1 1.7 0.47 10 0.7 0.06 0.5 4.0 0.2 0.02 0.30 74 0.0 Passed QC yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes
Page 50 FNR-2011-00265/ Part 1
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Quality Control

Calibration Check Molybdenum Nickel Selenium Silver Strontium Thallium Tin Vanadium Zinc Date Acquired: Replicates Aluminum Antimony Arsenic Barium Beryllium Boron Cadmium Chromium Cobalt Copper Iron Lead Lithium Manganese Molybdenum Nickel Selenium Silver Strontium Tellurium Thallium Thorium Tin Titanium Uranium Vanadium Zinc Zirconium Date Acquired: Units g/L g/L g/L g/L g/L g/L g/L g/L g/L October 27, 2009 Units g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L October 27, 2009 Replicate 1 63 <0.2 7.0 6 <0.04 109 <0.01 0.5 0.05 <1 <10 <0.1 5 3.9 0.5 <1 <0.6 <0.01 34 <0.1 <0.01 <0.4 <0.1 0.7 0.4 0.8 <1 <0.1 Replicate 2 64 0.2 7.2 6 <0.04 112 <0.01 0.5 0.05 <1 <10 <0.1 5 4.0 0.6 <1 <0.6 <0.01 34 <0.1 <0.01 <0.4 <0.1 <0.4 0.4 0.9 <1 <0.1 % RSD Criteria 20 10 10 20 10 20 10 20 20 20 20 10 20 20 10 20 10 10 20 10 10 10 10 20 10 20 20 10 Absolute Criteria 20 1.0 1.0 5 1.00 5 0.50 5.0 0.50 5 50 0.5 5 0.5 0.50 5 0.5 0.50 0 0.5 0.10 0.1 0.5 0.5 0.10 0.50 5 0.5 Passed QC yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes % Recovery 94.60 96.40 97.48 0.10 95.96 100.24 97.88 91.24 93.66 Lower Limit 90 90 90 90 90 90 90 90 90 Upper Limit 110 110 110 110 110 110 110 110 110 Passed QC yes yes yes yes yes yes yes yes yes
Page 51 FNR-2011-00265/ Part 1
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Quality Control
Trace Metals Total

Blanks Aluminum Antimony Arsenic Barium Beryllium Bismuth Boron Cadmium Chromium Cobalt Copper Lead Lithium Manganese Molybdenum Nickel Selenium Silver Strontium Tellurium Thallium Thorium Tin Titanium Uranium Vanadium Zinc Zirconium Date Acquired: Aluminum Antimony Arsenic Barium Beryllium Bismuth Boron Cadmium Chromium Cobalt Copper Lead Lithium Units g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L October 28, 2009 g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L <5 <0.2 0.3 <1 <0.04 <1 <5 0.03 <0.4 <0.02 <1 <0.1 <1 -4 -0.6 -0.6 -0.1 -0.09 0.0 -12 -0.08 -0.1 -0.07500 -1.930 -0.150 -0 8 0.4 0.6 0.1 0.09 0.0 11 0.08 0.2 0.08700 1.430 0.210 0 yes yes yes yes yes yes yes yes yes yes yes yes yes Measured <5 <0.2 <0.2 <1 <0.04 <1 <5 <0.01 <0.4 <0.02 <1 <0.1 <1 <0.2 <0.1 <1 <0.6 <0.01 <1 <0.1 <0.01 <0.4 <0.1 <0.4 <0.4 <0.1 <1 <0.1 Lower Limit -7 -0.4 -0.5 -0.1 -0.10 -3.0 -6 -0.03 -0.1 -0.06600 -0.830 -0.100 -0 -0.9 -0.31 -1 -1.7 -0.07 -0.3 -0.7 -0.03 -1.50 -3.0 -0.2 -0.0 -0.30 -2 -0.0 Upper Limit 7 0.2 0.5 0.2 0.10 3.0 5 0.03 0.2 0.06600 0.790 0.140 0 0.9 0.29 1 1.3 0.05 0.3 0.7 0.03 1.50 3.0 0.2 0.0 0.30 4 0.0 Passed QC yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes
Page 52 FNR-2011-00265/ Part 1
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Quality Control
Trace Metals Total - Continued

Blanks Manganese Molybdenum Nickel Selenium Silver Strontium Tellurium Thallium Thorium Tin Titanium Uranium Vanadium Zinc Zirconium Date Acquired: Calibration Check Aluminum Antimony Arsenic Barium Beryllium Boron Cadmium Chromium Cobalt Copper Lead Manganese Molybdenum Nickel Selenium Silver Strontium Thallium Tin Vanadium Zinc Date Acquired: Replicates Aluminum Units g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L October 28, 2009 Units g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L October 28, 2009 Units g/L Replicate 1 621 Replicate 2 593 % RSD Criteria 15 Absolute Criteria 100 Passed QC yes % Recovery 100.12 95.92 100.28 93.54 99.00 100.16 99.36 94.24 96.06 98.08 103.24 95.04 94.52 95.16 97.12 0.14 95.64 100.24 96.68 93.30 98.50 Lower Limit 70 85 90 90 90 70 90 90 90 90 90 90 90 90 90 90 90 90 85 90 90 Upper Limit 130 115 110 110 110 130 110 110 110 110 110 110 110 110 110 110 110 110 115 110 110 Passed QC yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes Measured <0.2 <0.1 <1 <0.6 <0.01 <1 <0.1 <0.01 <0.4 0.2 <0.4 <0.4 <0.1 <1 <0.1 Lower Limit -1.0 -1.67 -1 -2.5 -0.13 -0.2 -0.2 -0.32 -1.75 -0.5 -0.2 -0.1 -0.30 -4 -0.1 Upper Limit 1.1 1.81 1 1.5 0.07 0.2 0.2 0.34 0.95 0.4 0.3 0.1 0.30 6 0.1 Passed QC yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes
Page 53 FNR-2011-00265/ Part 1
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Quality Control

Replicates Antimony Arsenic Barium Beryllium Boron Cadmium Chromium Cobalt Copper Lead Lithium Manganese Molybdenum Nickel Selenium Silver Strontium Tellurium Thallium Thorium Tin Titanium Uranium Vanadium Zinc Zirconium Date Acquired: Units g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L October 28, 2009 Replicate 1 0.4 15.5 12 <0.04 122 0.01 0.8 0.29 2 0.5 6 15.8 0.5 <1 <0.6 <0.01 40 <0.1 <0.01 <0.4 <0.1 27.2 0.5 1.8 11 0.2 Replicate 2 0.4 15.0 11 <0.04 117 <0.01 0.8 0.28 2 0.5 6 15.4 0.5 <1 <0.6 <0.01 38 <0.1 <0.01 <0.4 0.1 23.9 0.5 1.8 10 0.2 % RSD Criteria 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 20 15 15 15 15 15 15 15 15 Absolute Criteria 2.0 2.0 10.0 0.40 40 0.10 6.0 0.20000 5.000 1.000 10 1.0 0.20 10 5.0 0.10 10.0 0.5 0.10 1.00 1.0 1.0 1.0 0.40 10 1.0 Passed QC yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes
Page 54 FNR-2011-00265/ Part 1
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Methodology and Notes

Method of Analysis
Method Name EPH - Water Reference BCELM Method Date Analysis Started Location Exova Surrey Exova Surrey Exova Surrey Exova Surrey Exova Surrey Exova Surrey Exova Surrey
* Extractable Petroleum Hydrocarbons 27-Oct-09 (EPH) in Water by GC/FID, EPH Water * Metals & Trace Elements by ICP-AES, 27-Oct-09 6010B * Metals & Trace Elements by ICP-AES, 28-Oct-09 6010B * Determination of Trace Elements in Waters and Wastes by ICP-MS, 200.8 27-Oct-09
Metals SemiTrace (Dissolved) in water US EPA Metals SemiTrace (Total) in Water Trace Metals (dissolved) in Water Trace Metals (dissolved) in Water Trace Metals (Total) in Water Trace Metals (Total) in Water US EPA US EPA US EPA US EPA US EPA
* Metals & Trace Elements by ICP-AES, 27-Oct-09 6010B * Determination of Trace Elements in Waters and Wastes by ICP-MS, 200.8 28-Oct-09
* Metals & Trace Elements by ICP-AES, 28-Oct-09 6010B

* Laboratory method(s) based on reference method
References
B.C.M.O.E US EPA B.C. Ministry of Environment US Environmental Protection Agency Test Methods
Comments:
Please direct any inquiries regarding this report to our Client Services group. Results relate only to samples as submitted. The test report shall not be reproduced except in full, without the written approval of the laboratory.
Page 55 FNR-2011-00265/ Part 1
Exova #104, 19575 - 55A Avenue Surrey, B.C. V3S-8P8, Canada
T: +1 (604) 514-3322 F: +1 (604) 514-3323 E: NWL-Surrey@exova.com W: www.exova.com
Project ID: Bill To: Cascade Environmental Resource Group Name: Report To: Cascade Environmental Resource Group
#203 - 38026 2nd Avenue Squamish, BC, Canada V8B 0C3 Attn: Christine Becker Sampled by: MN Company: CERG NWL Number: Sample Date: 710095-1 Oct 26, 2009
Location: LSD: P.O.:
Lot ID:
710095
Control Number: Date Received: Oct 27, 2009 Date Reported: Report Number: 1267596
Sample Description: Surface Tailrace
*FID1 A, (091027\FID00011.D - 091027\FID00006.D) -C10 -C12 -C14 -C16 -C18 -C20 -C22 -C24 -C26 -C28 -C30 -C32 pA
CARBON NUMBER
40
30
20
10
0 0 2 4 6 8 TYPICAL PRODUCT CHROMATOGRAMS Heavily Weathered Crude

Sig. 1 in C:\HPCHEM\...\020F0401.D
1 2 | . . . 1 6 | . C R O A B N N M ER U B 2 0 2 4 2 8 3 2 3 6 4 0 4 4 4 8 5 5 6 2 6 0 . . | . . . | . . . | . . . | . . . | . . . | . . . | . . . | . .. | . .. | . .. |
10
12
14
min
Diesel Fuel
Sig. 1 in D:\HPCHEM\...\007F0101.D
Motor Oil 10W30

1.0e6
78 | |
9 10 | |
12 |
14 |
16 . |
18 . |
CARBON NUMBER 20 24 28 32 . | . . . | . . . | . . . |
36 40 . . . | . . . |
1.4e5
12 |
16 | .
C R O A B N N M ER U B 20 24 28 32 36 40 44 48 52 56 60 . . | . . . | . . . | . . . | . . . | . . . | . . . | . . . | . .. | . .. | . .. |
3.0e4
1.0e4
0 0 Time (min.) 16
Time (min.)
30
Time (min.)
30
Product Carbon Number Ranges Gasoline Varsol C4-C12 C8-C12 Kerosene Diesel C7-C16 C8-C22 Lubricating Oils Crude Oils C20-C40 C3-C60+
Terms and conditions: www.exova.ca/terms&conditions.html
Page 56 FNR-2011-00265/ Part 1
Page 57 FNR-2011-00265/ Part 1
Report Transmission Cover Page

Bill To: Cascade Environmental Report To: Cascade Environmental #203 - 38026 2nd Avenue Squamish, BC, Canada V8B 0C3 Attn: Christine Becker Sampled By: CB Company: CERG Project: ID: Name: Location: LSD: P.O.: Acct code: Lot ID: Approval Status: Invoice Frequency: COD Status: Control Number: Date Received: Date Reported: Report Number:
710339
Approved by Lot
Oct 28, 2009 Oct 29, 2009 1268089
Contact & Affiliation Lesley Nelson Cascade Environmental Resource
Address #203 - 38026 2nd Avenue Squamish, British Columbia V8B 0C3 Phone: (604) 815-0901 Fax: (604) 815-0904 Email: lnelson@cerg.ca #203 - 38026 2nd Avenue Squamish, British Columbia V8B 0C3 Phone: (604) 815-0901 Fax: (604) 815-0904 Email: cbecker@cerg.ca
Delivery Commitments On [Lot Approval and Final Test Report Approval] send (Invoice) by Post M
Christine Becker Cascade Environmental Resource
On [Lot Verification] send (COA) by Email - Single Report On [Report Approval] send (COC, Test Report) by Email - Merge Reports
Notes To Clients:
The information contained on this and all other pages transmitted, is intended for the addressee only and is considered confidential. If the reader is not the intended recipient, you are hereby notified that any use, dissemination, distribution or copy of this transmission is strictly prohibited. If you receive this transmission by error, or if this transmission is not satisfactory, please notify us by telephone.
Page 58 FNR-2011-00265/ Part 1
Sample Custody
Bill To: Cascade Environmental Report To: Cascade Environmental #203 - 38026 2nd Avenue Squamish, BC, Canada V8B 0C3 Attn: Christine Becker Sampled By: CB Company: CERG Project: ID: Name: Location: LSD: P.O.: Acct code: Lot ID: 710339 Control Number: Date Received: Oct 28, 2009 Date Reported: Oct 29, 2009 Report Number: 1268089
Sample Disposal Date: November 28, 2009

All samples will be stored until this date unless other instructions are received. Please indicate other requirements below and return this form to the address or fax number on the top of this page.
Extend Sample Storage Until The following charges apply to extended sample storage: Storage for an additional 30 days Storage for an additional 60 days Storage for an additional 90 days
(MM/DD/YY)
S. 21
per sample per sample per sample
Return Sample, collect, to the address below via: Greyhound DHL Purolator Other (specify) Name Company Address Phone Fax Signature
Page 59 FNR-2011-00265/ Part 1
Page 1 of 15
Analytical Report
Reference Number Sample Date Sample Time Sample Location Sample Description Matrix Analyte Extractable Petroleum Hydrocarbons - Water EPHw10-19 EPHw19-32 Units ug/L ug/L
710339-1 Oct 27, 2009 12:10 Tailrace / Surface Water Results <100 600 Results Results
100 100
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Analytical Report
Reference Number Sample Date Sample Time Sample Location Sample Description Matrix Analyte Metals Dissolved Titanium Aluminum Antimony Arsenic Barium Beryllium Bismuth Boron Cadmium Chromium Cobalt Copper Iron Lead Lithium Manganese Molybdenum Nickel Selenium Silver Strontium Sulfur Tellurium Thallium Thorium Tin Uranium Vanadium Zinc Zirconium Metals Total Aluminum Antimony Arsenic Barium Beryllium Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Dissolved Total Total Total Total Total Units mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L
710339-1 Oct 27, 2009 12:10 Tailrace / Surface Water Results <0.010 0.081 <0.0002 0.0008 0.004 <0.00004 <0.001 0.011 0.00002 <0.0004 0.00003 0.001 0.01 <0.0001 <0.001 0.0017 0.0002 <0.001 <0.0006 <0.00001 0.014 0.5 <0.0001 <0.00001 <0.0004 <0.0001 <0.0004 0.0001 0.01 <0.0001 0.174 <0.0002 0.001 0.005 <0.00004
710339-2 Oct 27, 2009 12:35 Background / Surface Water Results <0.01 0.061 <0.0002 0.0003 0.004 <0.00004 <0.001 0.004 <0.00001 <0.0004 0.00002 <0.001 <0.01 <0.0001 <0.001 0.0006 0.0002 <0.001 <0.0006 <0.00001 0.012 0.5 <0.0001 <0.00001 <0.0004 <0.0001 <0.0004 <0.0001 <0.001 <0.0001 0.113 <0.0002 0.0003 0.005 <0.00004 Results
0.01 0.005 0.0002 0.0002 0.001 0.00004 0.001 0.004 0.00001 0.0004 0.00002 0.001 0.01 0.0001 0.001 0.0002 0.0001 0.001 0.0006 0.00001 0.001 0.2 0.0001 0.00001 0.0004 0.0001 0.0004 0.0001 0.001 0.0001 0.005 0.0002 0.0002 0.001 0.00004
Page 61 FNR-2011-00265/ Part 1
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Analytical Report
Reference Number Sample Date Sample Time Sample Location Sample Description Matrix Analyte Metals Total - Continued Bismuth Total Boron Total Cadmium Total Calcium Total Chromium Total Cobalt Total Copper Total Iron Total Lead Total Lithium Total Magnesium Total Manganese Total Molybdenum Total Nickel Total Phosphorus Total Potassium Total Selenium Total Silicon Total Silver Total Sodium Total Strontium Total Sulfur Total Tellurium Total Thallium Total Thorium Total Tin Total Uranium Total Vanadium Total Zinc Total Zirconium Total Physical and Aggregate Properties Solids Total Suspended Routine Water pH @ 25 C Calcium Dissolved Magnesium Dissolved
710339-1 Oct 27, 2009 12:10 Tailrace / Surface Water Results <0.001 0.013 0.00004 3.70 <0.0004 0.00007 0.002 0.105 0.0001 <0.001 0.19 0.0038 0.0003 <0.001 <0.01 0.2 <0.0006 1.72 <0.00001 1.37 0.015 0.5 <0.0001 <0.00001 <0.0004 <0.0001 <0.0004 0.0003 0.014 <0.0001 <2 7.03 3.6 0.2
710339-2 Oct 27, 2009 12:35 Background / Surface Water Results <0.001 0.005 <0.00001 3.12 <0.0004 0.00005 <0.001 0.036 <0.0001 <0.001 0.15 0.0016 0.0003 <0.001 <0.01 0.2 <0.0006 1.69 <0.00001 0.87 0.013 0.5 <0.0001 <0.00001 <0.0004 <0.0001 <0.0004 0.0002 0.001 <0.0001 4 6.90 3.1 0.1 Results
Units mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L
0.001 0.004 0.00001 0.05 0.0004 0.00002 0.001 0.01 0.0001 0.001 0.05 0.0002 0.0001 0.001 0.01 0.1 0.0006 0.05 0.00001 0.02 0.001 0.1 0.0001 0.00001 0.0004 0.0001 0.0004 0.0001 0.001 0.0001 1
mg/L mg/L
0.1 0.1
Page 62 FNR-2011-00265/ Part 1
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Analytical Report
Reference Number Sample Date Sample Time Sample Location Sample Description Matrix Analyte Routine Water - Continued Phosphorus Potassium Silicon Sodium Hardness Dissolved Dissolved Dissolved Dissolved as CaCO3 Units mg/L mg/L mg/L mg/L mg/L
710339-1 Oct 27, 2009 12:10 Tailrace / Surface Water Results <0.01 0.2 1.60 1.2 10
710339-2 Oct 27, 2009 12:35 Background / Surface Water Results <0.01 0.1 1.62 0.7 8 Results
0.01 0.1 0.05 0.1 5
Approved by: Marie England Consulting Scientist

Page 63 FNR-2011-00265/ Part 1
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Quality Control
Metals Dissolved
Certified Reference Material Aluminum Antimony Arsenic Barium Beryllium Boron Cadmium Chromium Cobalt Copper Iron Lead Manganese Molybdenum Nickel Selenium Silver Strontium Thallium Vanadium Zinc Date Acquired: Replicates Titanium Sulfur Date Acquired: Units mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L Measured 0.249 0.0723 0.0628 0.192 0.0745 0.092 0.05450 0.0638 0.07710 0.054 0.29 0.154 0.3640 0.0557 0.209 0.1060 0.01380 0.048 0.06390 0.7470 0.126 Target 0.301 0.0750 0.0650 0.201 0.07500 0.087 0.05800 0.0680 0.08000 0.057 0.32 0.1530 0.3760 0.06000 0.221 0.1100 0.01500 0.050 0.06500 0.75000 0.130 Lower Limit 0.257 0.0558 0.0530 0.183 0.06540 0.070 0.04960 0.0563 0.07010 0.053 0.28 0.1308 0.3448 0.04980 0.198 0.0935 0.01260 0.042 0.05270 0.66390 0.115 Upper Limit 0.345 0.0942 0.0770 0.219 0.08460 0.104 0.06640 0.0797 0.08990 0.062 0.36 0.1752 0.4132 0.07020 0.244 0.1265 0.01740 0.058 0.07730 0.83610 0.145 Passed QC yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes
October 28, 2009 Units mg/L mg/L October 28, 2009 Replicate 1 <0.010 0.5 Replicate 2 <0.01 0.5 % RSD Criteria 30 30 Absolute Criteria 0.012 3.0 Passed QC yes yes
Metals Total
Blanks Calcium Iron Magnesium Manganese Phosphorus Potassium Silicon Sodium Date Acquired: Calcium Iron Magnesium Units mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L October 28, 2009 mg/L mg/L mg/L <0.05 <0.010 <0.05 -0.13 -0.029 -0.09 0.17 0.031 0.09 yes yes yes Measured <0.05 <0.010 <0.05 <0.005 <0.01 <0.1 <0.05 <0.02 Lower Limit -0.08 -0.030 -0.06 -0.0098 -0.033 -0.30 -2.55 -0.23 Upper Limit 0.10 0.030 0.06 0.0022 0.027 0.30 3.15 0.19 Passed QC yes yes yes yes yes yes yes yes
Page 64 FNR-2011-00265/ Part 1
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Quality Control

Blanks Manganese Phosphorus Potassium Silicon Sodium Date Acquired: Calibration Check Calcium Iron Magnesium Manganese Phosphorus Potassium Silicon Sodium Date Acquired: Units mg/L mg/L mg/L mg/L mg/L October 28, 2009 Units mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L October 28, 2009 Units mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L Measured 0.572 0.150 0.128 0.39 0.145 0.19 0.116 50.6 0.128 0.156 0.11 0.620 0.316 30.1 0.772 0.114 0.42 24 0.217 0.0283 10.2 0.10 0.132 1.47 Target 0.601 0.1500 0.1310 0.401 0.15100 0.175 0.11600 0.1350 0.16100 0.114 0.3050 Lower Limit 0.502 0.1116 0.1067 0.365 0.13210 0.135 0.09920 46.23 0.1119 0.14090 0.104 0.560 0.2603 26.50 0.6846 0.09960 0.396 21.30 0.1870 0.02550 8.02 0.085 0.10640 1.32780 Upper Limit 0.700 0.1884 0.1553 0.437 0.16990 0.225 0.13280 54.21 0.1581 0.18110 0.125 0.722 0.3497 33.70 0.8214 0.14040 0.486 28.50 0.2530 0.03450 11.98 0.115 0.15560 1.67220 Passed QC yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes % Recovery 97.21 70.40 96.67 97.40 96.78 89.72 102.83 91.29 Lower Limit 90 85 90 90 90 85 80 90 Upper Limit 110 115 110 110 110 115 120 110 Passed QC yes yes yes yes yes yes yes yes Measured <0.005 <0.01 <0.1 <0.05 <0.02 Lower Limit -0.0098 -0.033 -3.83 -2.40 -0.23 Upper Limit 0.0022 0.027 4.09 3.00 0.19 Passed QC yes yes yes yes yes
Certified Reference Material Aluminum Antimony Arsenic Barium Beryllium Boron Cadmium Calcium Chromium Cobalt Copper Iron Lead Magnesium Manganese Molybdenum Nickel Potassium Selenium Silver Sodium Strontium Thallium Vanadium
0.12000 0.441 0.2200 0.03000 0.100 0.13100 1.50000
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Quality Control

Certified Reference Material Units Zinc mg/L Date Acquired: Replicates Calcium Iron Magnesium Manganese Phosphorus Potassium Silicon Sodium Sulfur Date Acquired: October 28, 2009 Units mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L October 28, 2009 Replicate 1 3.70 0.105 0.19 <0.005 <0.01 0.2 1.72 1.37 0.5 Replicate 2 3.68 0.097 0.19 <0.005 <0.01 0.2 1.71 1.38 0.5 % RSD Criteria 20 20 20 20 20 20 20 20 20 Absolute Criteria 0.05 0.050 0.05 0.0050 0.050 0.10 0.10 0.10 0.0 Passed QC yes yes yes yes yes yes yes yes yes Measured 0.26 Target 0.260 Lower Limit 0.230 Upper Limit 0.290 Passed QC yes
Routine Water
Blanks Calcium Iron Magnesium Manganese Phosphorus Potassium Silicon Sodium Date Acquired: Calcium Iron Magnesium Manganese Phosphorus Potassium Silicon Sodium Date Acquired: Calibration Check Calcium Iron Magnesium Manganese Phosphorus Units mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L October 28, 2009 mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L October 28, 2009 Units mg/L mg/L mg/L mg/L mg/L % Recovery 96.62 67.00 95.95 97.10 97.94 Lower Limit 90 85 90 90 90 Upper Limit 110 115 110 110 110 Passed QC yes yes yes yes yes <0.1 <0.005 <0.1 <0.001 <0.01 <0.1 <0.05 <0.1 -0.13 -0.024 -0.07 -0.009 -0.14 -0.8 -1.76 -0.3 0.16 0.025 0.08 0.002 0.16 0.8 2.02 0.4 yes yes yes yes yes yes yes yes Measured <0.1 <0.005 <0.1 <0.001 <0.01 <0.1 <0.05 <0.1 Lower Limit -0.05 -0.031 -0.05 -0.008 -0.04 -0.4 -0.20 -0.2 Upper Limit 0.05 0.029 0.07 -0.000 0.04 0.4 0.25 0.2 Passed QC yes yes yes yes yes yes yes yes
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Quality Control
Routine Water - Continued

Calibration Check Potassium Silicon Sodium Date Acquired: Units mg/L mg/L mg/L October 28, 2009 Units mg/L mg/L mg/L mg/L mg/L mg/L Measured 25.2 0.288 15.1 0.380 12.3 4.9 Target 25.11 0.321 15.04 0.376 12.4 5.0 Lower Limit 21.93 0.261 13.00 0.342 10.6 4.3 Upper Limit 28.29 0.339 17.08 0.410 14.3 5.6 Passed QC yes yes yes yes yes yes % Recovery 87.84 100.90 92.89 Lower Limit 85 80 90 Upper Limit 115 120 110 Passed QC yes yes yes
Certified Reference Material Calcium Iron Magnesium Manganese Potassium Sodium Date Acquired: Replicates Calcium Iron Magnesium Manganese Phosphorus Potassium Silicon Sodium Date Acquired: Hardness Date Acquired:
October 28, 2009 Units mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L October 28, 2009 mg CaCO3/L October 28, 2009 10.0 9.99 20 1.000 yes Replicate 1 3.6 0.012 0.2 <0.001 <0.01 0.2 1.60 1.2 Replicate 2 3.6 0.013 0.2 <0.001 <0.01 0.2 1.58 1.2 % RSD Criteria 30 30 30 30 30 30 30 30 Absolute Criteria 1.00 0.060 1.00 0.015 0.10 1.0 0.15 1.0 Passed QC yes yes yes yes yes yes yes yes
Extractable Petroleum Hydrocarbons Water

Blanks EPHw10-19 EPHw19-32 Date Acquired: Calibration Check EPHw10-19 EPHw19-32 Date Acquired: Replicates EPHw10-19 EPHw19-32 Units ug/L ug/L October 28, 2009 Units ug/mL ug/mL October 28, 2009 Units ug/L ug/L Replicate 1 500 500 Replicate 2 400 400 % RSD Criteria 60 60 Absolute Criteria 500 500 Passed QC yes yes % Recovery 101.28 101.28 Lower Limit 85 85 Upper Limit 115 115 Passed QC yes yes Measured <100 <100 Lower Limit -100 -100 Upper Limit 100 100 Passed QC yes yes
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Quality Control
Extractable Petroleum Hydrocarbons Water - Continued

Replicates Date Acquired: Matrix Spike EPHw10-19 EPHw19-32 Date Acquired: Units October 28, 2009 Units ug/L ug/L October 28, 2009 % Recovery 102 101 Lower Limit 79 81 Upper Limit 128 136 Passed QC yes yes Replicate 1 Replicate 2 % RSD Criteria Absolute Criteria Passed QC
Trace Metals Dissolved

Blanks Aluminum Antimony Arsenic Barium Beryllium Bismuth Boron Cadmium Chromium Cobalt Copper Iron Lead Lithium Manganese Molybdenum Nickel Selenium Silver Strontium Tellurium Thallium Thorium Tin Titanium Uranium Vanadium Zinc Zirconium Date Acquired: Aluminum Antimony Units g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L October 28, 2009 g/L g/L <5 <0.2 -6 -0.4 6 0.3 yes yes Measured <5 <0.2 <0.2 <1 <0.04 <1 <4 <0.01 <0.4 <0.02 <1 <10 <0.1 <1 <0.2 <0.1 <1 <0.6 <0.01 <1 <0.1 <0.01 <0.4 <0.1 <0.4 <0.4 <0.1 <1 <0.1 Lower Limit -10 -0.4 -0.5 -0 -0.10 -1.0 -6 -0.03 -0.1 -0.07 -1 -7 -0.1 -1 -1.0 -0.31 -1 -1.7 -0.05 -0 -0.7 -0.03 -1.5 -3.0 -0.2 -0.03 -0.35 -2 -0.0 Upper Limit 10 0.2 0.5 0 0.10 1.0 5 0.03 0.2 0.07 1 13 0.1 1 1.1 0.29 1 1.3 0.05 0 0.7 0.03 1.5 3.0 0.2 0.03 0.35 4 0.0 Passed QC yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes
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Quality Control

Blanks Arsenic Barium Beryllium Bismuth Boron Cadmium Chromium Cobalt Copper Iron Lead Lithium Manganese Molybdenum Nickel Selenium Silver Strontium Tellurium Thallium Thorium Tin Titanium Uranium Vanadium Zinc Zirconium Date Acquired: Calibration Check Aluminum Antimony Arsenic Barium Beryllium Boron Cadmium Chromium Cobalt Copper Iron Lead Manganese Units g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L October 28, 2009 Units g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L % Recovery 89.40 94.04 98.52 93.62 100.92 104.96 97.92 93.74 96.46 96.90 94.88 101.96 94.60 Lower Limit 70 85 90 90 90 70 90 90 90 90 80 90 90 Upper Limit 130 115 110 110 110 130 110 110 110 110 120 110 110 Passed QC yes yes yes yes yes yes yes yes yes yes yes yes yes Measured <0.2 <1 <0.04 <1 <4 <0.01 <0.4 <0.02 <1 <10 0.6 <1 <0.2 <0.1 <1 <0.6 <0.01 <1 <0.1 <0.01 <0.4 <0.1 <0.4 <0.4 <0.1 1 <0.1 Lower Limit -0.4 -0 -0.10 0.0 -18 -0.03 -0.1 -0.30 -1 -12 -0.3 -0 -0.5 -0.95 -1 -1.7 -0.67 -8 -0.7 -0.06 -0.7 -3.8 -0.3 -0.04 -0.30 -58 -0.0 Upper Limit 0.3 1 0.10 0.0 19 0.03 0.2 0.30 1 18 0.4 0 0.7 0.85 1 1.7 0.47 10 0.7 0.06 0.5 4.0 0.2 0.02 0.30 74 0.0 Passed QC yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes
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Quality Control

Calibration Check Molybdenum Nickel Selenium Silver Strontium Thallium Tin Vanadium Zinc Date Acquired: Replicates Aluminum Antimony Arsenic Barium Beryllium Boron Cadmium Chromium Cobalt Copper Iron Lead Lithium Manganese Molybdenum Nickel Selenium Silver Strontium Tellurium Thallium Thorium Tin Titanium Uranium Vanadium Zinc Zirconium Date Acquired: Units g/L g/L g/L g/L g/L g/L g/L g/L g/L October 28, 2009 Units g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L October 28, 2009 Replicate 1 81 <0.2 0.8 4 <0.04 11 0.02 <0.4 0.03 1 13 <0.1 <1 1.7 0.2 <1 <0.6 <0.01 14 <0.1 <0.01 <0.4 <0.1 <0.4 <0.4 0.1 10 <0.1 Replicate 2 80 <0.2 0.8 4 <0.04 12 0.02 <0.4 0.04 1 14 <0.1 <1 1.7 0.2 <1 <0.6 <0.01 14 <0.1 <0.01 <0.4 <0.1 <0.4 <0.4 0.1 9 0.2 % RSD Criteria 20 10 10 20 10 20 10 20 20 20 20 10 20 20 10 20 10 10 20 10 10 10 10 20 10 20 20 10 Absolute Criteria 20 1.0 1.0 5 1.00 5 0.50 5.0 0.50 5 50 0.5 5 0.5 0.50 5 0.5 0.50 0 0.5 0.10 0.1 0.5 0.5 0.10 0.50 5 0.5 Passed QC yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes % Recovery 93.52 95.76 99.44 0.14 94.20 99.24 94.44 90.66 99.78 Lower Limit 90 90 90 90 90 90 90 90 90 Upper Limit 110 110 110 110 110 110 110 110 110 Passed QC yes yes yes yes yes yes yes yes yes
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Quality Control
Trace Metals Total

Blanks Aluminum Antimony Arsenic Barium Beryllium Bismuth Boron Cadmium Chromium Cobalt Copper Lead Lithium Manganese Molybdenum Nickel Selenium Silver Strontium Tellurium Thallium Thorium Tin Titanium Uranium Vanadium Zinc Zirconium Date Acquired: Aluminum Antimony Arsenic Barium Beryllium Bismuth Boron Cadmium Chromium Cobalt Copper Lead Lithium Units g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L October 28, 2009 g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L <5 <0.2 0.3 <1 <0.04 <1 <5 <0.01 <0.4 <0.02 <1 <0.1 <1 -4 -0.6 -0.6 -0.1 -0.09 0.0 -12 -0.08 -0.1 -0.07500 -1.930 -0.150 -0 8 0.4 0.6 0.1 0.09 0.0 11 0.08 0.2 0.08700 1.430 0.210 0 yes yes yes yes yes yes yes yes yes yes yes yes yes Measured <5 <0.2 <0.2 <1 <0.04 <1 <5 <0.01 <0.4 <0.02 <1 0.4 <1 <0.2 <0.1 <1 <0.6 <0.01 <1 <0.1 <0.01 <0.4 <0.1 <0.4 <0.4 <0.1 <1 <0.1 Lower Limit -7 -0.4 -0.5 -0.1 -0.10 -3.0 -6 -0.03 -0.1 -0.06600 -0.830 -0.100 -0 -0.9 -0.31 -1 -1.7 -0.07 -0.3 -0.7 -0.03 -1.50 -3.0 -0.2 -0.0 -0.30 -2 -0.0 Upper Limit 7 0.2 0.5 0.2 0.10 3.0 5 0.03 0.2 0.06600 0.790 0.140 0 0.9 0.29 1 1.3 0.05 0.3 0.7 0.03 1.50 3.0 0.2 0.0 0.30 4 0.0 Passed QC yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes
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Quality Control

Blanks Manganese Molybdenum Nickel Selenium Silver Strontium Tellurium Thallium Thorium Tin Titanium Uranium Vanadium Zinc Zirconium Date Acquired: Calibration Check Aluminum Antimony Arsenic Barium Beryllium Boron Cadmium Chromium Cobalt Copper Lead Manganese Molybdenum Nickel Selenium Silver Strontium Thallium Tin Vanadium Zinc Date Acquired: Replicates Aluminum Units g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L October 28, 2009 Units g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L October 28, 2009 Units g/L Replicate 1 174 Replicate 2 168 % RSD Criteria 15 Absolute Criteria 100 Passed QC yes % Recovery 103.20 95.96 101.32 94.72 97.92 103.00 102.68 95.80 96.56 99.12 105.16 98.44 95.68 96.28 101.08 0.13 98.96 102.60 99.04 94.50 103.48 Lower Limit 70 85 90 90 90 70 90 90 90 90 90 90 90 90 90 90 90 90 85 90 90 Upper Limit 130 115 110 110 110 130 110 110 110 110 110 110 110 110 110 110 110 110 115 110 110 Passed QC yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes Measured <0.2 <0.1 <1 <0.6 <0.01 <1 <0.1 <0.01 <0.4 <0.1 <0.4 <0.4 <0.1 1 <0.1 Lower Limit -1.0 -1.67 -1 -2.5 -0.13 -0.2 -0.2 -0.32 -1.75 -0.5 -0.2 -0.1 -0.30 -4 -0.1 Upper Limit 1.1 1.81 1 1.5 0.07 0.2 0.2 0.34 0.95 0.4 0.3 0.1 0.30 6 0.1 Passed QC yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes
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Quality Control

Replicates Antimony Arsenic Barium Beryllium Boron Cadmium Chromium Cobalt Copper Lead Lithium Manganese Molybdenum Nickel Selenium Silver Strontium Tellurium Thallium Thorium Tin Titanium Uranium Vanadium Zinc Zirconium Date Acquired: Units g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L g/L October 28, 2009 Replicate 1 <0.2 1 5 <0.04 13 0.04 <0.4 0.07 2 0.1 <1 3.8 0.3 <1 <0.6 <0.01 15 <0.1 <0.01 <0.4 <0.1 4.3 <0.4 0.3 14 <0.1 Replicate 2 <0.2 1 5 <0.04 14 0.04 <0.4 0.07 1 0.1 <1 3.6 0.3 <1 <0.6 <0.01 15 <0.1 <0.01 <0.4 <0.1 4.2 <0.4 0.3 14 0.3 % RSD Criteria 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 20 15 15 15 15 15 15 15 15 Absolute Criteria 2.0 2.0 10.0 0.40 40 0.10 6.0 0.20000 5.000 1.000 10 1.0 0.20 10 5.0 0.10 10.0 0.5 0.10 1.00 1.0 1.0 1.0 0.40 10 1.0 Passed QC yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes
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Methodology and Notes

Method of Analysis
Method Name Alk, pH, EC, Turb in water EPH - Water Reference APHA BCELM Method * Electrometric Method, 4500-H+ B Date Analysis Started 28-Oct-09 Location Exova Surrey Exova Surrey Exova Surrey Exova Surrey Exova Surrey Exova Surrey Exova Surrey Exova Surrey Exova Surrey
* Extractable Petroleum Hydrocarbons 28-Oct-09 (EPH) in Water by GC/FID, EPH Water * Metals & Trace Elements by ICP-AES, 28-Oct-09 6010B * Metals & Trace Elements by ICP-AES, 28-Oct-09 6010B * Total Suspended Solids Dried at 103105'C, 2540 D * Determination of Trace Elements in Waters and Wastes by ICP-MS, 200.8 29-Oct-09 28-Oct-09
Metals SemiTrace (Dissolved) in water US EPA Metals SemiTrace (Total) in Water Solids Suspended (Total, Fixed and Volatile) Trace Metals (dissolved) in Water Trace Metals (dissolved) in Water Trace Metals (Total) in Water Trace Metals (Total) in Water US EPA APHA US EPA US EPA US EPA US EPA
* Metals & Trace Elements by ICP-AES, 28-Oct-09 6010B * Determination of Trace Elements in Waters and Wastes by ICP-MS, 200.8 28-Oct-09
* Metals & Trace Elements by ICP-AES, 28-Oct-09 6010B

* Laboratory method(s) based on reference method
References
APHA B.C.M.O.E US EPA Standard Methods for the Examination of Water and Wastewater B.C. Ministry of Environment US Environmental Protection Agency Test Methods
Comments:
Please direct any inquiries regarding this report to our Client Services group. Results relate only to samples as submitted. The test report shall not be reproduced except in full, without the written approval of the laboratory.
Page 74 FNR-2011-00265/ Part 1
Exova #104, 19575 - 55A Avenue Surrey, B.C. V3S-8P8, Canada
T: +1 (604) 514-3322 F: +1 (604) 514-3323 E: NWL-Surrey@exova.com W: www.exova.com
Project ID: Bill To: Cascade Environmental Resource Group Name: Report To: Cascade Environmental Resource Group
#203 - 38026 2nd Avenue Squamish, BC, Canada V8B 0C3 Attn: Christine Becker Sampled by: CB Company: CERG NWL Number: Sample Date: 710339-1 Oct 27, 2009
Location: LSD: P.O.:
Lot ID:
710339
Control Number: Date Received: Oct 28, 2009 Date Reported: Oct 29, 2009 Report Number: 1268089
Sample Description: Surface Tailrace
*FID1 A, (091028\FID00026.D - 091028\FID00006.D) -C10 -C12 -C14 -C16 -C18 -C20 -C22 -C24 -C26 -C28 -C30 -C32 pA
CARBON NUMBER
40
30
20
10
0 0 2 4 6 8 TYPICAL PRODUCT CHROMATOGRAMS Heavily Weathered Crude

1 2 | . . . 1 6 | . C R O A B N N M ER U B 2 0 2 4 2 8 3 2 3 6 4 0 4 4 4 8 5 5 6 2 6 0 . . | . . . | . . . | . . . | . . . | . . . | . . . | . . . | . .. | . .. | . .. |
10
12
14
min
Diesel Fuel
Sig. 1 in D:\HPCHEM\...\007F0101.D
Motor Oil 10W30

1.0e6
78 | |
9 10 | |
12 |
14 |
16 . |
18 . |
CARBON NUMBER 20 24 28 32 . | . . . | . . . | . . . |
36 40 . . . | . . . |
1.4e5
12 |
16 | .
C R O A B N N M ER U B 20 24 28 32 36 40 44 48 52 56 60 . . | . . . | . . . | . . . | . . . | . . . | . . . | . . . | . .. | . .. | . .. |
3.0e4
1.0e4
0 0 Time (min.) 16
Time (min.)
30
Time (min.)
30
Product Carbon Number Ranges Gasoline Varsol C4-C12 C8-C12 Kerosene Diesel C7-C16 C8-C22 Lubricating Oils Crude Oils C20-C40 C3-C60+
Terms and conditions: www.exova.ca/terms&conditions.html
Page 75 FNR-2011-00265/ Part 1
Page 76 FNR-2011-00265/ Part 1
ASHLU CREEK GREEN POWER PROJECT OPERATING PARAMETERS AND PROCEDURES REPORT (OPPR)
October 28, 2009 Revision A
Ashlu Creek Investments Limited Partnership Suite 303 38 Fell Avenue North Vancouver, B.C. V7P 3S2
Page 77 FNR-2011-00265/ Part 1
TABLE OF CONTENTS
Section 1.0 - Introduction ................................................................................................... 1 1.1 Background ......................................................................................................... 1 1.2 Project Description.............................................................................................. 1 1.2.1 Diversion structures .................................................................................... 1 1.2.2 IFR Measurement Stations.......................................................................... 3 1.2.3 Water Conveyance System ......................................................................... 3 1.2.4 Powerhouse ................................................................................................. 4 1.2.5 Tailrace ....................................................................................................... 4 1.2.6 Generating Equipment ................................................................................ 4 1.2.7 Energy Dissipation System ......................................................................... 5 1.2.8 Switchyard and Interconnection ................................................................. 5 1.2.9 Access Roads .............................................................................................. 5 Section 2.0 - Operating Parameters .................................................................................... 6 2.1 Design Parameters .............................................................................................. 6 2.2 Environmental..................................................................................................... 7 2.2.1 Instream Flow Release (IFR) .................................................................. 7 2.2.2 Flow Ramping............................................................................................. 7 2.2.3 Sediment Transport..................................................................................... 8 2.2.4 First Nations Relations................................................................................ 9 2.2.5 Community Relations ................................................................................. 9 2.3 Public Safety ....................................................................................................... 9 2.3.1 General site safety....................................................................................... 9 2.3.2 Kayak specific safety .................................................................................. 9 Section 3.0 - Operating Procedures .................................................................................. 11 3.1 Daily Operating Procedures.............................................................................. 11 3.2 Headpond filling and draining .......................................................................... 11 3.3 Tunnel and Penstock Flushing and Filling........................................................ 11 3.3.1 Initial flushing of water conveyance system.................................................... 12 3.3.2 Filling/pressurizing of water conveyance system ............................................ 12 3.4 Intake Water Level Management...................................................................... 12 3.5 Start-Up Procedures .......................................................................................... 13 3.6 Shut-Down Procedures ..................................................................................... 13 3.6.1 Normal Shutdown ..................................................................................... 13 3.6.2 Forced Outage........................................................................................... 14 3.6.3 Emergency Shutdown ............................................................................... 14 3.6.4 Long Term Outage.................................................................................... 15 3.7 Monitoring and Control Procedures.................................................................. 15 3.7.1 General...................................................................................................... 15 3.7.2 Protection Relays ...................................................................................... 16 3.7.3 Human Machine Interface (HMI).......................................................... 16 3.7.4 Historian.................................................................................................... 17 3.7.5 Web Based Digital Video System............................................................. 17 3.8 Maintenance and Inspection Program............................................................... 17
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3.8.1 Intake, sluiceway, rockfill weir, and spillway .......................................... 17 3.8.2 Fishladder.................................................................................................. 18 3.8.3 Shaft, Tunnel, and Penstock...................................................................... 18 3.8.4 Powerhouse Civil Works .......................................................................... 18 3.8.5 Tailrace ..................................................................................................... 19 3.8.6 Access Roads ............................................................................................ 19 3.8.7 Turbines/Generators.................................................................................. 19 3.8.8 Energy Dissipation System ....................................................................... 19 3.8.9 Back-up System ........................................................................................ 19 3.8.10 Controls and Protection............................................................................. 20 3.8.11 Switchyard ................................................................................................ 20 3.9 Trouble Shooting and Repair ............................................................................ 21 Section 4.0 - Operating Staff ............................................................................................ 22 4.1 Staffing Levels .................................................................................................. 22 4.2 Training............................................................................................................. 22 4.4 Safety ................................................................................................................ 22 Section 5.0 - Monitoring and Reporting ........................................................................... 23 5.1 Operations Flow Monitoring............................................................................. 23 5.2 Telecommunications ......................................................................................... 23 5.3 Operations Reports............................................................................................ 23 5.4 Environmental Reporting Requirements........................................................... 24 5.5 Ministry Reporting Requirements..................................................................... 24 Section 6.0 - Key Personnel.............................................................................................. 25
APPENDIX A General Arrangement Drawings.............................................................. 1 APPENDIX B Conditional Water License ...................................................................... 2 APPENDIX C DFO Authorization.................................................................................. 3 APPENDIX D Transport Canada / Navigable Waters Protection Division Approval .... 4 APPENDIX E Long term (5 year) Aquatic Monitoring Program ................................... 5 APPENDIX F Water Quality Management Plan (DRAFT) ............................................ 6
Page 79 FNR-2011-00265/ Part 1
Ashlu Creek Investments Limited Partnership
Section 1.0 - Introduction

1.1 Background
Ashlu Creek Investments Limited Partnership ("ACILP") is constructing a run-of-river hydroelectric generating station on Ashlu Creek, some 30km north west of Squamish. In 2003, BC Hydro awarded a twenty-year Electricity Purchase Agreement ("EPA") for the Ashlu Project under the 2002/2003 Green Power Generation Call. Under the EPA, BC Hydro contracted to purchase the energy generated by the Ashlu Creek Generating Station ("GS"). The EPA was amended in 2006 extending the contract to a period of thirty years. Water Stewardships Management and Standards Branch of the Ministry of Environment issued Conditional Water Licence #102203 (file #2001264) on July 10, 2006. The Licence allows for diversion of a maximum of 29.0 m/s of water from Ashlu Creek for the purpose of energy generation and requires that values for minimum Instream Flow Release (the IFR) are established. Authorization # 04-HPCA-PA2-000-000530 from the Department of Fisheries and Oceans Canada (DFO) requires a minimum all year around IFR of 2.42 m/s. In addition to the DOF requirements, Approval #8200-T10595.2 issued by Transport Canadas Navigable Waters Protection Division (NWPD) calls for instream flow releases to accommodate recreational use of the creek through kayakers during specific days and times as outlined in Section 2.2.1 of this document. The project has been designed and will operate to meet those requirements. The Licence further requires that the proponent clearly demonstrate the various processes for the diversion and use of water in the context of the preparation of an Operating Parameters and Procedures Report (OPPR"). In the context that there are requirements in any underlying approvals with respect to the use of water, diversion rates, ramping rates, etc, they will be represented in the following OPPR. Further the OPPR is intended to be a consolidation of permits which have impact on the operation of the project.
1.2
Project Description
1.2.1 Diversion structures

The diversion structure comprises of the following: Intake: The intake is a concrete structure that is located on the south side of the overall intake/diversion structure that spans Ashlu Creek. The intake diverts water from the head pond into the vertical tunnel shaft, the horizontal tunnel, the penstock, the distribution pipe and finally to the powerhouse. The conveyance system is designed for the maximum licensed flow of 29 m/s. Coarse and fine trash racks prevent debris from entering the tunnel shaft. The elevation of the intake inlet sill at the invert of the coarse trash rack is 272.0 m. A gate is installed between the fine trash rack and the tunnel shaft. The intake gate is open during normal operation. The gate is closed during head pond and tunnel/penstock filling and draining and in emergency situations that require a complete shut down of flows from the intake.
Operating Parameters and Procedures Revision A October 2009
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Such an emergency situation could be when during a load rejection condition at least one of the Turbine Inlet Valves or at least one of the Energy Dissipation System bypass valves fail to operate as intended and a complete depressurization of the water conveyance system is required. The intake gate contains within itself a small 600 mm butterfly valve, which acts as a bypass to the intake gate for the purpose of the, controlled filling of the water conveyance system. The procedures and allowable flow rates for filling and draining the headpond and water conveyance system are provided in Section 3.2s and 3.3 of this document. Sluiceway: The sluiceway is a 7 meter wide concrete channel that extends from the headpond to the downstream side of the weir/intake structures. The left (south) abutment wall of the sluiceway upstream of the sluicegate contains the intake opening with the coarse trash rack. The sluiceways purpose is to flush sediment that may accumulate in the headpond in front of the intake inlet and to manage flows in excess of the intakes flow capacity (i.e. greater than 29 m/s). The sluiceways design capacity is 150 m/s, but it is expected to operate the sluiceway only to 70 m/s. The base elevation of the sluiceway channel inlet is 270.5 m. The flow through the sluiceway is controlled by the vertical sluiceway gate, located approximately mid-way along the sluiceway channel. The sluiceway gate is operated through a hydraulic power unit located near the sluiceway gate. The operation of the gate is controlled by a local automated system located in the intake control building atop of the rockfill weir. Rockfill Weir: The rockfill weir extends 55 m between the sluiceway channel and the bypass spillway. The weir has an impermeable glacial till core with a series of increasing coarse filter layers and a final armored layer of rip rap. There is an upstream liner blanket keyed into the impermeable core which extends up into the headpond. The overall design of the intake weir with the midstream rock fill weir allows the effective management of sediments under both average and high flow events. The weir crest elevation is 279.0m. Spillway: The spillway is a 35 meter wide channel cut into natural rock on the left bank of Ashlu Creek across from the intake and sluiceway. The spillways primary purpose is to pass flows that are in excess of the combined intake and sluiceway flow capacity (i.e. greater than 29 m/s + 70 m/s). Flow through the spillway is controlled by a 5.5 m high, Obermeyer weir that is comprised of five steel plate flap gate sections which in turn are raised by five inflatable rubber bladders. To provide enhanced control, the Obermeyer weir and gates are divided into two sections: one gate panel (referred to as Section 1) and a section comprised of four gate panels (referred to as Section 2/5). The elevation of the fully deflated (open) bladder and gates is elevation 271.0 m; the elevation of the fully inflated (closed) bladder and gates is 276.5 m, for a total height of 5.5 m for the fully inflated weir. The flow capacity of the spillway with fully deflated Obermeyer gate is 918 m/s. The flow capacity of the spillway with Section 1 deflated and Section 2/5 inflated is 184 m/s (20% of full capacity).
Communication between the powerhouse and intake and the power supply to the intake is provided by cables which are embedded in the Forest Service Road between the powerhouse and the intake. A radio system with a repeater station at the Mile 25 bridge location provides redundancy for communication in the instance the fiber optic cable is not functioning.
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1.2.2 IFR Measurement Stations

The primary gauge for IFR measurement is at the first suitable location downstream of the intake which is the transition from a relatively flat gravel and boulder field into a bedrock canyon, approximately 250 m downstream of the intake. A pressure transducer level probe is installed in this location and connected to the intake control building by a teck cable suitable for direct burial. The water level is measured on a continuous basis and relayed to the powerhouse control system in real time. A water level benchmark corresponding with the 2.42 m/s IFR required under the DFO Authorization has been established in March 2009 and will serve as a visual reference to calibrate the level probe. A secondary gauge for backup and calibration purposes is installed approximately 800 m downstream of the intake at a location that has a proven flow discharge curve which was established during the development phase of the project ("Mile 25 bridge") and has been monitored on a regular basis. Approximately 10% of the flows measured at this location are contributed to a small tributary between intake and this location. Therefore, the IFR immediately downstream of the intake is approximately 90% of the flow measured at this location. The secondary station is powered by a solar panel with battery backup and direct radio link to the powerhouse. The station also provides data required under the DFO Authorization and houses a kayaker warning system as required by NWPD.
1.2.3 Water Conveyance System

The water conveyance system consists of the following components: Structure Vertical shaft Horizontal tunnel Tunnel steel liner Penstock Distribution pipe lengths (m) 115 4,442 180 160 45 elevation (m at entry) 268 153 88 86 53 diameter (m) 3.8 4.08 2.8 3.8 3.8 to 2.0 (varies)
The shaft commences at the intake structure and transitions into the horizontal tunnel through a blasted chamber (commonly referred to as "boot"). The chamber is approximately 7.0 m wide and 8.0 m long. This enlarged cross section results in a reduced velocity of the flow through the chamber and reduced head losses due to the nearly 90 degree deflection of the flow. The tunnel commences at an average slope of 1.5% downwards towards the tunnel portal. A concrete plug is installed approximately 180 m upstream of the tunnel portal. The tunnel from the portal to the plug is lined with a 2.8 m diameter steel pipe which is sealed into the tunnel plug. The tunnel liner welded to the steel penstock just outside the tunnel portal. The penstock is then buried and it passes under the Forest Service Road before following more or less the natural slope
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from the road down to the powerhouse. Three concrete thrust blocks are installed at each of the penstock alignment changes. The total volume of the system, when filled with water, is approximately 62,000 m. The total gross head from the full headpond level to the tail race water level at the powerhouse is 224 meters (276.0 to 52.0m).
1.2.4 Powerhouse
The powerhouse is a pre-engineered steel clad building with the overall footprint of 55.0 m by 14.5 m and an eave height of 13 m (55 masl to 68 masl). An 80 ton gantry crane is supported by the steel structure. The steel structure is supported by a reinforced concrete foundation. The distribution pipe is embedded in concrete on the side of the powerhouse facing away from the creek (west side). Within the powerhouse is the ancillary equipment for the turbine generators as well as the mechanical and electrical station services, including lighting, heating, ventilation and the back up generator. The hydraulic power units and generator bearings use fully biodegradable oils. All floor drains are connected to an oil-water separator system. The building also includes a security and fire alarm system tied into the plants control system.
1.2.5 Tailrace
The tailrace is 55 m wide x 12 m long between the powerhouse and the tailrace weir. The diverted water flows back into the creek over the low profile tailrace weir on the creek side of the tail race. Three draft tube gates allow isolation of the individual turbines from the tailrace in order to service the turbines without draining the tail race and allowing the other two units to operate while one unit is isolated for inspection, service or repair.
1.2.6 Generating Equipment

The powerhouse contains three horizontal-shaft Francis turbines, each with the following specifications: Rated output (each): Diameter: Head: Speed: Runner material: 16.5 MW 1,206 mm 225.0 m 720 rpm Stainless Steel
Each turbine is directly coupled to a synchronous generator with the following specifications: Rated output (each): Voltage: Excite: Bearings: 16.6 MW 13.8 KV Brushless with automatic voltage regulator (2) self-lubricated bearings complete with temperature and oil level sensors. Mineral based bearing oil. Closed loop cooling water heat exchanger system with glycolwater coolant. air cooled, see Section 3.0
Stator: Controls:
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1.2.7 Energy Dissipation System

The Energy Dissipation System ("the EDS") is housed within the powerhouse structure. It consists of a set of six 30 inch ball valves that are connected to the penstock by an extension of the header pipes past the turbine branches. The valves in turn are connected to vertical pipes that end in dissipation baskets located in the dissipation chamber beneath the valve room. The EDS is capable of diverting and dissipating the full licensed flow of 29.0 m/s or 4.83 m/s per branch. The ball valves are capable to fully open and close within 30 seconds which is approximately the same time for the TIVs to close under a load rejection trip (see section 3.6.2). The valves are not designed for gradual increase and decrease of flows, mainly due to expected cavitation under partially opened condition. In order to allow controlled gradual incremental changes of flows through the EDS, two of the six dissipation baskets are equipped with adjustable sleeve valves (adjustable EDS valves). The adjustable sleeves can be operated at minimum increments of 1% of branch flow or 0.048 m/s per step.
1.2.8 Switchyard and Interconnection

The switchyard is located approximately 20 meters adjacent to the powerhouse. It has the following components and specifications: 40/60/75 MVA 13.8/230KV oil cooled transformer 230 kV SF6 circuit breaker Secondary revenue metering HV disconnect switch R/C foundation slabs complete with oil retention and separation facilities Crushed stone ground cover throughout 2.1 m height security fencing Grounding grid
The 230 kV transmission line is a 3 phase unshielded 795 kcmil ACSR 26/7 Drake conductor mounted on timber poles with a total length of 3.2 km. From the Ashlu switchyard, the transmission line follows the Forest Service Road for its entire length, spanning over the Ashlu Creek approximately 600 m downstream of the powerhouse. The line connects at the Point of Interconnection ("POI") to a 500 m long spur tap line constructed by BCTC. The tap line connects to BCTC's 2L12 transmission line which subsequently connects to BCTCs Cheekye substation near Squamish.
1.2.9 Access Roads

General access to the site is provided through the Ashlu Creek Forest Service Road ("Ashlu FSR 9160, "the FSR"). ACILP is holding Road Use Permit #9160-06-02 and is named secondary user of the road. Access to the switchyard and powerhouse site is provided through a new 200 meter long all-weather spur road branching off the FSR. Access to the intake site is provided through a 400 meter all-weather long spur road branching off the FSR in the upper reaches of the Ashlu Creek valley. Both roads are gated to control public access to the sites.
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Section 2.0 - Operating Parameters

2.1 Design Parameters
Ashlu Creek Hydroelectric Project 35km northwest of Squamish, BC Direct tap into BCTC transmission line 2L12 Ashlu Creek Run-of-River 49.5 MW 29.0 m/s 29.0 m/s 1,200 m/s 276-52 = 224 m
Project Title: Project Location: Interconnection: Water Source: Project Operation: Rated Capacity of Plant: Design Flow: Water License Flow: Design Flood (intake): Gross Head:
Main Intake Structures: Reinforced concrete structure comprised of an intake chamber with coarse and fine trash racks, provisions for stop logs, intake gate and steel elbow to connect to the tunnel shaft. Reinforced concrete sluiceway channel with sluicegate and provision for stop logs. Rockfill weir with impermeable till core. Spillway excavated in rock with reinforced concrete walls and foundation and inflatable Obermeyer flap gate. Shaft and Tunnel: 115 m vertical shaft with transition chamber to 4,442 m of horizontal tunnel with average slope of 1.5%. Reinforced concrete tunnel plug with transition to 2.8 m tunnel steel liner for the balance of 180m of the tunnel. Penstock: Continuously welded and buried 2.8 m diameter high pressure steel penstock, length approximately 160 m, laid in direct line from the tunnel portal to the powerhouse north end, three reinforced concrete thrust blocks where alignment changes occur. Powerhouse: Concrete substructure, structural steel and steel clad superstructure, steel roof, equipped with three turbines/generators, energy dissipation system, switchgear, protection and control equipment. Turbines: Generators: Switchyard: Three horizontal Francis turbines, each rated 17.0 MW for total installed capacity of 51.0 MW Direct Coupled Synchronous at 13.8KV, each rated 16.6 MW for a total installed capacity of 49.9 MW Step-up 13.8/230KV transformer, breaker and disconnection switch, wave-trap, fenced perimeter
Transmission Line: 3.2 km, 230 kV, timber pole, 3-phase line to BCTC 2L12 transmission line direct tap Access: Road access through Ashlu Creek Forest Service Road.
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2.2
Environmental
2.2.1 Instream Flow Release (IFR)

IFR requirements for this project are defined in the Authorization issued by DFO and the Approval issued by NWPD. It is noted that when the two documents call for different minimum flows at the same time, the higher flow will be released. The IFR will be measured at the stations described under Section 1.2.2. Requirements under DFO: DFO Authorization 04-HPAC-PA2-000-000530 sets the minimum IFR at 2.42 m/s year around with no seasonal adjustments required. This flow is primary provided through a 30 inch bypass pipe has been installed as part of the sluiceway structure. The center inlet elevation of the pipe is 272.0 meters, while the normal operating water level is 276.0. The inlet is protected by a coarse trash rack and the inflow can be controlled by a manually actuated knife valve. The IFR valve will be calibrated to the required minimum flow during the commissioning of the plant. Because the water level in the head pond will remain nearly unchanged during normal operation, it is not expected that the valve requires adjustments during the operational phase of the project. The sluiceway flap gate acts as a backup system to meet the IFR in case the 30 inch pipe is not providing the required flows or is shut down for maintenance and repair works. The capacity of the flap gate is approximately 3 m/s at normal head pond operating water level. Requirements under Transport Canada / Navigable Waters Protection Division: Approval #8200-T-10595.2 issued by NWPD calls for instream flow releases to accommodate recreational use of the creek through kayakers during specific days and times as follows if pre-booked by kayakers: Four weekends (Saturdays and Sundays) in May and eight weekends (Saturday and Sundays) in August and September for a total of 24 days and on each of those days between 9am and 6pm Flow release to range between 16 m/s and 32 m/s. Amounts of actual release to be coordinated between ACILP and the kayakers.
An online booking system will be developed in time to be available for the spring 2010 kayaking season. The system will allow kayakers to book flow release days within the windows described above and select their preferred release rate within the required range. Flows for kayaking purposes will be primarily released and controlled through the sluiceway.
2.2.2 Flow Ramping

The DFO Authorization for Ashlu Creek stipulates a ramping rate of 90 to 120 minutes for full diverted flow of 29 m/s and requires that actual ramping rates will be established during the commissioning process. Actual ramping rates in the diversion reach will be measured by the two IRF measurement stations (refer to Section 1.2.2). Ramping rates downstream of the diversion will be measured manually during the commissioning process. The areas between the powerhouse tail race and the downstream side of the "twin bridges" have been identified at those potentially affected by the ramping rates. Specific locations
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within this area where stranding of fish and fry could occur have been identified by the project EM prior to commissioning. Those locations will be specifically monitored during all ramping tests with the goal to confirm that a ramping rate of 90 minutes is adequate for low and medium flow conditions and that a shorter ramping rate may be adequate for high flow conditions. Further to DFO requirements, ramping rates are required under the permits issued by TC/NWPD. The purpose of those ramping rates is to protect kayakers from impact of sudden flow changes within the diversion reach and downstream of the powerhouse and the rates can be identical to the rates acceptable to DFO and established during the commissioning of the plant. Ramping between 3.0 m/s and 29.0 m/s during normal operation will be provided through gradual increase and decrease of the turbine flows in accordance with the established ramping rates. The lower number is determined by the minimum flow required to operate one of the three turbines. Ramping between 0 to 3.0 during start up and normal shut down will be provided through one of the adjustable EDS valves over the duration of 9 minutes. In case of a load rejection trip under full load, the TIVs will close within approximately 30 seconds to prevent damages to the generating equipment. At the same time all six ball valves of the EDS will open and there will be no effective net change of the flow rates diverted at the intake and consequently discharged at the tail race. Shortly after the trip, the EDS ball valves and adjustable EDS valves will start closing in a preprogrammed sequence to allow gradual reduction of flow at the approved ramping rates. The sequence will start with one adjustable valve closing over a duration of 15 minutes (assumed ramping duration of 90 minutes). Then one of the non adjustable ball valves will close within 30 seconds while the first adjustable valve opens over the same duration. Then the adjustable valve will close again over a duration of 15 minutes and upon completion the next non adjustable ball valve will close within 30 seconds while the adjustable valve opens again.
2.2.3 Sediment Transport

It is expected that sediment will deposit over time during low and medium creek flow conditions within the area of the head pond. During low and medium flow conditions (up to 100 m/s), the flows in the head pond is directed towards the intake and sluiceway. The elevation of the sluiceway apron adjacent to the intake is approximately 2.0 m lower then the elevation of the intake sill and this apron is constructed with a 2% slope through the sluiceway. Therefore, sediment that migrates on the head pond floor or is suspended within the bottom 2 m will pass the intake inlet sill and pass through the sluiceway from where it is discharged into the creek downstream of the intake area. It is expected that minor amounts of suspended sediment may enter the intake structure and will be eventually discharged back into the creek at the powerhouse tailrace after passing through the generating equipment. During high flow conditions (more then 100m/s) the Obermeyer gates in the spillway will be lowered and the majority of the creek water will pass through the spillway. It is expected that the majority of accumulated sediment in the head pond will at this time be flushed through the spillway and the head pond therefore effectively "cleaned". A permanent deposit of sediment in the head pond is therefore not expected and the overall natural sediment and bed-load migration pattern of the creek will be maintained.
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2.2.4 First Nations Relations

ACILP has forged a strong relationship with the Squamish First Nation. This relationship resulted into the agreement in which ACILP commits to effectively transfer all assets of the project to the Squamish First Nation after 40 years of operation. During construction, employment opportunities were provided to First Nations members and ACILP will continue to attempt to provide employment opportunities during the operation of the project.
2.2.5 Community Relations

ACILP has setup a trust fund to be administered by the local community at its discretion. The objective of the fund is to provide support to projects that benefit the community as a whole. Possible projects in discussion are improved high speed internet infrastructure, improvements to public access roads, development of a community center and others. The project was of significant interest to the local kayaking community during its development phase. Consequently, Transport Canada, NWPD requires that minimum flow releases for kayaking purposes are provided on certain dates and times, specifically on weekends in May, August and September. ACILP will develop a system to ensure effective communication with interested kayakers. During operation it is expected that members of the public will continue to use the public forest service road and from there have view of the powerhouse area and the intake area. Both sites will be fenced and warning signs will be posted for both electrical hazard and for navigational hazards. Operators will be trained to for typical public interaction scenarios, including request for tours and information, and for trespass issues.
2.3
Public Safety
2.3.1 General site safety

During normal operation it is expected that members of the public will pass the project on the public Forest Service Road. (FSR). At various points the powerhouse, tunnel portal area and weir/intake area will be visible. The spur roads constructed by ACILP to the powerhouse/switchyard and intake area will be gated to prevent vehicle access to the sites. Further, security fencing and safety railings have been installed to avoid public safety incidents. Warning signs have been posted at various locations to advise the public of safety hazard such as flows and subsurface currents at the intake and electrical hazard inside the switchyard.
2.3.2 Kayak specific safety

Ashlu Creek is considered a navigable water course by Transport Canada, NWPD The approval calls for the installation of an acoustic kayak warning system at the intake area, "mile 25 bridge", "mile 23 pull out", and at the powerhouse. The system warns kayakers with a sound pattern in case the required kayak ramping rates can be not maintained. This could be the case if the energy dissipation system fails during a load rejection scenario. ACILP has installed and tested the system prior to commencing commissioning. The design of the system was submitted to NWPD for review prior to its installation.
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A life line is installed upstream of the intake area across the creek with signs on both creek sides advising kayakers of the downstream hazard by the intake facilities and a sign warning of Suction Hazard has been installed immediately adjacent to the intake window. A designated portage route has been constructed and marked with appropriate signage allowing kayakers to safely bypass the intake area via portage. The coarse trash rack at the intake is sized to prevent kayakers or swimmers being entrained on the trashrack in the instance the upstream safety and warning measurements are not effective or ignored. Sings warning of flow changes at the tail race have been installed clearly visible from the upstream and downstream approaches of the Ashlu Creek to the powerhouse location and also near the FSR to inform kayakers that use the FSR to access the creek upstream of the powerhouse.
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Section 3.0 - Operating Procedures

3.1 Daily Operating Procedures
Ashlu Creek GS will be attended by operations staff on a daily basis. Staff will conduct routine inspections, perform a preventative maintenance program, minor repairs, as well as the usual housekeeping and caretaker duties. Focus of the inspections will be the intake area with regards to debris accumulation at the trash racks and the sluiceway and cleaning will be performed on an as needed basis. Attention will also be given to confirm IFR flows by visually comparing the IFR probe reading with the benchmark in the creek at the IFR gauging station. The operation of the fishladder will also be inspected on a regular basis. Minor road maintenance such as clearing blocked ditches and culverts will also be completed on a regular schedule as well as responding to major rain events. Around the powerhouse, switchyard and intake area any brush accumulation will be cleared. Procedures within the powerhouse will include cleaning and monitoring of equipment, verification of remote readings and recording of daily logs. At all times operating personnel shall ensure the project is operating in an environmentally responsible manner in accordance with the underlying permits, applicable acts and regulations. The project will be monitored remotely through its Supervisory Control and Data Acquisition ("SCADA") system as well as through a system of video cameras installed at strategic locations around the intake area and the powerhouse (both inside and outside). An automatic dialer system will place a series of phone and pager calls to operations staff and management in case alarms or trip conditions occur.
3.2
Headpond filling and draining
Filling and draining of the head pond is under normal circumstances not performed while water is diverted through the water conveyance system and consequently discharged at the powerhouse tail race. Consequently, the change of flows to the creek extends to the areas downstream of the tail race and therefore past the diversion reach; DFO has advised that changes to the creek flow at the intake, while no discharge from the tail race occurs, have to be limited to 10% of the creek flow. Headpond filling and draining requires meeting water level ramping rates of no more then 25mm/hr downstream of the intake area and downstream of the powerhouse. Control of the flows for head pond filling is achieved by first raising spillway gates S2/5, then S1, then gradually lowering the sluiceway gate. This order is reversed for head pond draining. A detailed head pond and water conveyance system filling and draining procedure has been prepared for DFO in August 2009.
3.3
Tunnel and Penstock Flushing and Filling
To allow controlled flow of relatively low rates of water from the intake into the water conveyance system, a small 300 mm butterfly valve has been integrated into the intake gate. This filling valve has a capacity of approximately 2.0 m/s and is operated through a removable hydraulic hand pump. During flushing and filling, the hand pump is connected to the filling valves hydraulic hoses and operated at the intake.
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3.3.1 Initial flushing of water conveyance system

Prior to filling and pressurizing the water conveyance system, the system needs to be flushed. Flushing water is introduced through the intake gate filler valve at a rate of no more then 0.2 m/s over a duration of no longer then 3 hours, therefore resulting in a total volume of flushing water of no more then 2,160 m or approximately 70% of the powerhouse tail race water. The flushing water must be contained within the tail race and its quality tested. Subject to the test results, a plan for discharge, treatment, disposal, and additional flushing of the water (or a combination thereof) to the satisfaction of the EM and DFO must be developed and executed. The flushing procedure requires to close all TIVs and open at least two EDS ball valves to allow the water flow into the tail race. The intake gate remains closed and locked out. Flushing during the operational phase of the project is required after lengthy periods of the system being dewatered for extensive repair work comprising of welding or shotcreting at penstock and tunnel. The chemistry of the tunnel rock can lead to the development of Acid Drain Rock (ADR) when exposed to air and exposure of metals such as suspended and non suspended Arsenic. Care will be taken to detect ADR and metals and deal with its effect appropriately in accordance with the Water Quality Management Plan (Appendix F).
3.3.2 Filling/pressurizing of water conveyance system

To mitigate high pressure gradients and air entrapment during filling of the tunnel and penstock, it is critical that the system is filled at controlled flow rates. High pressure gradients can also cause problems during the dewatering of the system. The following maximum rates for filling and draining have to be respected: Header pipes, penstock, tunnel liner, and horizontal tunnel: 2.0 m/s Vertical shaft: 10 m (head) / hr. The allowable pressure change rate of the shaft is achieved by a flow rate of 0.03 m/s or 1.5% of the filler valve capacity. It is critical during the filling that the flow rate reduction between horizontal tunnel and vertical shaft is adjusted ahead of time to avoid any sudden changes in the flow and consequent pressurization rates. The first rate of 2.0 m/s can be maintained for 8 hours and the second rate for 12.5 hours, resulting into a total filling time of at least 20.5 hours. Filling rates may not exceed the flow rates available due to the natural flow in the creek at the intake, in general 10% of creek flow (refer to Section 3.2), therefore ruling the filling rate of the first portion of the system if creek flows are below 20 m/s. A stand alone procedure for headpond filling and draining and water conveyance system filling and draining has been prepared for DFO in August 2009.
3.4
Intake Water Level Management
The head pond water level is measured at several locations be means of submersible pressure transducers. The readings are communicated to the local PLC in the intake control building ("the intake PLC"). The intake PLC is connected to the powerhouse main control PLC ("the powerhouse PLC") via the fiber optic cable that is installed in the road. The intake PLC provides water level readings and status of equipment such as
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the position of the gates, condition of the hydraulic power unit, condition of the compressors and other data to the powerhouse PLC. The intake PLC's logic is programmed to allow a range of head pond water levels. The normal operating level is set at 276.0 m and the normal operating window is +/-0.3 m. While the water level is within this window, the intake PLC's function is limited to provide information to the powerhouse PLC which is programmed to change the turbines water use in order to maintain the head pond level within this window. This means that the powerhouse PLC increases the turbine flow if the water level increases and decreases the turbine flow if the water level decreases. The PLC will shut down the plant and stop drawing water through the tunnel and penstock if the water level continues to drop while the plant is operating at its minimum required flow (approximately 3.0 m/s). If the water level continues to increase while the plant flow is at full capacity (29 m/s), then the intake PLC increases the water flow that bypasses the intake by first gradually opening the sluiceway and then, if levels continue to rise due to an extreme flow event, by lowering the spillway gates.
3.5
Start-Up Procedures
Ashlu Creek is a "run-of-river" hydroelectric project and has very limited capacity to store of impounded water. The plant's production is governed by quantity of the creek flow apportioned to the facility by the plant flow controller after releasing the required IFR flow. The facility is fully automated and will continuously operate in flow level control mode as described under Section 3.4. The plant will start up when the following conditions are met: All technical permissive are given which basically means that all components are ready to operate and not alarms or trips are present; The powerhouse PLC determines that the required minimum creek flow for operation at the intake is present (the minimum flow is the sum of the minimum IFR flow and the minimum plant flow: 2.42 m/s + 3.0 m/s = 5.42 m/s).
If both conditions are fulfilled, the PLC will start the first turbine at its minimum flow. The PLC continues to monitor the head pond water levels and will change the plant flow as described under Section 3.4 with the second unit being started when the total instream flow exceeds 12.1 m3/s and the third unit being started when the flow exceeds 21.8 m3/s.
3.6
Shut-Down Procedures
Three types of plant shutdown may be experienced. The most common type of shutdown, a normal shutdown, allows for a reasonably long period of gradual turbine wicket gate closure with creek flows within the diversion reach increasing in accordance with the ramping rate established during commissioning. Secondly a forced outage resulting from a load rejection or plant fault will result in the Energy Dissipation System ("the EDS"), and the third shutdown is the instance there is a system failure requiring the immediate diversion of the flows at the intake by lowering the intake gate.
3.6.1 Normal Shutdown

If the flow in the creek decreases to a point where there is insufficient flow to continue operating a single turbine at its minimum operating point after the IFR is released, the plant controller will automatically initiate a "normal" turbine shutdown and cease diverting
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any flow to the facility. The minimum flow required to prevent potentially damaging cavitation conditions to the turbines is approximately 30% of nominal turbine flow or 2.8 m/s. During the shut down the wicket gates of the operating turbine close within approximately 10 seconds. At the same time, one valve of the EDS opens to a position allowing dissipation of 2.8 m/s. The valve gradually closes within the ramping rates established during commissioning (expected: 29m/s over 90min => 2.8 m/s over 8 minutes). Normal shut downs will also be initiated for planned outages for scheduled or unscheduled inspections, maintenance or repair work of the generating equipment. During those shut downs, the turbines ramp down at the ramping rates established during commissioning until all turbine flow is stopped. The minimum turbine flow will be ramped through the EDS as described in above paragraph.
3.6.2 Forced Outage

Rapid shut down of the generating equipment will occur when a major fault or trip condition is detected by the control system in the plants infrastructure (sudden loss of head pond water level, tunnel, penstock), turbine, generator, protection and control system ("electrical"), switchyard, transmission line or in the BC Hydro transmission system. The Ashlu Creek facility will be well maintained in order to minimize shutdowns caused by equipment within the facility or the transmission line between the facility and the BC Hydro system through a proactive preventative maintenance program with the majority of maintenance on the units occurring when there are sufficient flows for only one or two units. In the event of a trip, the units must be taken off line very rapidly and the protection relays within the plant control system are designed to do this instantly. During the shut down sequence, the plant controller closes the turbine wicket gates and TIVs simultaneously. At the same time, the valves of the EDS will open and divert an equivalent amount of water from the penstock. There will be no noticeable net change of the total flow of turbine and EDS flows and therefore no change to the flow regime at the intake and the powerhouse. The EDS will ramp down flows gradually at the rate established during the commission of the plant. In the unlikely event that the EDS fails to operate as planned and a rapid change in flows downstream of the intake area can occur, the audible kayak warning system will be activated for a duration of 60 minutes. Qualified personnel will be dispatched to survey the area downstream of the powerhouse tail race for stranded fish and will recover and release any fish found. Reporting will be performed in accordance with applicable laws, regulations, permits, and as outlined in the OEMP. During forced outages where the transmission line is disconnected from the powerhouse, the emergency generator within the powerhouse building will automatically start and provide power for station service, including power to the intake through the buried power cable in the forest service road. A DC system provides backup power to the plant controller and shaft lubrication system in order to allow damage free shut down of units.
3.6.3 Emergency Shutdown

In the event that a system failure requires the immediate diversion of the flows at the intake, the intake gate will be lowered and the water supply to the water conveyance system effectively stopped. At the same time the spillway gates would be lowered and
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the sluiceway gate raised to prevent overtopping of the intake structures. Subject to the condition and position of the TIVs and EDS valves, the water would discharge through the tail race into the creek and the conveyance system would be drained. If the EDS is fully open, it is expected that this process would take between 30 and 60 minutes. The audible kayak warning system will be activated for a duration of 60 minutes and qualified personnel will be dispatched to survey the area downstream of the powerhouse tail race for stranded fish and will recover and release any fish found. Reporting will be performed in accordance with applicable laws, regulations, permits, and as outlined in the OEMP.
3.6.4 Long Term Outage

Periodic inspection of the shaft, tunnel and penstock will occur during the project life. These outages will generally be scheduled during low flow periods. This will require draining the shaft, tunnel and penstock. It is also expected that the plant will shut down for brief periods during the winter when flows fall below a level where sufficient flow is available for generation. Typically, this situation occurs between December and February. The ambient temperatures for shaft and tunnel are above freezing point and the penstock is backfilled in order to prevent freezing. Therefore, the water conveyance system will not be drained and it is not necessary to maintain a minimum flow in order to prevent freezing.
3.7
Monitoring and Control Procedures
3.7.1 General
The project can be monitored and controlled from the powerhouse control room and various remote work stations of the operations management team provided by Innergex Renewable Energy Inc. (the operations team). The control system is capable of controlling, in a stable manner, turbine speed at all power outputs between minimum and maximum power, during start-up, shut down (including load rejection), and changes in power output. Monitoring of auxiliary systems such as the hydraulic pressure unit ("HPU"), cooling water system ("CWS"), and bearing oil lube and lift systems has been incorporated into the facility control system. Each generator may be manually started and stopped by the operator, but are normally controlled automatically by control system with alarms, trips and shutdowns automatically initiated if they operate outside set normal conditions. Any input parameter for operation of the facility such as operating parameters, alarms and trip set points, time constants, and time intervals are adjustable using the Human Machine Interface ("HMI"). These operating inputs will be determined during commissioning an optimized during operation of the facility as equipment wears and operating parameters change. Safeguards have been incorporated into the design of the HMI to prevent accidental changes to parameters that may result in "dangerous" operation for the facility. Changes to Operating Parameters will be logged in a historical information database ("Historian"). The facility is equipped with an independent control system. The control system interfaces with the digital turbine governor on each unit to provide unit control and feedback. The governor uses wicket gates position to control unit speed during start-up and generator output when online. The automatic voltage regulator is responsible for
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maintaining the desired power factor and generator voltage using closed loop controlled exciters. The control system will monitor HPUs, CWSs, generator status, switchyard status, EDS status, and other auxiliary devices. In relation to the selected operating modes (isolated from or synchronized to the grid), the digital governor system will respond by adjusting various control parameters to maintain the unit set points For example, when synchronized with the grid, the governor will adjust the unit output in accordance with the available water at the intake while maintaining the required IFR. In synchronized mode the speed set point is based on the grid not the governor. The governor controls the speed during synchronization, and then the unit flow is adjusted to as described in above paragraph by the wicket gates.
3.7.2 Protection Relays

The plant control system is based on several programmable logic controller ("PLC") which will monitor the status of designated inputs, direct the status of designated output functions and sequentially star-up or shutdown the units as needed. Those PLC systems are modular, card rack type designs. The PLC for generation control (turbines, generators, switchyard, and their respective auxiliary systems) is mounted in the control panel inside the control room. The PLC for the dissipation system is mounted in a local control panel inside the energy dissipation valve room. The PLC controlling the intake (intake gate, sluicegate, spillway gate, and their respective auxiliary systems) is mounted inside a local control panel inside the intake control building. The intake PLC and dissipation PLC communicate with the control room PLC on an ongoing basis. However, all three PLCs operate their respective equipment independently from each other. This ensures that failure of one PLC or loss of communication (i.e. between intake and powerhouse) will not lead to unsafe conditions or disruption of normal operation. The Protective Relay System ("PRS") provides alarms and takes preventive or corrective action in case of local or remote electrical or mechanical fault likely to affect the safe and continuous operation for the Plant. The PRS provides the required and appropriate protective functions, meeting the BC Hydro Interconnection requirements for Power Generators. Operation of the PRS is independent of the PLCs, and failures of the PLCs will not prevent proper operation of the PRS. The output trip contacts of the protective relays are directly inserted in both the breaker trip circuit and to the PLC inputs. Non critical alarms coming from the PRS are routed to the PLC; critical alarms are hardwired to the PLCs input. All protective relays are supplied power from the uninterruptible power supply (UPS") so that relay control is not lost during trip conditions, including those where station service is temporarily or permanently interrupted.
3.7.3 Human Machine Interface (HMI)

The HMI is a PC-based system to enable control, monitoring, and log plant operations. Analog, digital, and accumulated system parameters shall be collected, displayed, stored, logged, and processed as appropriate. Data shall be trended and stored at a reasonable rate depending of parameter rate of change (i.e. fast for fast changing values and slow for slow changing values). The HMI provides the operator with adequate realtime plant system status in all conditions. It is designed to provide an efficient and user
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friendly means for controlling all equipment and their controls. Gross system status shall be continuously updated in real-time. Any critical pages that may alter the proper operation of the system are provided with access password protection.
3.7.4 Historian
The Historian system will monitor the key control elements in the system and will provide a user interface to chart, trend, and examine data. This is a PC based system that enables monitoring, logging, and recording of plant operations. Secure and reliable data acquisition will be the primary focus of the system. The data will be logged from the plant control system through the PC located in the control room that also acts as the interface of the HMI.
3.7.5 Web Based Digital Video System

A web based video system provides real time camera views and camera control at the intake (three cameras), inside the powerhouse (three cameras), outside the powerhouse and switchyard (two cameras). A digital video recorder starts recording video data upon detection of motion in the pictures. The DVR can be accessed for review of the files and live video feed and camera control through the control room PLC and remotely by the operations team.
3.8
Maintenance and Inspection Program
Recommended routine and preventative maintenance procedures specified by the equipment manufacturers will largely govern the Maintenance and Inspection Program. All routine maintenance requirements and inspection frequencies will be clearly outlined in the O&M Manual for the facility. When integrating the requirements of individual equipment manufacturers into the Maintenance and Inspection Program, the objective will be to minimize downtime and maintain consistent operations. Each maintenance activity will include a detailed work plan that will be reviewed, amended as necessary, and approved prior to understanding the work. Through continuous monitoring and inspections of the facilities, maintaining consistent maintenance documentation, and based on experience, the routine maintenance schedule will be adapted and modified. The Ashlu Creek GS has three generating units and an energy dissipation system consisting of six valves. Consequently, much of the equipment inspection and maintenance will be scheduled during periods of low flow between September and April when only one or two units are in operation.
3.8.1 Intake, sluiceway, rockfill weir, and spillway

The intake area will be inspected on a regular basis. Focus will be the condition of the coarse and fine intake trash rack and cleaning will be performed on an as needed basis. Floating debris accumulated upstream of the sluicegate will be flushed through the sluiceway top flap gate. The flap gate can be controlled through a local control panel or through the HMI inside the powerhouse control room. The sluicegate will be partially opened on an as needed basis to flush sediment that accumulates upstream of the intake and sluiceway inlet areas.
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The inflatable spillway gates will in general not be lowered for the sole purpose of flushing accumulated debris. It is expected that only minor amounts of debris will accumulate during normal operation at the spillway channel and the accumulated debris will be flushed through the spillway channel when the gates are lowered during high flow conditions. Should larger amounts of debris accumulate in this area, the gates may be lowered for the sole purpose of flushing the debris. It is expected that debris and sediment accumulated in the head pond over time will flush downstream through the spillway during high flow conditions. Oil samples from the intake and sluiceway gates hydraulic power unit will be taken on a regular basis and tested for contamination and decomposition. The intake control building and the equipment inside will also be subject to regular inspections and a maintenance program in accordance with the suppliers' recommendations. The civil structures will be subject to inspections with focus on the downstream toe area of the rockfill weir where washing out of fines would indicate an undermining of the weir through subsurface flows.
3.8.2 Fishladder
The fishladder will be inspected on a regular basis and cleaned from debris and sediment on an as needed basis. The intake valve and adjustable buffer plates at the upstream entry of each channel section (4 sections in total) will be checked for position and subsequent control of flows and adjusted as required. If fish are present during inspections, a record will be kept in the powerhouse control room. The inlet pool will be checked for fish during each inspection. If fish are present but do not "climb" the ladder, a qualified biologist will be brought to site in order to recalibrate the fish ladder flow and promote use of the ladder by fish.
3.8.3 Shaft, Tunnel, and Penstock

Shaft, tunnel, and penstock require little or no service during normal operations. The toe of the intake/shaft transition back fill area will be inspected on a regular basis in order to identify any leakage from this area and its possible effect on the integrity of the backfill and its foundation around the intake structure. If leakage should be observed, a qualified geotechnical professional will be brought to site to assess the situation and a repair program will be developed and executed. The penstock is backfilled and the surface above it will be inspected on a regular basis for signs of leakage or other problems such as erosion on the steep section near the powerhouse. Should areas that require correction be identified, a qualified professional will be brought to site for inspection and a repair program will be developed and executed. It is expected that the tunnel and penstock will be dewatered on average every 5 years to complete a full inspection of the system, empty the rock trap and perform repair work as needed. It is expected that some paint repair work will be required at the penstock and tunnel liner sections over time. Spare paint is kept at the powerhouse.
3.8.4 Powerhouse Civil Works

Routine maintenance of the powerhouse will include all routine maintenance associated with an industrial building located in a rural setting including painting, roof maintenance,
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ditch cleaning, brush clearing, danger tree assessment and their removal, if required. Ancillary equipment such as the back-up diesel generator and overhead crane will be tested, inspected and operated regularly to accordance with manufacturers recommendations to ensure proper operation. The heating and ventilation systems will require routine service.
3.8.5 Tailrace
The tail race will be pumped empty during longer planned outages in order to inspect the mechanical components of the generation and dissipation system. The rock traps at the invert of the dissipation baskets will then be inspected and emptied as needed.
3.8.6 Access Roads

Main access to the side is through the Forest Service Road. ACILP is named a secondary user in the road use agreement with the Ministry of Forests. During times when the primary user is not actively using and maintaining the road, ACILP will perform routine inspections and maintenance work, such as grading, ditch and culvert cleaning and bridge repair work. The roads constructed by ACILP to access the powerhouse and intake site will be subject to permanent inspection and maintenance as described above.
3.8.7 Turbines/Generators
The exterior of the turbines, generators and auxiliary equipment will be visually inspected on a daily basis. The inspections include checking of manual gauges and comparison of their readings with the electronic readings provided through the HMI in order to find any inconsistent readings. Inspections include hydraulic and water lines, listening for unusual noise and vibration. The inspection program will include any recommendations provided by the equipment suppliers. Maintenance program will include regular tests of hydraulic fluids and their change if test results require doing so or when the recommended life time has been reached. Oil storage and handling will be in accordance with applicable permits and regulations. Turbine runners, wicket gates, shaft seals and the tolerances of moving parts will be inspected and measured on an annual basis and wear and tear will be recorded. Refurbishing of runners and other parts will be performed as needed.
3.8.8 Energy Dissipation System

The bolted flange connections will be inspected for water leaks on a daily basis. Torque on the bots will be checked on a regular basis as per the suppliers recommendations. Focus at the EDS is on the 9 hydraulic power units and the piping connecting them. Inspections will include careful examination for oil leaks and any other signs of wear and tear. Oil samples will be taken on a regular basis and tested for contamination. Oil will be changed if test results require doing so or when the recommended life time has been reached.
3.8.9 Back-up System

A diesel generator is installed at the plant to provide station service power during outage periods when electricity is not available form the BC Hydro system or the projects
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transmission line and switchyard are unable to provide power from the BC Hydro system to the plant. The generator is connected to the station service through an Automatic Transfer Switch which precludes synchronous operation for the back-up generator. The diesel generator will be tested and serviced on a regular basis, including but not limited to regular start ups, fluid tests and changes, all of the foregoing in accordance with the manufacturer's recommendations. It is critical to ensure that the backup system will be available so that the facility has a reliable source of power for station service during an outage. In addition to the backup diesel generator, a battery DC battery backup system has been installed to supply emergency power to the facility control systems and the DC lube shaft lift pumps. The latter will provide lubrication to the shaft while the units continue to spin while slowing down after a load rejection event until complete stand still. The DC system is designed as a UPS, providing a seamless power supply to the controls and protection. The DC system will be monitored from the SCADA system. Further, visual inspections of the battery bank and the UPS switch will be performed on a regular basis. Battery performance as well as the physical condition of components such as leads and terminal will be monitored and replaced as needed.
3.8.10
Controls and Protection
The control system is relatively maintenance free. A supply of critical spare parts including fuses, PLC components, relays and other are kept on site. The HMI and SCADA system will continuously monitor and record operating parameters of the facility. Alarm set-points and trip set-points will be established during commissioning. The operators will monitor all operating records and note any trend so that potential problems may be addressed before impacting operations. The operations team will also conduct remotely independent analysis of trends for the same purpose. All relevant components of the control system are designed for safe shutdown of the generating system in the event of system failure. For example, the TIVs are closed through counter weights so that in an event of power failure, the TIVs will close automatically. The closing time is controlled through an office plate within the oil return line; the size of the office will be established during the commissioning of the system. The protection system is designed with reliability and redundancy including multiple power supplies and overlapping protection zones within the system. Protective relays will be tested periodically in accordance with NERC and WECC reliability standards, usually every five years. Spares of each type of relay are maintained so that in the event of relay failure, a spare of precisely the same model is readily available.
3.8.11
Switchyard
Critical power measurement parameters for generation (i.e. voltage and power on all phases, system frequency, and power factor) and control (i.e. transformer oil temperature and gas pressure) will be monitored continuously by the SCADA system and are available in real time to the operator through the HMI. The manufacturer's recommended routine and preventative maintenance procedures for all equipment will be followed in general and substituted by ACILP own procedures. Transformer oil samples are collected and analyzed on a regular basis. Routine maintenance of the switchyards infrastructure includes brush clearing and that the
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crushed stone base remains clear of weeds, and maintenance of the secure perimeter fence as required.
3.9
Trouble Shooting and Repair
The objective of any troubleshooting and repair action is to minimize any environmental impacts the event could have and at the same time to minimize equipment down time; both effects are often concurrent and their minimization is a common goal. In order to shorten response times for repairs, the following measurements are in place: Operating personnel on site and operation management personnel have a high level of familiarity with the plant, the equipment, and its operation principles. The high level is ensured by hiring operating personnel during the construction and commissioning phase, therefore allowing them to gain hands on experience prior to start of commercial operation. Personnel will be trained and audited for their expertise on an ongoing basis; An extended inventory of long lead spare parts is kept on site. Contacts are in place with potential trouble shooting and repair services, both locally and with the equipment suppliers and installers. The equipment design team has remote access to the SCADA system in order to provide support if ACILPs own resources is unable to resolve the issue within a reasonable time; Redundancy is provided through three identical generating units and six identical dissipation valves. Parts between the identical units are interchangeable, therefore reducing the amount of required spare parts and also allowing to temporary use parts of one unit to repair another; Operation and maintenance manuals, equipment descriptions and relevant control and logic drawings are kept on site as well as at the control center; Troubleshooting flow charts and diagrams for the most common issues will be developed and refined over time, therefore ensuring that any experience gained during commissioning and the initial operations phase is available if the issues arise again.
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Section 4.0 - Operating Staff

4.1 Staffing Levels
The Ashlu Creek GS will be manned during normal business hours on a daily basis within its initial phase of operation. If the reliability of the system warrants, then attendance on weekends and statutory holidays may be optional. In order to maintain the attendance level, one Operations Superintendent has been hired during the last phase of construction and one backup operator will be hired during the commissioning phase of the project. Both will be equipped with pagers as will all members of the local operations team. The automated calls out system will dial up pagers and cell phones in a predetermined order and will continue to repeat the order until one recipient has acknowledged the call. Other personnel and contractors will be hired on an as needed basis to perform work such as brushing underneath the transmission line.
4.2
Training
Operating personnel have been hired prior to commissioning the generating station and are trained on the job in the final stages of construction and throughout commissioning. Further, ACILP own core personnel train staff on an ongoing basis and the company wide experience gained during the operation of other facilities owned or operated by ACILP parent company, Innergex Renewable Energy Inc. is available to the project. In addition to technical training, all operating personnel receive training for safe work procedures and environmental awareness. The long term success of the project is tied to its environmental performance. The operators will receive a detailed orientation and regular updates on environmental commitments and requirements. Operators will be trained in route inspection and environmental management activities, as identified in the Operation Environmental Management Plan.
4.4
Safety
Safety includes safety of the worker and public safety. Each of the operators will have thorough understanding of the equipment and it safe and reliable operation. Hazards and their potential will be clearly identified on the equipment with industry standard decals and descriptions. Warning sings in accordance with the permits and best industry practice have been installed as described in previous sections. All operation personnel will be fully educated on workplace safety and OHSA regulations governing work within a hydroelectric generating station. Safety procedures incorporating good utilized practice and including Workers Compensation Board and Minister of Labor regulations will be strictly maintained. All industry standard mechanical and electrical lock-out procedures will be employed on all electrical and mechanical systems, including the intake, sluiceway, and spillway gates. The operators will be trained on using fire fighting equipment which is located at strategic locations within the powerhouse and the switchyard.
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Section 5.0 - Monitoring and Reporting

5.1 Operations Flow Monitoring
Flow monitoring at the intake and powerhouse through stream gauges, monitoring of head pond levels and deviation of turbine flow from the commissioning index testing is in place. The information is used to ensure that IFR requirements are met and to optimize power production. Any reporting required and the Fisheries Act Authorization and the Water license will be carried out as required by the respective Approval Agency, as identified in the approvals.
5.2
Telecommunications
Communication to the plant is provided primary through five land phone lines extended by ACILP through a fiber-optic line near the point of interconnection with BCTC ("the POI"). Redundancy is provided through a satellite internet service installed directly at the powerhouse with a steady IP address. Communication between Ashlu Creek GS and BC Hydro's Cheakamus GS is provided through a branch of the fiber optic cable near the POI. Communication between the intake and powerhouse is provided by a fiber-optic cable installed in the forest service road between the two locations. Backup is provided through a radio system with a repeater station integrated into the kayak warning system as the "mile 25 bridge" location.
5.3
Operations Reports
On site operations staff will produce daily reports and keep continuous logs of routinely checked data. Incident reports will be made of one time or unusual events, such as but not limited outages or equipment failure. Reports will be analyzed in order to detect any abnormalities at an early stage or to post analyze events of significance. The Operation Environmental Management Plan also contains incident reporting protocols and forms consistent with regulatory requirements. Any incidents related to regulatory approval will be forwarded to the approving agencies. Monthly Operation Reports will be prepared and include the following information as a minimum: Energy production, including peak and off-peak values, and comparisons to historical production and predicted production; Unit efficiencies with comparisons to average values; Flow data, broken down into total flow at intake, flow released for IFR, flow spilled in excess of IFR and flow diverted to the plant for generation; Incident summary report
Comprehensive quarterly and annual reports will be prepared and include the information of the monthly reports and comparison of the respective historic and expected data. Those reports will also provide details with regards to past and planned maintenance and repair plans as well as energy forecasting.
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5.4
Environmental Reporting Requirements
All the environmental requirements from various project approvals and commitments will be incorporated in the Operations and Maintenance Plans and into the OEMP. The primary operating requirements are minimum in-stream flow release requirements and stream flow ramping rates. In response to these requirements, the facilities have been designed to operate only in flow control mode, meaning that, at all times, the generation equipment reacts to the amount of flow available after ensuring the required IFR and ramping rates. Both the IFR and ramping rate constructs have been programmed into the facility control system. The creek flow and rate of change of creek flow will be continuously monitored and recorded by the control system and verified by the operator through visual inspections of benchmarks in the creek. Long term monitoring of the project impacts will be conducted in accordance with the Five Year, Post Construction Aquatic Monitoring Program. Annual reports and a final report at the end of the program will be submitted to the relevant agencies and used to determine whether any adjustments to the operating procedures are required.
5.5
Ministry Reporting Requirements
ACILP will provide to MoE annual energy production, water use, and recorded IFR flows as required under the Water Licence. Further the annual reports under the Five Year, Post Construction Aquatic Monitoring Program will also be provided. In the event of an IFR non-compliance or ramping non-compliance, MoE and DFO will be notified and provided all relevant data to assess the impact. Water Stewardship division will also be copied on all other provincial reporting requirements including Dam Safety and spill response.
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Section 6.0 - Key Personnel

Project Owner
Michel Letellier, MBA President and CEO Ashlu Creek Investments LP Suite 303 - 38 Fell Avenue, North Vancouver, BC TEL: (604) 984-8600 FAX: (604) 984-8699 EMAIL: mletellier@innergex.com Richard Blanchet, P.Eng. Vice President Ashlu Creek Investments LP Suite 303, 38 Fell Avenue North Vancouver, BC V7P 3S2 Tel: (604)984-8600 Fax: (604)984-8699 Email: rblanchet@innergex.com
Project Operators
Francois Hebert Vice President, Operations & Maintenance Innergex Renewable Energy Inc. 1111 Saint-Charles Street W. East Tower, Suite 1255 Longueuil, PQ J4K 5G4 Tel: (450)928-2550 Cell: (514)249-2677 Pager: 1-888-235-6901 Email: fhebert@innergex.com Brian Patjas Operations Superintendent Ashlu Creek Investments LP Suite 303, 38 Fell Avenue North Vancouver, BC V7P 3S2 Plant: (604) 898-8287 Cell: (604) 932-8677 Pager: (604) 686-3445 Email: bpatjas@innergex.com
Provincial Agencies
Timothy Bennett, P.Eng. Assistant Regional Water Manager Ministry of Environment 10470 152nd Street Surrey, BC V3R 0Y3 Tel: (604)582-5227 Fax: (604-582-5235 Email: Timothy.Bennett@gov.bc.ca Kevin Walker Land Officer Integrated Land & Management Bureau 200 10428 153rd Street Surrey, BC V3R 1E1 Tel: (604)586-4409 Fax: (604)586-4434 Email: Kevin.Walker@gov.bc.ca Steve Rochetta Ecosystems Specialist (Squamish) Ministry of Environment Squamish, BC Tel: 604 898-3678 Fax: 604 898-4171 Email: Steve.Rochetta@gov.bc.ca
Kevin Haberl, R.P.F. Operations Manager Squamish Forest District, Ministry of Forests Suite 101, 42000 Loggers Lane, Squamish, BC V8B-0H3 Phone: 604-898-2145 Email: Kevin.Haberl@gov.bc.ca 25
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Federal Agencies
Vince Busto, P.Eng. Habitat Engineer Fisheries and Oceans Canada 100 Annacis Parkway, Unit 3 Delta, BC V3M 6A2 Tel: (604)666-8281 Fax: (604)657-0723 Email: Vince.Busto@dfo-mpo.gc.ca Francesca Knight, RP.Bio. Habitat Biologist Fisheries and Oceans Canada Squamish, BC Tel: (604) 892-2040 Fax: Email: Francesca.Knight@dfo-mpo.gc.ca Shannon Vollema Navigable Waters Protection Division Transport Canada Pacific Region 820 800 Burrard Street Vancouver, BC V6Z 2J8 Tel: (604)775-8896 Fax: (604)775-8828 Email: Shannon.Vollema@tc.gc.ca
First Nations
Dale Harry, Councilor Squamish First Nation 320 Seymour Blvd North Vancouver, BC, V7J 2J3 Tel: (604)980-4553 Fax: (604)980-4523 Email: n.a.
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APPENDIX A General Arrangement Drawings
Ashlu Creek Parameters and Procedures Revision A October 2009
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APPENDIX B Conditional Water License
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APPENDIX C DFO Authorization
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APPENDIX D Transport Canada / Navigable Waters Protection Division Approval
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APPENDIX E Long term (5 year) Aquatic Monitoring Program
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APPENDIX F Water Quality Management Plan (DRAFT)
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Russell, Veronica A ENV:EX

From: Sent: To: Cc: Subject: Attachments: Bennett, Timothy A ENV:EX Friday, December 18, 2009 3:12 PM 'Robert Kulka' Babakaiff, Scott C ENV:EX; XT:Busto, Vince DFO EAO:IN; 'gsteeves@ameresco.com'; 'Richard Blanchet'; 'Kelly Boychuk' RE: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management Plan Ashlu OEMP - Rev B.PDF; image001.jpg
HiRobert, ThankyouforprovidingyourdraftOEMPforourreview. Staffhaverevieweditandprovidedthefollowingpreliminarycomments: 1. ReportAuthorshipunknown:Thereportshouldbepreparedandsignedbyappropriatelyqualifiedlicensed professional(s)(e.g.,RPBio). 2. Fewcommitmentstofollowcommonlyacceptedguidelinesfordatacollection&analysis,despitea proposalthatmonitoringdetailsmeettherequirementsofDFOandMOE(p.6oftheOEMP).Many detailsproposedintheOEMPareseeminglyarbitraryanddonotreferenceanyguidelinesorstandards typicallyreferencedbyProvincialorFederalagencies.Forinstance: 1. StagedischargeratingcurvestheOEMPcommitstocollectingaminimumofthreedischarge measurementsandwarnsthat...itisunlikelythatflowswillbeabletobemeasuredabove20%of meanannualdischarge.Thereareclearandwellestablishedguidelinesfordevelopingstage dischargeratingcurves(e.g.LWBCHydrometricGuidelines;B.C.ProvincialHydrometricStandards (see http://www.env.gov.bc.ca/fia/documents/Manual%20of%20British%20Columbia%20Hydrometric% 20Standards%20V1.0,%20March%2012,%202009.pdf)thattheproponentisrecommendedtomeet. 2. Reportingofstreamflowdata:theOEMPcommitstocollecttocollectflowdataonacontinuous basis,typicallyin15minuteintervalsandpromisesthatdatawillberecorded...andcanbe providedtoonsiteDFOand/orMOEstaff...forcompliancepurposes...flowdatawillbereported quarterly.Isuggestthereisnoneedtosubmitdatatoreviewagenciesmorefrequentlythanonce peryear,butagenciesmustbeinformedwithin24hoursofanynoncompliance(e.g.IFRprovision, rampingrates),andtheproponentmustresolvetheissueofnoncomplianceimmediately.Interms ofdatacollection&logging,InotethattheBCProvincialHydrometricStandards(Section3.2.2.3) recommendsastagereadingevery15minutes,butadvisesthat"thisisaminimum requirement...sitespecificflowregimesmaynecessitateashorterfrequency...".Forpurposesof verifyingcompliancewithflowrampingrequirementsinfishbearingwaters,particularlythosewith thediversityoffishvaluesintheAshludiversionreach,Iwouldrecommendamuchshorterstage samplingfrequency(say,10second),witha2minuteaverageforstorageinthedatalogger(and submissiontoagencies).Iwouldalsorecommendthatdatabedownloadedfromtheloggerona frequencynolessthanoncepermonth,toensurethatanyequipmentmalfunctions(e.g.battery loss,equipmentdamage)donotresultinlengthydatagaps.Forpurposesofgraphicalpresentation inmonitoringreports,itmaybehelpfultoapplyanhourlyaveragetothe2minutestagedata. 3. Developmentoframpingrates:Section12.2oftheOEMPproposesthattherampingratesshall notexceed29.0cmsper90minutes.Thisratewillbeestablishedduringthecommissioningprocess oftheplant,andmaybesubjecttodifferentflowconditionsinthecreek.Thisratewasbasedon thenaturalrampingratesthathavebeenhistoricallyobservedinAshluCreekoverseveralyears since1991....TheOEMPprovidessomedetailregardingproposedmethodsforestablishing rampingratesduringcommissioning,butIwouldsuggestthatsuchprotocol(andsuchinterimrates like29cmsper90minutes)shouldbeestablishedandscientificallyjustifiedbyanexperienced professional,withreferencetoestablishedagencycriteria(e.g.DFOsdefaulthourlyrampingrates of2.5cm&5.0cmforfry&juveniles)orrecommendedguidelines.Finally,Isuggestthatthe commitmentwithinSection14oftheOEMPtosubmittherampingratereportsixmonthsafter
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commissioningrepresentsaninappropriaterisktofish&fishhabitatgiventherapidinterim rampingrateproposedandthefishvaluespresentinthediversionreach. 4. FishAbundance(Section7)&InvertebrateDensity(Section8):nomethodologicalguidelinesfor datacollectionoranalysisareproposed,despitethebibliographicreferenceinSection16ofthe OEMPtoHatfield&Lewis(2007).TheMOEESDinformationchecklistprovidedintheProvincialIPP GuidebookalsoprovidessupplementalguidanceforOEMPdevelopment.Itismyunderstanding thatthebaselinebiologicaldatacollectedinrecentyearsdidnotfollowanyparticularprotocol,but wasundertakenbyseveraldifferentbiologistsindifferentlocations,usingdifferentmethods.As such,itisimperativethatallbaselinedatabecollatedandassessedbyaprofessionalbiologistwith experienceintherelevantspecialization(ie.fisheriesbiology,macroinvertebratebiology),and compiledforassessmentregardingitsadequacyasabaselinetoassessfuturechangesthatmaybe attributabletooperationoftheIPPfacility.Onthisnote...
3. Nobaselinedataorpoweranalysis:theadequacyofthemonitoringdetailsproposedintheOEMP(e.g.
durationandfrequencyofsampling,expectednaturalvariability,samplesizes,methodsofanalysis,apriori agreementonecologicallyacceptablethresholdsofdependentvariables,corrective/compensatory measurestobeadopteduponthresholdexceedance,monitoringprogrambudgets,etc.)cannotbe objectivelyconsideredwithoutpreliminaryanalysisofbaselinedata,includingstatisticalpoweranalysis.In theabsenceofsuchanalyses,particularlyforthebiologicaldatadescribedinSections6&7oftheOEMP,I havelittleconfidenceintheadequacyofprediversionbaselinedatadescribedintheOEMPtoassessany diversioninducedchangesinthesebiologicalresponsevariables. 4. DetailsofmonitoringcommitmentstabulatedintheAppendixoftheOEMPdonotseemcongruentwith textinthebodyoftheOEMP.Forinstance,page3oftheOEMPclearlystates:InthecaseoftheAshlu Project,baselinestudieswerecarriedoutfrom2001to2006,aperiodoffive(5)yearsandweredoneprior tothenewProvincialguidelines(HatfieldandLewis,2007);therefore,notallofthecriteriaoutlinedinthe guidelinesforcontrolsiteshavebeenimplementedduringthesepreviousstudies.However,monitoring proposedforsomecomponents(e.g.biologicalcomponentsfromTables35oftheOEMP)havebeencopied verbatimfromtheguidelines(which,incidentally,arenotreferencedcorrectly)andsubsequentcasestudy (TroutCreek),soitisunclearwhataspectsofthemonitoringcriteriawillorwillnotbeundertakenperthe OEMP. 5. Prediversionactivitieswhichmayrequireseveralmonthstocompletehaveyettohavebeeninitiated. Forinstance: 1. installationofthefourpressuretransducers(perSection4.2.1oftheOEMP)anddevelopmentof associatedratingcurvesforwaterflow(Section4)andinstreamflow(Section11)monitoring; 2. Collectionofstreamchannelmorphologydata(perSection10oftheOEMP).Thiscomponentofthe OEMPisparticularlyilldefined:therearenoexplicitguidelinesorstandardsreferenced,andIalso questiontheproposedbenefitsofcompletingrepeatsurveysatafewtransectstoassesswhether theIFRisaffectanyofthefishhabitataswasoriginallypredicted.Assessmentofchangesin channelmorphologyrelatedtoprojectoperations(e.g.flowdiversion,changesinsedimentand LWDtransportratesandvolumes,etc.)iscrucial,butshouldbeconsideredmoreholisticallyusing lowlevelairphotosandlongitudinalsurveyprofiles.Again,itisrecommendedthatanprofessional experiencedwithdevelopmentofchannelmonitoringprograms(ie.afluvialgeomorphologistor riverengineer)betaskedwithdevelopingthestudydesignandundertakingtheworkpriortofinal commissioning; IalsonotethatitappearsthisdraftOEMPwasprovidedtoDFOinMay2009;wereearliercopiessubmittedtoMoE? Ifyouhaveanyquestionsinthisregard,pleasedonothesitatetocontactmeorScottBabakaiff. Regards,
TimothyBennett,M.Sc.,P.Eng. SectionHead,WaterAllocation WaterStewardshipDivision
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MinistryofEnvironment
10470152Street,Surrey,BCV3R0Y3 Ph.(604)5825227Fx.(604)5825235 Timothy.Bennett@gov.bc.ca
From: Robert Kulka [mailto:RKulka@innergex.com] Sent: Friday, November 27, 2009 3:04 PM To: Bennett, Timothy A ENV:EX Cc: Babakaiff, Scott C ENV:EX; XT:Busto, Vince DFO EAO:IN; gsteeves@ameresco.com; Richard Blanchet; Kelly Boychuk Subject: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management Plan Hello Tim, Attached are the following files: Revision B of the Operations Environmental Management Plan for the Ashlu Creek project. Jpeg file of the monitoring map shown as Figure 1 in the OEMP. Cover letter regarding submission of the OEMP. Hard copies are in the mail to you, to Scott Babakaiff, and to Vince Busto. Please contact me if you have any questions. Regards, Robert
________________________________________
ROBERT J. KULKA, P. Eng., Dipl.-Wirt.-Ing.
Construction Manager
Innergex nergie renouvelable - Innergex Renewable Energy
Suite 303 - 38 Fell Avenue North Vancouver, British Columbia V7P 3S2
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
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Ashlu Creek Hydroelectric Power Project Operations Environmental Management Plan
Revision B
November 2009
Ashlu Creek Investments Limited Partnership 303-38 Fell Avenue North Vancouver, BC V7P 3S2
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Ashlu Creek Hydroelectric Power Project Operational Environmental Management Plan
Revision B November 26, 2009
Abstract
In July 2006, the Ministry of Environment (MOE) issued Ashlu Creek Investments Limited Partnership Conditional Water License #102203 on Ashlu Creek near Squamish B.C. Conditions of the water license included a maximum diverted flow of 29.0 m3/s and the completion of an Operational Environmental Monitoring Plan (OEMP) to evaluate the effect of the regulation of works. In July 2006, the Department of Fisheries and Oceans (DFO) issued authorization #04-HPCAPA2-000-000530. Conditions of this authorization include a year round Instream Flow Requirement (IFR) of 2.42 m3/s. A draft (Revision A) of the Five Year, Post-Construction Aquatic Monitoring Program Revision A was submitted to DFO in May 2009. A follow-up letter was sent to DFO in October 2009 with description of the specific plan to confirm ramping rates. As of November 27, 2009, comments have not been received from DFO. In addition, Approval #8200-T-10595.2 issued by Transport Canadas Navigable Waters Protection Division (NWPD) requires the IFR to range between 16 m3/s and 32 m3/s during twelve (12) weekends between May and September. The OEMP outlines the biotic and physical monitoring parameters to be monitored during both pre and post construction of the Ashlu Creek Hydroelectric Project. The purpose of the OEMP is to provide early warning of impending change in key variables and provide an opportunity to mitigate any change through alterations of operating procedures. The goal of the OEMP is to ensure resource values potentially affected by power production are not adversely compromised over the life of the facility.
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Table of Contents Abstract........................................................................................................................... i Table of Contents ...........................................................................................................ii List of Figures ...............................................................................................................iv List of Tables .................................................................................................................iv 1.0 2.0 3.0 3.1 3.2 3.3 3.4 3.5 3.6 3.7 3.8 3.9 Introduction......................................................................................................... 1 Study Area........................................................................................................... 1 Monitoring Components .................................................................................... 2 Headpond ............................................................................................................. 3 Intake/Weir ........................................................................................................... 3 Mile 25 Bridge....................................................................................................... 4 Gravel Bar in Ashlu Canyon ................................................................................. 4 Gustafson (Bend) Creek ....................................................................................... 4 Powerhouse/Tailrace/Switchyard ......................................................................... 4 Double Bridges ..................................................................................................... 4 Fish Compensatory Habitat .................................................................................. 4 Transmission Line ................................................................................................ 6
4.0 Water Flow .......................................................................................................... 6 4.1 Monitoring Locations ............................................................................................ 6 4.2 Monitoring Approach and Analysis ....................................................................... 6 4.2.1 Electronic Pressure Transducers............................................................... 6 4.2.2 Visual Staff Gauges ................................................................................... 7 4.3 Reporting .............................................................................................................. 7 5.0 5.1 5.2 5.3 6.0 6.1 6.2 6.3 7.0 7.1 7.2 7.3 8.0 8.1 8.2 8.3 Water Quality ...................................................................................................... 7 Monitoring Locations ............................................................................................ 8 Monitoring Approach and Analysis ....................................................................... 8 Reporting .............................................................................................................. 8 Water Temperature............................................................................................. 9 Monitoring Locations ............................................................................................ 9 Monitoring Approach and Analysis ....................................................................... 9 Reporting .............................................................................................................. 9 Fish Abundance and Biomass Density (Fish Community)........................ 10 Monitoring Locations .......................................................................................... 10 Monitoring Approach and Analysis ..................................................................... 10 Reporting ............................................................................................................ 11 Invertebrate Abundance and Biomass Density ............................................. 12 Monitoring Locations .......................................................................................... 12 Monitoring Approach and Analysis ..................................................................... 12 Reporting ............................................................................................................ 13
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9.0 Compensatory Fish Habitat Efficacy .............................................................. 13 9.1 Monitoring Locations .......................................................................................... 13 9.2 Monitoring Approach and Analysis ..................................................................... 13 9.2.1 Fish Ladder.............................................................................................. 13 9.2.2 Rearing Fish Compensation .................................................................... 13 9.3 Reporting ............................................................................................................ 14 10.0 Stream Channel Morphology........................................................................... 14 10.1 Monitoring Locations .......................................................................................... 15 10.2 Monitoring Approach and Analysis ..................................................................... 15 10.3 Reporting ............................................................................................................ 15 11.0 Instream Flow Requirement............................................................................. 15 11.1 Monitoring Locations .......................................................................................... 15 11.2 Monitoring Approach and Analysis ..................................................................... 16 11.2.1 Requirements under DFO........................................................................ 16 11.2.2 Requirements under TC / NWPD............................................................. 16 11.3 Reporting ............................................................................................................ 17 12.0 Ramping ............................................................................................................ 17 12.1 Monitoring Locations .......................................................................................... 17 12.2 Monitoring Approach and Analysis ..................................................................... 17 12.3 Reporting ............................................................................................................ 18 13.0 Footprint Impact Verification........................................................................... 19 13.1 Monitoring Locations .......................................................................................... 19 13.2 Monitoring Approach and Analysis ..................................................................... 19 13.3 Reporting ............................................................................................................ 19 14.0 15.0 Reporting........................................................................................................... 19 Exclusions......................................................................................................... 20
16.0 References ........................................................................................................ 20 16.1 General References ........................................................................................... 20 16.2 Project-Specific References ............................................................................... 20
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List of Figures
Figure 1 Post-Construction Aquatic Monitoring Program Monitoring Station Locations ........... 5
List of Tables
Table 1 Table 2 Table 3 Table 4 Table 5 Table 6 Table 7 Table 8 Table 9 Table 10 Water Flow ............................................................................................................... 23 Water Quality............................................................................................................ 23 Water Temperature .................................................................................................. 24 Fish Abundance and Biomass Density..................................................................... 24 Invertebrate Abundance and Biomass Density ........................................................ 25 Compensation Fish Habitat Efficacy......................................................................... 25 Stream Channel Morphology.................................................................................... 26 Instream Flow Requirement ..................................................................................... 26 Flow Ramping .......................................................................................................... 27 Footprint Impact Verification..................................................................................... 27
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1.0
Introduction
The post-construction and operational impacts of the Ashlu Creek Hydroelectric Power Project (the Project) on the aquatic environment of Ashlu Creek will be monitored to ensure compliance with the environmental standards and agreements made with MOE and DFO during the permitting process for the Project. This Five Year, Post-Construction Monitoring Program (the Program) proposes the technical methods that will be used for data collection and presentation to DFO under the Projects Fisheries Authorization (04-HPAC-PA2-000-000530) dated July 31, 2006. The post-construction monitoring period, as described in the Fisheries Authorization, is five (5) years from the date of commercial operation of the Project, which is the date when construction is substantially completed and the Project begins to generate electricity for sale to BC Hydro, which based on an expected Commercial Operation Date (COD) of December 2009, is anticipated to be the period from January 2010 to December 2014.
2.0
Study Area
Ashlu Creek rises in the Tantalus Range of the Coast Mountains and flows in a south-easterly direction to its confluence with the Squamish River, approximately 20 km north of the Town of Squamish, B.C. It is a fifth order stream with a length of approximately 34 km and a drainage area of 324 km2. The catchment area of Ashlu Creek at the proposed intake location is 295 km2. The mean annual flow in Ashlu Creek at the intake site is estimated to be 27.1 m3/s (per Knight Pisolds February 2004 report). Ashlu Creek has been gauged intermittently since 1991 and consequently longer term flow records were synthesized from data obtained from a nearby Water Survey of Canada gauging station on the Elaho River. The lowest mean monthly discharges of 3 m3/s to 5 m3/s occur in winter (December to March), while the highest mean monthly discharges of 60 m3/s to 65 m3/s occur in the summer (June and July). The Ashlu Creek Aquatic Environmental Assessment Report (September 2002) and the Aquatic Environmental Addendum (April 2004) by Sigma Engineering described the fish and fish habitat in detail. It is summarized following in the context of the six distinct reaches of the creek. Reach 1 begins at Ashlu Creeks confluence with the Squamish River and extends up 2.8 km upstream to the upstream end of the double bridge island. This reach has a low gradient, highly productive side channels, and comprises primarily riffle habitat. Chinook, coho, chum, pink, and sockeye salmon, winter run steelhead, coastal cutthroat and rainbow trout, and Dolly Varden char were found in this reach. Reach 2 is the cascade section of the creek, with gradients ranging from 4 to 8%, several small falls, and riffle-chute habitat. It extends 2.7 km from the top end of the double bridge island up
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to the natural island in the middle of the Ashlu Canyon. This reach provides little to no spawning or rearing habitat due to the high velocity and minimal in-stream cover. An adult steelhead was found at the start of the reach at low flows in November 2001, and several smaller migratory fish were found at the top end of the reach at low flows in April 2002. A natural fish barrier is located in Reach 2 at approximately 0.8 km upstream of the double bridges; anadromous fish migration ends at the canyon. Reach 3 is located entirely within a vertical walled canyon from the natural island to a 6 m high waterfall. The habitat is continual rapid-chute with many waterfalls up to 2 m in height. Instream cover is minimal and banks are steep, providing little overstream cover. No fish were located in this reach. Reach 4 has low gradient and good fish habitat, with a mixture of riffles, glides and pools, and abundant in-stream cover. It extends 6.5 km upstream from the 6 m high water fall, past the proposed project intake, up to near the confluence with Pykett Creek. Within the creek there are several islands, creating side and back channels, and the substrate is primarily gravels and boulders. Numerous rainbow trout were caught on all sampling dates. Reach 5 extends from near Pykett Creek to 3.5 km upstream of the confluence of Tatlow Creek. It has similar habitat to Reach 4, with low gradient, abundant cover, a mixture of riffles, glides and pools, and several side channels. Fish were caught throughout the lower reach. Reach 6 is characterized by high velocities and steep slopes in a narrow, confined channel. It extends from Reach 5 up to the headwaters of Ashlu Creek. There is minimal cover in the reach, the flows are cascades and riffles, and the substrate is mainly bedrock and boulder. No fish were located in this reach. Steelhead fry were stocked in the upper reaches (Reaches 4, 5 and 6) of Ashlu Creek by the Fisheries Branch of Ministry of Environment, Lands and Parks (MoELP) from 1978 to 1997, and residual populations of these steelhead/rainbow trout inhabit the reaches above the Ashlu Canyon.
3.0
Monitoring Components
The Program comprises two types of monitoring: compliance monitoring and biotic response monitoring. Compliance monitoring measures water use to ensure that Ashlu Creek Investments Limited Partnership (the Proponent) is complying with the conditions of MOEs Conditional Water License, including water quantity, quality and temperature, and DFO/MOEs habitat compensation works to ensure that they are physically stable and performing adequately. Biotic response monitoring addresses the complexity of the biological response to flow conditions, and the monitoring program will measure the effect of flow releases on target ecological resources (i.e. fish populations, fish habitat, and invertebrate abundance).
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To reduce the natural variation in Ashlu Creek, time of year and flow range at the time of sampling will be standardized to the extent possible. Field studies will be planned to target a specific flow within a practical calendar period rather than aiming solely for a particular calendar date each year. The approached developed by Hatfield and Lewis (2007) for Independent Power Projects (IPPs) in British Columbia follows a quantitative, site effectiveness monitoring with a beforeafter control-impact (BACI) approach. Under this approach, control sites (i.e. portions of Ashlu Creek or reaches without water withdrawal) are monitored simultaneously with impact sites (i.e. reaches with water withdraw) for a predetermined period both before and after project implementation. Typically, the control sites are upstream of the Project area, and impact sites are within the diversion reach of the Project. In the case of the Ashlu Project, baseline studies were carried out from 2001 to 2006, a period of five (5) years and were done prior to the new Provincial guidelines (Hatfield and Lewis, 2007); therefore, not all of the criteria outlined in the guidelines for control sites have been implemented during these previous studies. The Program consists of monitoring the following aquatic components: 1. 2. 3. 4. 5. 6. 7. 8. 9. Water flow; Water quality; Water temperature; Fish abundance and biomass density; Invertebrate abundance and biomass density; Compensation fish habitat efficacy; Stream channel morphology; Instream Flow Requirement; Flow ramping; and
10. Footprint impact verification. The key areas where these monitoring components will be performed are described below and are shown on Figure 1. All locations are referenced to the distance along the Ashlu Forest Service Road (Ashlu FSR) originating from the Squamish River Bridge. 3.1 Headpond The headpond is located approximately 9 km along the Ashlu FSR and is directly upstream of the intake and weir. When the headpond is filled to its normal operating elevation of 276.0 metres, it will extend approximately 400 metres upstream of the intake and weir. 3.2 Intake/Weir The intake and weir are located approximately 9 km along the Ashlu FSR and are directly downstream of the headpond. The intake comprises a fixed concrete structure and earthfill dam
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with sluice and intake gates; the weir comprises a fixed concrete sill and an inflatable, rubber, Obermeyer weir. The fish ladder is located within the intake/weir structures. 3.3 Mile 25 Bridge The Mile 25 Bridge is located approximately 7 km along the Ashlu FSR and crosses Ashlu Creek just upstream of the Ashlu Canyon. The bridge was built by previous logging companies who worked within Tree Farm License 38 area where Ashlu Creek is located. There is a fork in the Ashlu FSR just 100 metres prior to reaching the Mile 25 Bridge, and this fork leads to the intake, weir and headpond areas. 3.4 Gravel Bar in Ashlu Canyon The gravel bar in the Ashlu Canyon is located approximately 5.5km along the Ashlu FSR and is not accessible from the road. The area is defined at a widening of the Ashlu Canyon where the flow energy of the stream decreases and forms a large gravel bar. Both upstream and downstream of this location are narrow, bedrock canyons. 3.5 Gustafson (Bend) Creek Gustafson (or Bend) Creek is located approximately 4.4km along the Ashlu FSR and is an intermittent stream. In the winter and early spring, Gustafson Creek typically acts as a conduit for avalanches that cross the Ashlu FSR. Immediately downhill of Gustafson Creek is a steep section of the Ashlu FSR. 3.6 Powerhouse/Tailrace/Switchyard The powerhouse and tailrace are located approximately 2.8km along the Ashlu FSR. The powerhouse comprises a fixed concrete building with turbines and generators within, and the tailrace comprises a fixed concrete pool and overflow sill into Ashlu Creek. The powerhouse and tailrace are located immediately downstream of the mouth of the narrow Ashlu Canyon. Adjacent to both structures is the electrical switchyard, and slightly uphill is the tunnel portal and adjoining penstock (buried beneath the Ashlu FSR). 3.7 Double Bridges The double bridges are located approximately 2.5km along the Ashlu FSR and cross Ashlu Creek in two places. Like the Mile 25 Bridge, these bridges were built by previous logging companies who worked within the Tree Farm License 38 area. The double bridges mark the area where Ashlu Creek changes to a wide, low energy, meandering stream. This location is generally known to be the upstream limit for salmon spawning in Ashlu Creek. 3.8 Fish Compensatory Habitat The fish compensatory habitat is located approximately 1.5 to 2km along the Ashlu FSR and covers the area to the north and south of the FSR, including along the transmission line right-ofway. This area also connects DFOs small intake and fish habitat ponds and channels that were
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established in the late 1990s. The fish compensatory habitat comprises a network of narrow, low energy streams and pools that criss-cross the transmission line right-of-way and enter into the forested area on the Ashlu Creek delta.
Figure 1 Post-Construction Aquatic Monitoring Program Monitoring Station Locations
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3.9 Transmission Line The transmission line begins at the electrical switchyard and extends for approximately 3km to the BC Hydro switch beside the Squamish River Bridge. The transmission line parallels the Ashlu Forest Service Road and crosses over Ashlu Creek at the double bridges.
4.0
Water Flow
The primary objective of water flow monitoring is to provide accurate, real time instantaneous flow data in the most practical manner that meets the requirements of DFO and MOE. Monitoring flows will allow verification of the instream flow release (IFR) in the stream at these critical locations for compliance with DFOs Fisheries Authorization provision for minimum flow release. 4.1 Monitoring Locations A total of four (4) hydrometric stations will be installed at the intake (two), Mile 25 Bridge, and at the powerhouse/tailrace. At each station, an electronic pressure transducer will be utilized, and will measure the water level in the headpond and the water level in Ashlu Creek downstream of the intake, within the diversion reach, and downstream of the tailrace. A total of four (4) visual staff gauges will be installed alongside the electronic pressure transducers to provide visual references of the water levels. The staff gauges will allow regulatory agency personnel to evaluate instream flow conditions independent of project operations at any time. 4.2 4.2.1 Monitoring Approach and Analysis Electronic Pressure Transducers At the headpond, a pressure transducer will be installed to continually measure the elevation of the water upstream of the rockfill weir and concrete structures. A second pressure transducer will be installed at a suitable location downstream of the rockfill weir and concrete structures to measure the total IFR, which includes flows from the IFR pipe, fish ladder, sluiceway, emergency spillway, seepage under the structures and overflow from the Obermeyer weir. At the Mile 25 Bridge, located approximately 2 km downstream of the headpond, an existing pressure transducer will continue to measure the elevation of the water within the diversion reach. This station has a proven flow discharge curve which was established during the development phase of the project and has been maintained on a regular basis. It is envisioned that this information will be converted from water depth to flow and be posted onto a publicly accessible web site for recreation users to observe. At the Mile 25 Bridge location, the water level in the diversion reach will be a combination of the IFR plus inflows from tributaries downstream of the weir, seepage from underneath the
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various structures, and any flow releases from the fish ladder, sluiceway and emergency spillway. The hydrometric stations will be installed according to RISC protocols (1998). 4.2.2 Visual Staff Gauges The visual staff gauges will be located near the electronic pressure transducers so that the water level readings from the transducers correlate to the staff gauges. The staff gauges will typically be aluminium strips with calibrated markings (in centimetres) on them, and will be mounted to a stationary object (i.e. rock outcrop, bridge abutment).
A minimum of three (3) discharge measurements, well distributed over the range of discharge flows, will be manually measured to establish the initial rating curves for Ashlu Creek in the diversion and downstream reaches. Due to the significant amount of natural flow in Ashlu Creek, it is unlikely that flows will be able to be measured above 20% of Mean Annual Discharge (MAD) of the full stream flow (27 m3/s) in Ashlu Creek. Once the flow rating curve is established, the water level data collected from the electronic pressure transducers can be converted to flow values. 4.3 Reporting The flow data will be collected on a continuous basis, typically in 15 minute reading intervals, and will be converted to flows for reporting purposes. The data will be recorded and available to the plant operator on a real time basis. The Proponents plant operator can provide on-site DFO and/or MOE staff with the instantaneous water level and flow data for compliance purposes. The headpond data will also be collected on a continuous basis but at a higher frequency as this information is transmitted to the powerhouse for the overall flow control from the intake. The flow passing through the turbines in the powerhouse can be accurately measured through a turbine efficiency test that will be completed during commissioning of the Project. This tests will provide measured data on turbine flow output that can be correlated with tunnel/penstock pressures and then used to develop a program that can convert real time energy and pressure measurements into flows. Flow data will be reported quarterly. summarized in Table 1. Details of the water flow monitoring program are
5.0
Water Quality
The primary objective of water quality monitoring is to monitor for potential impacts of the Project on the stream by collecting and comparing water quality samples taken upstream of the intake and headpond areas of influence (the Control Samples), and within the diversion reach and downstream of the tailrace (Impact Samples).
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5.1 Monitoring Locations Water quality samples will be collected from four (4) locations; i) upstream of the headpond (upstream by 100 to 200 metres and downstream of Pokosha Creek), ii) upstream of the powerhouse/tailrace in the mouth of Ashlu canyon, iii) directly from within the tail race weir, and iv) at or near the double bridges on the Ashlu delta. The double bridge location will likely correspond with one of the pre-project water quality data collection locations; the other two locations will be new locations. 5.2 Monitoring Approach and Analysis Samples taken upstream of the headpond will provide baseline water quality prior to any water reaching, and being influenced by, the intake structure. Samples taken upstream of the powerhouse will represent the most changed water conditions as the water will have flown entirely down the diversion reach at this point. Samples taken from within the tail race weir will reflect any changes to the water quality due to its passage through the water conveyance system, and in particular the tunnel. Samples taken at the double bridge site will reflect the mixed water quality of the diversion reach and discharged water back into the stream from the tunnel/penstock. Water quality samples at all sample locations will be collected semi-annually, which is coincident with low flow events at the beginning and end of the fish growing season, which occurs in April and October, when there is the greatest potential for there to be impacts from the Project on water quality. Water quality samples at the tail race will be collected quarterly to more frequently monitor Acid Drain Rock and metals leaching from the tunnel rock. Water quality parameters most likely to be affected by the project operations include total suspended solids (TSS) and total gas pressure (TGP). Samples will be collected and sent to a certified laboratory for analysis; dissolved oxygen and TGP data will be collected in-situ with portable meters. Dissolved oxygen, turbidity, total suspended solids (TSS), specific conductance, total alkalinity, pH, total phosphorus, ortho-phosphorus, ammonia, nitrite, nitrate and metals will also be analysed. 5.3 Reporting TSS and TGP values will be compared from the three sampling locations to compare and contrast any changes between the values of the Control and Impact Samples. Also, the baseline study values will also be presented to compare and contrast with sample results from the double bridge sample location. Dissolved oxygen, turbidity, TSS, specific conductance, total alkalinity, pH, total phosphorus, ortho-phosphorus, ammonia, nitrite, nitrate, and metals will also be compared. TGP is expected to decrease in the diversion and downstream reaches following project operation, based on the fact that flow reductions in the diversion reach will decrease the entrainment of air in pools and the potential for increases in dissolved gas. This prediction will
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be confirmed by comparing the results of the Year 1 study with the baseline data; should the predictions be confirmed, then TGP sampling will be terminated after Year 1. Water quality results will be reported annually. Details of the water quality monitoring program are summarized in Table 2.
6.0
Water Temperature
The primary objective of water temperature monitoring is to observe any potential significant changes in water temperature and the effect of water diversion during operations on water temperatures in the diversion reach and the Ashlu delta. The secondary objective is to observe the water temperatures in the new fish compensatory habitat areas, which are somewhat independent of the ambient water temperature of Ashlu Creek due to the change in stream characteristics for creek into the habitat areas.(i.e. high vs. low energy streams). 6.1 Monitoring Locations Water temperature will be monitored at five (5) stream locations: within the headpond, in the diversion reach at the Mile 25 Bridge, at the powerhouse/ tailrace discharge area, and near the double bridges. A fifth location, which is not on Ashlu Creek, will be in the new fish compensatory habitat on the Ashlu delta. 6.2 Monitoring Approach and Analysis Water temperature data will be collected using stand-alone water temperature sensors or with water level data collection from electronic pressure transducers (as per Section 1). The sensor in the headpond and will be combined with the headpond water level sensor, and will measure the water temperature of the inflowing water from the non-impacted reaches upstream of the Project. The existing water temperature sensor at the Mile 25 Bridge will continue to measure the water temperature within the diversion reach. The sensor installed within the tailrace will measure the temperature of the diverted water from the intake as its passed through the tunnel/penstock and discharged from the powerhouse. The sensor near the double bridges will measure the water temperature of the mixed water from the powerhouse discharge and the flows in the diversion reach. The sensor in the new fish compensatory habitat will monitor the overall temperatures of the slow moving water as it passes through the shallow channels and pools (see Section 6 for details). Water temperature data will be collected in 15 minute intervals (when the sensor is combined with an electronic pressure transducer for measuring water levels) or in two hour intervals (for stand-alone sensors) and will be downloaded quarterly (for the electronic pressure transducers) and semi-annually (for the stand-alone temperature transducers). 6.3 Reporting
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Water temperature data will be reviewed to determine if any temperature issues are present (i.e. biologically significant differences between baseline and operating temperature regimes). The measured temperatures will be compared to the temperature database from the environmental baseline study to observe whether the diverted flow has any affect on the streams overall water temperature. The new measurements may be used to potentially predict and calculate extreme conditions to provide more accurate estimates of temperatures during extreme conditions, which may not be observed in the first few years of monitoring. The frequency of temperature monitoring may be reduced or terminated after five (5) years from the project commissioning should the measurements show that temperature changes are insignificant under the Projects operations and the predicted future conditions. Water temperature results will be reported annually. monitoring program are summarized in Table 3. Details of the water temperature
7.0
Fish Abundance and Biomass Density (Fish Community)
The primary objective of fish abundance and biomass density (also known as fish community) monitoring is to determine whether the fish populations decrease in the diversion reach during Project operations. The target species for monitoring of fish abundance and biomass will be rainbow trout, which were encountered in the upper end of the diversion reach; the secondary target species will be coho salmon, encountered at the lower end of the diversion reach. Rainbow trout were primarily observed upstream of the Mile 25 Bridge, although some were found in the Ashlu Canyon as they were washed down each year, and were survivors of a stocking program carried out by the Ministry of Environment in the 1980s in the upper reaches of Ashlu Creek. Coho salmon were observed in the lower end of the diversion reach (approximately 300 metres upstream of the powerhouse and tailrace location).While this short length of stream was used primarily for rearing and not spawning, it will be included in the monitoring program. The area downstream of the double bridges is known salmon spawning habitat. 7.1 Monitoring Locations The fish community will be monitored in four (4) reaches: one (1) "control" reach located upstream of the headpond on an undisturbed section of Ashlu Creek and three (3) impact reaches within the diversion reach. The control reach location will be upstream the upper limit of the headpond and downstream of the confluence of Pokosha Creek. The impact reaches will be at or near the Mile 25 bridge, in Ashlu Canyon along the gravel bar/side channel, and upstream of the powerhouse/tailrace area at the mouth of the Ashlu canyon. 7.2 Monitoring Approach and Analysis To observe the potential affects of the Project on fish, the following fish characteristics will be
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monitored and measured: Presence/absence; Distribution; Population density; Condition (health); and Age structure.
Rainbow trout abundance and density will be monitored at the upper monitoring locations (i.e. headpond, Mile 25 bridge, gravel bar) whereas coho salmon abundance and density will be monitored at the lower location (i.e. powerhouse/tailrace) only as coho salmon are limited to this reach due to the cascade at approximately 500 metres further upstream of the powerhouse/tailrace location. Within this lower reach, rainbow trout may also be encountered as they may be seasonally washed down through the Ashlu canyon to this location. Due to the low conductivity of Ashlu Creek, electrofishing has not typically been the most effective method for fish sampling, and therefore fish sampling will be primarily performed using Gee Traps. The Gee Traps will comprise fine mesh nets capable of barring rainbow trout fry and coho salmon. A minimum of five (5) replicate sample sites will be established in each of the control and impact reaches. Impacts of the headpond, caused by backwatering of the stream channel upstream of the water intake and weir, will also be monitored. Fish abundance sampling will be performed during project operations and the results comparing the observed densities in the baseline study to determine if the headpond has encouraged or displaced fish. Due to the greater depth of the headpond than the pre-project creek, angling will be used as the primary method of fish detection. During the fish abundance sampling, abundance in fish habitats approximately 100 m upstream and downstream of the intake (i.e. within the headpond and downstream of the IFR and fish ladder flow releases) will be evaluated by snorkelling and/or Gee Traps (or electrofishing, if possible) to determine fish quantity, species type and size class. Captured fish will be identified (type and species), body weight and fork length measured, and scale samples of adult taken for age identification prior to being returned to the stream. In addition, notes of the sampling area, its usability as habitat, and the water temperature and conductivity on the day of sampling will also be collected. 7.3 Reporting Based on the fish captured using the various methods, the presence/absence, distribution, population density, condition (health) and age structure of the fish will be reported. The same sampling sites will be used each year to allow paired comparisons of the fish capture in statistical tests and thereby increase statistical reliability as the program is performed over the five year period. The sampling sites will be georeferenced, photographed, and marked in the
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field to allow the same location to be used repeatedly each year. Sampling will take place during September or October when the flow in Ashlu Creek is low and also during the rainbow trout growing season. The headpond/IFR data will be used to evaluate the relative use of the headpond and habitat downstream of the intake structures by rainbow trout, and will provide evidence of any blockage to upstream movement. Fish abundance and biomass density results will be reported annually. Details of the fish abundance and biomass density monitoring program are summarized in Table 4.
8.0
Invertebrate Abundance and Biomass Density
The primary objective of invertebrate abundance and biomass density monitoring is to test whether invertebrates decrease in the diversion reach during Project operations. 8.1 Monitoring Locations Invertebrate abundance and biomass density will be monitored in three (3) locations: two (2) "control" reach located upstream and downstream of the Project, and one (1) impact reach within the diversion reach. The upper control reach location will be upstream the upper limit of the headpond and downstream of the confluence of Pokosha Creek; the lower control reach will be at or near the double bridges. The impact reach will be within the proposed diversion reach at or near the gravel bar in the Ashlu canyon. In addition, the sampling sites will be located in representative habitat in the downstream half of a riffle section, and to the extent possible, nets will be set in areas with water velocities of 0.2 to 0.4 m/sec. 8.2 Monitoring Approach and Analysis Abundance and distribution of macroinvertebrates in the drift will be characterized through the use of drift samplers, which are vertically fixed nets that are suspended in the water column. The samplers will be installed with rebar, set in the current and left to "fish" for a period. Drift samplers will be fixed plankton-type drift nets (30 x 30 cm mouth) with 250 m mesh to retain invertebrates of most importance to fish. Drift will be sampled in the daytime to reflect prey abundances available to fish and will be deployed for a sufficient period to gather an adequate drift sample (typically two hours, but may be shorter, depending on drift conditions. Two (2) replicate samples will be collected at each site on each sampling day according to the methods for collection and analysis of invertebrate drift as presented in Hatfield and Lewis (2007). Sites will be sampled at least once during the main growing season, usually May through September when the fish abundance surveys are being performed and during low to moderate flows. If additional samples are collected, the sampling dates will be separated by at least one (1) month. One (1) sample should be taken during base flow conditions; the other
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sample should be taken within the growing season prior to the period of lowest flows. Captured macroinvertebrates will be identified by type and species, as well as abundance (quantity). In addition, the sampling area and the water temperature on the day of sampling will also be noted.
8.3 Reporting Based on the macroinvertebrates captured, the presence/absence, type and species, quantity and population density will be reported. The same sampling sites will be used each year to allow paired comparisons of the macroinvertebrates capture in statistical tests and thereby increase statistical reliability as the program is performed over the required period. The sampling sites will be georeferenced, photographed, and marked in the field to allow the same location to be used repeatedly each year. Sampling will take place during September or October when the flow in Ashlu Creek is low and also during the rainbow trout growing season. The monitoring of invertebrate drift organism abundance and biomass density will be measured up to twice per year. Details of the invertebrate abundance and biomass density monitoring program are summarized in Table 5.
9.0
Compensatory Fish Habitat Efficacy
The primary objective of compensatory fish habitat efficacy monitoring is to monitor the performance of project mitigation and compensation habitats, which will be evaluated following project commissioning after one (1) and five (5) years of operation. 9.1 Monitoring Locations Compensatory fish habitat efficacy will be monitored at two (2) locations: the fish ladder, at the intake and weir area, and the new fish compensation habitat on the Ashlu delta. 9.2 9.2.1 Monitoring Approach and Analysis Fish Ladder The efficacy of rainbow trout passage past the water intake will be evaluated qualitatively by an inspection of the fish ladder each year during the period of rainbow trout movement (typically in April/May). The fish ladder will be examined, and measurements of depths and velocities at key locations within the ladder will be taken to provide information on the flow conditions and on the discharge through the ladder. Periodic observations will be made to check on fish passage either in the ladder or at the staging area below the ladder. 9.2.2 Rearing Fish Compensation Mitigation and compensation habitat for the Project was created on the Ashlu delta
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primarily for coho salmon, with secondary works for rainbow trout/steelhead, as directed by DFO and MOE. The compensatory fish habitat for coho salmon comprises a series of new channels, pools and the interconnection of existing, intermittent channels along the Ashlu flood plain into the existing DFO developed pools and channels created in the late 1990s. Construction of the new habitat was supervised by an on-site DFO representative in June 2007 and May 2008, with overview by the Environmental Monitor and Proponent to assist in the channel and pool layouts. Once the compensatory habitat was built in 2007, occasional visits were made to review the conformance with the design specifications, and to ensure post-construction inspection to ensure adherence to the original compensation plan for the Project. In 2008, some modifications were performed to optimize flows, and additional channels and pools were independently added on by DFO to interconnect to Buck Creek, located further north on the Ashlu delta. The compensatory fish habitat for rainbow trout/steelhead comprised several triangulated debris jams (i.e. root wad and log structures) that were installed in 2007 by MOEs representative in and around the original DFO habitat as well as along the north bank of Ashlu Creek. Additional work was carried out in 2008 to fine-tune this habitat work, and was carried out under supervision of DFOs representative. The fish compensatory habitat will be examined, and measurements of depths and velocities at key locations within the streams and pools will be taken to provide information on the flow conditions and discharge through the system. Periodic observations will be made to check on fish utilization in the channels and pools. Utilization of the fish ladder and compensatory habitat will be through observations and photographs. 9.3 Reporting Coho salmon presence/absence, and the physical integrity, stability and erosion of the new habitat channels will be noted for the compensatory habitat, whereas rainbow trout presence/absence only will be noted for the fish ladder. Temperature will be monitored in the fish compensation habitat using a single continuous recorder, as described in Section 3. This sensor will be located in the large pool or in the adjacent large culvert located on the north side of the existing Forest Service Road and at the base of Buck Mountain. Details of the compensatory fish habitat efficacy monitoring program are summarized in Table 6.
10.0 Stream Channel Morphology

The primary objective of compensatory fish habitat efficacy monitoring is to assess any potential impacts that the Project has on channel stability and sediment conditions during operations.
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10.1 Monitoring Locations Stream channel morphology will be monitored at three (3) locations: in the headpond, the diversion reach at the gravel bar in the Ashlu canyon, and at or near the double bridges (downstream of the powerhouse/tailrace). 10.2 Monitoring Approach and Analysis To determine whether there are any changes in the stream channel morphology during Project operations, data will be collected prior to project completion to provide a baseline data set, and either (a) after a large flood event (the first 1 in 10-year event or greater event as determined by hydrology at the point of diversion) or (b) at the end of five (5) years of post-construction monitoring, whichever comes first. During operations, periodic observations will be made to identify any changes to the habitat in the diversion reach over time in the designated areas. Transects will be carried out to measure the quantity of change of the stream channel shape and size. These transects will allow for a comparison of the changing stream channel and will aid in assessing whether the IFR is affecting any of the fish habitat as was originally predicted. For the headpond, transects will likely not be achievable due to the depth of the headpond; as an alternative, bathometry may be used to map the profile of the headpond. At the headpond, the change in the bathometry profile of the base of the headpond will allow the rate of sediment infilling to be determined. In the diversion reach, the transect measurements will show how often the gravel bar side channel is wetted and used by rainbow trout. At the double bridges, the transect measurements will show if the channel profiles are changing on gradual basis during operations or if the channel profiles change only after large flood events as is currently the pre-Project case. 10.3 Reporting Transect cross sections and headpond bathometry profiles will be presented, as well as a description of any changes to these sections and their apparent affect on fish habitat. The sampling sites will be georeferenced, photographed, and marked in the field to allow the same location to be used repeatedly each year. The stream channel morphology results will be reported annually. Details of the stream channel morphology monitoring program are summarized in Table 7.
11.0 Instream Flow Requirement

The primary objective of monitoring water flows is to ensure the instream flow requirements (IFRs) are met. 11.1 Monitoring Locations
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The primary gauge for IFR measurement is at the first suitable location downstream of the intake which is the transition from a relatively flat gravel and boulder field into a bedrock canyon, approximately 250 m downstream of the intake. A pressure transducer level probe is installed in this location and connected to the intake control building by a teck cable suitable for direct burial. The water level is measured on a continuous basis and relayed to the powerhouse control system in real time. A water level benchmark corresponding with the 2.42 m/s IFR required under the DFO Authorization has been established in March 2009 and will serve as a visual reference to calibrate the level probe. A secondary gauge for backup and calibration purposes is installed in the diversion reach at the Mile 25 Bridge location. Approximately 10% of the flows measured at this location are attributed to a small tributary between intake and this location. Therefore, the IFR immediately downstream of the intake is approximately 90% of the flow measured at this location. The secondary station is powered by a solar panel with battery backup and direct radio link to the powerhouse. The station also provides data required under the DFO Authorization and houses a kayaker warning system as required by NWPD. 11.2 Monitoring Approach and Analysis IFRs for this project are defined in the Authorization issued by DFO and the Approval issued by NWPD. It is noted that when the two documents call for different minimum flows at the same time, the higher flow will be released. 11.2.1 Requirements under DFO DFO Authorization 04-HPAC-PA2-000-000530 sets the minimum IFR at 2.42 m/s year around with no seasonal adjustments required. This flow is primary provided through a 30 inch bypass pipe has been installed as part of the sluiceway structure. The center inlet elevation of the pipe is 272.0 meters, while the normal operating water level is 276.0. The inlet is protected by a coarse trash rack and the inflow can be controlled by a manually actuated knife valve. The IFR valve will be calibrated to the required minimum flow during the commissioning of the plant. Because the water level in the head pond will remain nearly unchanged during normal operation, it is not expected that the valve requires adjustments during the operational phase of the project. The sluiceway flap gate acts as a backup system to meet the IFR in case the 30 inch pipe is not providing the required flows or is shut down for maintenance and repair works. The capacity of the flap gate is approximately 3 m/s at normal head pond operating water level. 11.2.2 Requirements under Transport Canada / Navigable Waters Protection Division Approval #8200-T-10595.2 issued by NWPD calls for instream flow releases to accommodate recreational use of the creek through kayakers during specific days and times as follows if pre-booked by kayakers:
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Four weekends (Saturdays and Sundays) in May and eight weekends (Saturday and Sundays) in August and September for a total of 24 days and on each of those days between 9am and 6pm Flow release to range between 16 m/s and 32 m/s. Amounts of actual release to be coordinated between ACILP and the kayakers.
An online booking system is being developed to meet the spring 2010 kayaking season. The system will allow kayakers to book flow release days within the windows described above and select their preferred release rate within the required range. Flows for kayaking purposes will be primarily released and controlled through the sluiceway. 11.3 Reporting All data, raw and analyzed will be made available to the regulatory agencies throughout the season. Monitoring of stream flows will be maintained throughout the life of the project and may be used with other effectiveness and compliance monitoring programs. Details of the IFR monitoring program are summarized in Table 8.
12.0 Ramping
The primary objective is to assess the efficacy of Proponents proposed ramping rate. 12.1 Monitoring Locations Ramping will be monitored at three (3) locations: in the diversion reach immediately downstream of the water intake and weir and at the gravel bar within Ashlu canyon, and downstream of the diversion reach at the double bridges. 12.2 Monitoring Approach and Analysis During commissioning, normal operation, start ups, normal shut downs and emergency shut downs, the ramping rates shall not exceed 29.0 m3/sec per 90 minutes. This rate will be confirmed during the commissioning process of the plant and may be subject to different flow conditions in the creek. This rate was based on the natural ramping rates that have been historically observed in Ashlu Creek over several years since 1991 when a dedicated hydrometric station was first established on the stream. Ramping rates will be monitored during commissioning of the Project to measure water level change rates and their resulting changes to fish habitat (i.e. dewatering of side channels and the potential stranding of fish). During project commissioning, the efficacy of this rate will be tested by ramping down at the specified rate and measuring the resulting water level change in the sensitive habitats in the diversion reach and further downstream where all of the diverted and IFR flows converge. The ramping rate test will occur when fry and juvenile rainbow trout are present. If the Project is
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commissioned when fry and juveniles are not present (i.e. January to May), an additional test will be made when flows are below design flow levels and when fry and juveniles are present. Once determined, the ramping rate will be used throughout the operation of the Project. To monitor the effect of ramping during Project commissioning, temporary (or permanent) water level gauges will be installed at the key sites, and will consist of a manual gauge plate (approximately 60 cm in height) fixed to the bank, large boulder, large woody debris or hammered in the stream bed. In addition, the water level data measured by the electronic transducers at the hydrometric stations (installed as per Section 1) will also be collected. The habitat and water levels at the monitoring locations will be observed and measured by a biologist, who will be stationed at each monitoring station during the ramping test, to document any incidences of fish stranding. The biologist will collect the baseline habitat data and visually observe for any fish presence/absence. Habitat data will include dominant stream cover types, substrate composition and a general description, including GPS coordinates. A photo monitoring station will be established at each site, and photos will be collected (and repeated) at each of the cross-sections measured. Drawings of each site showing the location of photo monitoring stations and gauge locations will be prepared. The sites will be monitored at the beginning and end of each ramping commissioning test to document the extent of flooding and collected habitat measurements. At each site, the wetted widths and wetted lengths of any isolated pools will be measured along with measurements of water level changes from the staff gauges. Temporary cross-sectional pins will be set in the ground to identify the locations where wetted widths and lengths are to be collected pre-and post-ramping. Where wetted areas become dry post-ramp, substrate will be excavated by hand and overturned to confirm fish presence/absence. Any fish found will be captured, enumerated by species and age class, and their reason for stranding will be recorded (i.e. fish isolated in a pool or habitat was dewatered). Following project commissioning, the water level sensors hydrometric stations (as installed in Section 1) will record water level changes annually for one (1) to five (5) years in the diversion reach. 12.3 Reporting Photos of each key monitoring site at specific flows will be provided for each of the monitoring stations. Cross-sections of each monitoring site will be prepared and will show the stream profiles, water level changes and gauge locations from the transect measurements. In addition, a description of the dominant stream cover types and substrate composition will accompany the cross-sections. The ramping results will be reported within six months after Project commissioning is completed. Details of the ramping monitoring program are summarized in Table 9.
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13.0 Footprint Impact Verification

The primary objective of footprint impact verification is to assess and quantify whether the asbuilt Project footprint impacts aquatic and riparian habitats. 13.1 Monitoring Locations Footprint impact verification will be measured at the intake and weir, powerhouse, tailrace, switchyard, portions of the access roads (leading down to the intake, powerhouse, switchyard) and portions of the transmission line, as these areas are located instream and/or within the riparian zone of Ashlu Creek. 13.2 Monitoring Approach and Analysis Impacts on aquatic and riparian habitat will be verified through direct on-site measurements. The physical dimensions of each right-of-way or clearing that impacts a riparian zone or an aquatic habitat will be measured in the field and documented with photographs. For aquatic habitat, the bed material will be described in the impact zones (i.e. concrete, rip-rap), while for riparian habitat, the condition of the reseeding/replanting will be documented. The monitoring of the effectiveness of re-vegetation will take place for one (1) year following the completion of construction and late in the growing season, when a full season of growth will be evident. Successful replanting will be evidenced by a survival rate of 80% of the stock; if more than 20% of the planted stock dies over one year, replanting will be required. Replanting of lost vegetation should occur within eight months of disturbance, with stock planted during the fall and spring to ensure the greatest likelihood of survival. Once planted, brushing around seedlings may be required to remove competing vegetation and additional erosion control may be required to stabilize vegetation on steep, erodible soils and ensure long-term vegetation success. 13.3 Reporting The effectiveness of the re-vegetation and any replanting requirements will be documented so that they can be planned and completed the following year during the growing season. The footprint impact verification results will be reported annually. Details of the footprint impact verification monitoring program are summarized in Table 10.
14.0 Reporting
The objectives, methods, results and recommendations for changes to and/or additional monitoring will be provided in annual or more frequent reports, depending on the component of interest. The timing of reporting for the monitoring programs will vary by component, however annual reports will be prepared for all, except those components that only require a one-time study (documented in a single report) or those that require more frequent monitoring.
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All baseline monitoring data will be compiled in a report for agency review by March 31, 2010 following the year in which project construction is complete. In each year following this, an annual report will be submitted to DFO and MOE that documents the findings of the previous year's study. After five (5) years of post-project monitoring, a summary report will be completed that evaluates the need for additional monitoring. Section 8 (ramping) will be reported on within six (6) months of the completion of commissioning tests during which the ramping rate will be tested and refined. Section 9 (footprint impact verification) will be reported on by March 31, 2011 of the year following the completion of construction or earlier if the mitigation of disturbed areas has been completed. Annual reporting of project components will be standard for each component. All reports will be certified by an appropriately qualified professional registered biologist as required.
15.0 Exclusions
Post-construction monitoring of Harlequin Ducks and Grizzly Bears will be carried out and reports issued to Environment Canada and the MOE, respectively, as per their regulatory permitting requirements. Therefore, these species have not been included in the Program.
16.0 References
16.1 General References
Hatfield, T. and A.F. Lewis. 2007 (draft). Guidelines for the collection and analysis of data on fish and fish habitat in small steep streams. Prepared by Ecological Research Ltd. and Ecofish Research Ltd. for the BC Ministry of Environment, Surrey BC. Lewis, A., T. Hatfield, B. Chilibeck, and C. Roberts. 2004. Assessment methods of aquatic habitat and instream flow characteristics in support of application to dam, divert, or extract water from streams in BC. Ministry of Water, Land, and Air Protection, and the Ministry of Sustainable Resource Management, Victoria, BC. 101 pp. LWBC 2004. Hydrological Guidelines for Waterpower Projects, October 2004. Completed by the Surrey Regional Office, Land and Water Management Division, Suite 200-10428 153rd Street, Surrey, BC V3R 1E1. 20 pp. RISC. 1998a. Manual of Standard Operating Procedures for Hydrometric Surveys in British Columbia. Prepared for the Resource Inventory Standards Committee. Roper, B.B., J.L. Kershner, E. Archer, R. Henderson, and N. Bouwes. 2002. An evaluation of physical stream habitat attributes used to monitor streams. J. Am. Water Resource Assoc. 38: 1637 1646. 16.2 Project-Specific References
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Ashlu Creek Green Power Project Fish Ladder Design Modifications. Prepared by Ashlu Creek Investments Limited Partnership. March 3, 2008. Ashlu Creek Green Power Project Construction Environmental Management Plan Revision J. Prepared by Sigma Engineering Ltd. and modified by Ledcor Power Inc. November 8, 2006 (updated from original May 2004). Authorization for Works or Undertakings Causing the Harmful Alteration, Disruption or Destruction of Fish Habitat and Destruction of Fish (Authorization No. 04-HPAC-PA2000-000530). Prepared by Fisheries and Oceans Canada. July 31, 2006. 2005 Environmental Assessment Addendum for the Ashlu Creek Hydroelectric Project. Prepared by TRC Biological Ltd. September 1, 2005. Ashlu Creek Project South Side Channel Short-Term Compensation. Prepared by Ledcor Power Inc. February 28, 2005. Ashlu Creek Project Denil Fishway Design Proposal. February 3, 2005. Prepared by Ledcor Power Inc.
Ashlu Creek IPP Compensation for Steelhead Trout. Ministry of Water, Land and Air Protection to Fisheries and Oceans Canada. November 25, 2004. CEAA Screening Report Ledcor Power Inc.s Proposed Run-of-River Hydro Project on Ashlu Creek, BC. Prepared by Department of Fisheries and Oceans, Habitat and Enhancement Branch, Major Projects Review Unit (Vancouver, B.C.). October 18, 2004. Ashlu Creek Project Species at Risk Summary letter. Sigma Engineering Ltd. October 8, 2004. Ashlu Creek Project - Response to Environment Canada September 10, 2004 Letter. Prepared by Ledcor Power Inc. October 7, 2004. Ashlu Creek Hydroelectric Project Habitat Balance. Prepared by Sigma Engineering. September 2004 (updated from March 2004). Ashlu Creek Project Flow Ramping Rate Amendment. Prepared by Ledcor Power Inc. May 28, 2004. Ashlu Creek Run-of-River Power Project. Prepared by Fisheries and Oceans Canada. April 21, 2004. Ashlu Creek Power Project Species at Risk. Prepared by Sigma Engineering. June 7, 2004. 2003 Environmental Assessment Addendum for the Ashlu Creek Hydroelectric Project. Prepared by Sigma Engineering Ltd. April 13, 2004. Ashlu Creek Hydroelectric Project Habitat Balance. Prepared by Sigma Engineering Ltd. March 18, 2004. Ashlu Creek Water Power Project Wildlife Addendum to the Ashlu Creek Development Plan. Prepared by Sigma Engineering Ltd. January 9, 2004. 2003 Environmental Assessment Addendum for the Ashlu Creek Hydroelectric Project. Prepared by Sigma Engineering. April 13, 2004. Ashlu Creek Project Flow Ramping Rate Recommendation. Prepared by Ledcor Power Inc.
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March 29, 2004. Ashlu Creek Updated Hydrology Report. Prepared by Knight Pisold Consulting. February 25, 2004. Ashlu Creek Power Project - Wildlife Addendum to the Development Plan. Prepared by Sigma Engineering. November 28, 2003 Ashlu Creek Project Minimum Flow Recommendation. Prepared by Ledcor Power Inc. November 21, 2003. Ashlu Creek Hydroelectric Hydrology Report. Prepared by Sigma Engineering Ltd. October, 2002.
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Table 1. Objective Description Criteria Location Duration
Methods Sample area Units Sensitivity/accuracy Sample no.
Frequency Timing Measure constraints Analytical test
Water flow To ensure compliance with flow releases. Water level pressure sensors and manual flow discharge measurements. Flow discharge measurements over a range of flows (between 10% and 200% MAD). In the headpond; downstream of the intake structures; at the Mile 25 Bridge; downstream of powerhouse/tailrace. Headpond stage monitoring for the life of the project. Discharge measurements may be terminated when biotic response monitoring is complete five (5) years after project commencement provided that headpond stage has been shown to accurately measure channel flow in the diversion reach. Continuous pressure transducers; calibrated with manual velocity meters. Headpond; in stream channel downstream of intake, Mile 25 Bridge, downstream of powerhouse/tailrace. 3 Water level in mm and flow in m /s. +/- 2 mm for pressure transducers. To calibrate pressure sensors, minimum of three (3) discharge measurements (20+ vertical stream measurement slices) per transect; for headpond sensors, three (3) measurements. 15 second scan and two (2) minute log for headpond sensor; 15 minute scan and one (1) hour log for stream flow sensors. Continuous. For pressure transducers, select location on stream with adequate protection from debris for the standpipe; avoid placing transducer downstream of major local inflow, and avoid sites that dewater in low flow. n/a (compliance monitoring).
Table 2. Objective Description
Water quality To test whether water quality changes in the diversion reach during operations. Dissolved oxygen, total gas pressure (TGP), turbidity, total suspended solids (TSS) , specific conductance, total alkalinity, pH, total phosphorus, ortho-phosphorus, ammonia, nitrite, and nitrate Pre-construction (2 years) Upstream of headpond (control reach), in diversion reach (impact reach), and downstream of diversion reach. Two (2) year baseline and five (5) year post-construction mean. In-situ data collection (water quality meters) and sample collections for laboratory analysis. Spot locations in upstream reach above influence of headpond; in stream channel in diversion reach upstream and above influence of tailrace; at double bridges and downstream of tailrace return water. Varies by parameter. Varies by parameter. One (1) site in each sample area, three (3) per sampling event. Semi-annually Pre-construction: during typical flows of each season; post-construction: low flow periods near the beginning and end of the growing season Select sites avoiding sites immediately downstream of significant local inflow BACI: normalize data and use or use bootstrapping tests of difference between groups (rotating comparisons) if data normalization tests
Criteria Location Duration Methods Sample area
Units Sensitivity/accuracy Sample no. Frequency Timing Measure constraints Analytical test
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Table 3. Objective Description Criteria Location Duration Methods Sample area Units Sensitivity/accuracy Sample no. Frequency Timing Measure constraints Analytical test
Water temperature To assess whether water temperature changes in the diversion reach due to the diversion of water during operations. Temperature. Pre-construction (2 years) maximum, minimum and mean in critical periods. Headpond, diversion reach, at powerhouse/tailrace, double bridges (downstream of tailrace), new fish compensatory habitat areas. Two (2) year pre-construction baseline and five (5) year post-construction. Continuous temperature recorders (may be incorporated with water level sensors) Fixed locations in headpond, diversion reach, powerhouse/tailrace, double bridges (downstream of tailrace), in new fish compensatory habitat areas. Degrees Celsius. +/- 0.1 deg. C One (1) sensor in each location. Hourly. Continuous (15 minutes with incorporated water level sensor; 2 hours for standalone sensor). Select site away from temperature edge effects; avoid sites that dewater in low flow. BACI: express in appropriate format for issues. For fish rearing: degree days in growing season, days >18, >20, <1.
Fish abundance and biomass density To test whether fish abundance decreases in the diversion reach during operations. Number of fish by species and life stage per unit area; body weight and fork length of all fish captured; scale samples of adult fish; area of sampling; usability of habitat; temperature and conductivity. Pre-construction (2 years) mean. Upstream of headpond (control); headpond, diversion reach at Mile 25 Bridge, diversion reach in Ashlu Canyon, diversion reach below cascade in Ashlu Canyon (impact). Two (2) year pre-construction baseline and five (5) year post-construction mean. (a) Gee Traps; (b) angling; (c) snorkelling; (d) electrofishing; (e) on-site measurement of fork length and weight; (f) scale collection; (g) lab analysis of age; photo documentation of site; measure depth, velocity and substrate in enclosure to quantify usability (see Hatfield and Lewis 2007). 2 2 Minimum 100 m per site: greater area required if fish density <0.1 fish/m . no. fish/m2; g/m2 +/- 0.1 g 10 total; five (5) in control reach; five (5) in each section of impact reach. Annually. Late growing season (August to October). Conduct when flows are between 10 and 20% MAD; water clarity >30 cm; and water temperature >= 7 deg. C; release all fish unharmed; standardize effort by area and intensity; measure habitat usability to standardize areal unit measure. BACI: normalize data and use ANOVA or use bootstrapping tests of difference between groups (rotating comparisons) if data fail normalization tests.
Criteria Location
Duration Methods
Sample area Units Sensitivity/accuracy Sample no. Frequency Timing Measure constraints Analytical test
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Table 5. Objective Description Criteria Location Duration Methods
Invertebrate abundance and biomass density To test whether invertebrates decrease in the diversion reach during operations. Number and biomass of invertebrates by per unit flow; diversity. Pre-construction (minimum 1 year) mean. Upstream of headpond (control); diversion reach at gravel bar in Ashlu canyon and at double bridges (impact). Minimum one (1) year pre-construction baseline and one (1) year post-construction. (a) drift net samples fish for hours; (b) taxamonic id to genera or family; (c) photo documentation of site; (d) measure depth and velocity and discharge to quantify flow (see Hatfield and Lewis 2007). Drift net sampler (30 cm x 30 cm mouth, 100 cm length); 250 m mesh. No. and biomass of invertebrates per # of taxamonic. +/- 1 Three (3) in total; two (2) in control reach and one (1) in impact reach At least once per year in the growing season (May to September); twice preferred, if practical, and separated by one month. Under base flow conditions in the rainbow trout growing season. Conduct when flows are between 10 and 20% MAD; water m3/s; and water temperature traps placed in downstream half of riffles. BACI: normalize data and use or use bootstrapping tests of difference between groups (rotating comparisons) if data fail normalization tests. Compensation fish habitat efficacy To evaluate the performance of compensation habitats in compensating for lost habitat, and the effectiveness of migration. Measurement of habitat dimensions, evaluation of habitat quality through physical parameter measurements (stability, erosion), and monitoring of water level and temperature. Confirmation of fish use of compensation habitats through juvenile and adult fish observations. Examine fish ladder annually and comment on condition and apparent efficacy using fish abundance data for inference. Should habitat characteristics change such that habitat suitability is reduced, the compensation habitats will be restored as necessary. Intake (fish ladder) and compensation habitat on Ashlu delta. Up to five (5) years post-construction. Evaluation will be done by observation of fish presence/absence. Water temperature and level measurements will generally follow the guidance in Tables 1 and 3. Fish ladder and compensation habitat.
2 2 2 no. fish/ m ; g/m , deg. C, m , water level in mm
Criteria Location Duration Methods Sample area Units Sensitivity/accuracy Sample no. Frequency Timing
+/- 0.1 g; +/- 0.1 deg. C, +/- 2 mm (water level) Two (2) samples of fish abundance in compensation habitat; single survey of fish ladder use. Fish abundance and density annually; physical characteristics when the compensation habitat is completed, after one (1) and five (5) years of operation Year round for temperature and level for compensatory habitat only; fish observations in late growing season for coho salmon (August to October) for compensatory habitat; fish observations in rainbow trout migration season (April/May). Conduct when flows are between 10 and 20%, water clarity >30 cm; and water temperature release all fish unharmed; standardize effort by area and intensity; measure habitat usability to standardize areal unit measure. BACI design or variant: integrate with impact and control measures taken in other areas.
Measure constraints Analytical test
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Table 7. Objective
Description Criteria Location Duration Methods Sample area Units Sensitivity/accuracy Sample no. Frequency Timing Measure constraints Analytical test
Stream channel morphology To assess project impacts on channel stability and sediment conditions during operations in the headpond area, the diversion reach, and downstream of the powerhouse/tailrace Substrate surveys through transect surveys; photo transect survey points. Pre-construction and post-construction, following 1:10 year flood event or for five (5) years, whichever comes first. Headpond; in the diversion reach at the gravel bar in Ashlu canyon; at the double bridges. Pre-operational and after 1:10 year flood event or after five years, whichever comes first. Transect surveys in diversion and downstream reaches; bathometry topographical survey in the headpond. n/a n/a n/a Detailed transect survey: one (1) transect in diversion reach and one (1) at double bridges; bathymetry survey at headpond. Once pre-project, once after 1:10 year flood event or after 5 years, whichever comes first. Post-freshet: transects after large flood event (1:10 year flood). n/a n/a
Instream Flow Requirement To ensure compliance with the specified instream flow requirement. Water level pressure sensors and manual flow discharge measurements. 2.42 m3/s year round or 16 m3/s to 32 m3/s if pre-booked during 4 weekends in May and 8 weekends in August and September. Approximately 250m downstream of the intake structure Life of the project. Continuous pressure transducer n/a cm staff gauges; m3/s - discharge +/- 2 mm for pressure transducers. To calibrate pressure sensors, minimum of three (3) discharge measurements (20+ vertical stream measurement slices) per transect; for headpond sensors. 15 minute scan and one (1) hour log for stream flow sensors. Continuous. For pressure transducers, select location on stream with adequate protection from debris for the standpipe; avoid placing transducer downstream of major local inflow, and avoid sites that dewater in low flow. n/a
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Flow Ramping Assess the efficacy of prescribed ramping rates. Monitor ramping rates, survey for fish stranding. 15 m3/s per hour proposed rate when fry and juvenile fish are present. In diversion reach: immediately downstream of the intake/weir; the gravel bar and side channel in Ashlu canyon; downstream of diversion reach at double bridges. During project commencement to establish ramping rates. Ramp down and measure the resulting water level change in sensitive habitats in diversion reach and below diversion reach; observe sensitive habitats for fish stranding. Spot locations in sensitive habitats in diversion reach and below diversion reach. m3/s per hour (or equivalent cm/hr); number of stranded fish. +/- 2 mm Variable. During project commissioning. When fry and juvenile fish are present; if a project is commissioned when fry and juveniles are not present (January to May), an additional test will be made when flows are below design flow levels and when fry and juveniles are present (worst case conditions). n/a n/a
Sample area Units Sensitivity/accuracy Sample no. Frequency Timing
Footprint impact verification Quantify as-built footprint impact areas and characteristics. Measure extent and magnitude of impact of project structures on instream and within riparian zones. Ground measures and characteristics laid out in impact assessment reports. Intake, weir, powerhouse, tailrace, switchyard, access roads, transmission line. One time measurement following project construction. Measurements on the ground and/or from aerial photos based of the overlap of project structures and work areas: evaluation of magnitude of effect based on impact assessment criteria. Document instream bed characteristics and riparian condition. Document success of re-vegetation and replant areas. Ground measurement of impacted riparian or instream areas, supported with length and width measurements of individual sites. m2 +/- 10% n/a One time measurement. One year after construction, when mitigation of disturbed areas has been completed. n/a n/a
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From: Sent: To: Cc: Subject: Attachments: Babakaiff, Scott C ENV:EX Wednesday, April 14, 2010 10:40 AM 'Knight, Francesca'; 'Busto, Vince' Bennett, Timothy A ENV:EX; Stoddard, Erin M ENV:EX FW: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management Plan, Revision C image001.jpg; Ashlu OEMP Rev C 18-March-2010.pdf; 2010-03-18 Ashlu ltr RK to TB OEMP RevC.pdf
Wow, I hadnt noticed that you & Vince were not provided copies of Revision C. It seems that the proponent has not got the message that the monitoring plan will be referenced by both MOE & DFO. There is alot in Revision C that will benefit from your review...as you can see from my review, I did not address Water Quality or macroinvert stuff, and I dont believe anyone else from MOE will be providing that input. Erin will be providing review of the fish stuff shortly. Scott
From: Knight, Francesca [mailto:Francesca.Knight@dfo-mpo.gc.ca] Sent: Wednesday, April 14, 2010 10:33 AM To: Babakaiff, Scott C ENV:EX Subject: RE: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management Plan, Revision C Hey Scott, I was planning on writing my comments this week; could you send me revision C please...looks like my latest is revision B, thanks! C
Francesca Knight, M.Sc., R.P.Bio. Habitat Biologist Fisheries and Oceans Canada / Pches et Ocans Canada Oceans, Habitat and Enhancement Branch / Direction des ocans, de l'habitat et de la mise valeur Lower Fraser River - Le Bas Fraser Unit 3 - 100 Annacis Parkway Delta, BC V3M 6A2 Francesca.Knight@dfo-mpo.gc.ca Ph: (604) 666-3191 / Fax: (604) 666-6627 Government of Canada - Gouvernement du Canada
From: Robert Kulka [mailto:RKulka@innergex.com] Sent: Thursday, March 18, 2010 4:41 PM To: Bennett, Timothy A ENV:EX Cc: Babakaiff, Scott C ENV:EX; gsteeves@ameresco.com; Richard Blanchet; Kelly Boychuk; Bill Johnson Subject: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management Plan, Revision C
HelloTim, AttachedisRevisionCoftheOEMP.AlsoattachedisacoverletteroutliningthehistoryoftheOEMP,ourre applicationforLTCOperation,andcurrentstatusoftheproject(shutdownfortunnelrepairs).Asealedandsigned copyoftheOEMPwillbesentpermailtoyouearlynextweek. Pleasecontactmeifyouhaveanyquestions.Regards,

1
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Robert
________________________________________
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
Page 187 FNR-2011-00265/ Part 1
ASHLU CREEK HYDROELECTRIC PROJECT
AQUATIC ENVIRONMENT OPERATIONS ENVIRONMENTAL MONITORING PLAN
Prepared for Ashlu Creek Investments Limited Partnership North Vancouver, BC
Prepared by Focus Environmental Inc. Sidney, BC
Submitted to Ministry of Environment, Surrey, BC Fisheries and Oceans Canada, Surrey BC
March 2010
March 2010 Page 188 FNR-2011-00265/ Part 1
Focus Environmental Inc.
Ashlu Creek Hydro Project Operations Environmental Monitoring Plan
TABLE OF CONTENTS
1.0 1.1 1.2 1.3 2.0 INTRODUCTION ......................................................................................................................... 4 BACKGROUND.............................................................................................................................. 4 AVAILABLE BACKGROUND INFORMATION .................................................................................. 4 PURPOSE OF THE OEMP .............................................................................................................. 5 PROJECT OVERVIEW ............................................................................................................... 6
2.1 HEADWORKS ................................................................................................................................ 6 2.1.1 Intake....................................................................................................................................... 6 2.1.2 Sluiceway................................................................................................................................. 6 2.1.3 Rockfill Weir............................................................................................................................ 7 2.1.4 Spillway ................................................................................................................................... 7 2.2 WATER CONVEYANCE SYSTEM ................................................................................................... 7 2.3 POWERHOUSE, TAILRACE, AND SWITCHYARD ............................................................................ 7 2.4 ENERGY DISSIPATION SYSTEM .................................................................................................... 8 2.5 TRANSMISSION LINE AND INTERCONNECTION ............................................................................ 8 2.6 ACCESS ROAD .............................................................................................................................. 8 2.7 PLANT OPERATIONS .................................................................................................................... 9 2.7.1 Operators ................................................................................................................................ 9 2.8 INSTREAM FLOW REQUIREMENT DELIVERY ............................................................................... 9 3.0 3.1 3.2 3.3 4.0 SUMMARY OF POTENTIAL EFFECTS ................................................................................ 10 POTENTIAL EFFECTS .................................................................................................................. 10 MITIGATION MEASURES ............................................................................................................ 10 RESIDUAL EFFECTS.................................................................................................................... 11 REGULATORY FRAMEWORK .............................................................................................. 13
4.1 PROVINCIAL REQUIREMENTS .................................................................................................... 13 4.2 FEDERAL REQUIREMENTS ......................................................................................................... 13 4.2.1 Department of Fisheries and Oceans Canada ...................................................................... 14 4.2.2 Transport Canada ................................................................................................................. 14 5.0 PROPOSED MONITORING PROGRAM ............................................................................... 15 5.1 WATER LEVELS, TEMPERATURES, AND FLOWS ........................................................................ 19 5.1.1 Baseline Information ............................................................................................................. 19 5.1.2 Proposed Monitoring Activities ............................................................................................ 19 5.1.2.1 Monitoring Sites ........................................................................................................... 20 5.1.2.2 Methods and Data Analysis.......................................................................................... 20 5.1.3 Reporting............................................................................................................................... 21 5.2 WATER QUALITY ....................................................................................................................... 22 5.2.1 Baseline Information ............................................................................................................. 22 5.2.2 Proposed Monitoring Activities ............................................................................................ 22 5.2.2.1 Monitoring Sites ........................................................................................................... 23 5.2.2.2 Methods and Data Analysis.......................................................................................... 23 5.2.3 Reporting............................................................................................................................... 24 5.3 FISH HABITAT ............................................................................................................................ 25
5.3.1 Baseline Information ............................................................................................................. 25 5.3.2 Proposed Monitoring Activities ............................................................................................ 26 5.3.2.1 Monitoring Sites ........................................................................................................... 26 5.3.2.2 Methods and Data Analysis.......................................................................................... 27 5.3.3 Reporting............................................................................................................................... 27 5.4 FISH COMMUNITY ...................................................................................................................... 28 5.4.1 Baseline Information ............................................................................................................. 28 5.4.2 Proposed Monitoring Activities ............................................................................................ 29 5.4.2.1 Monitoring Sites ........................................................................................................... 29 5.4.2.2 Methods and Data Analysis.......................................................................................... 30 5.4.3 Reporting............................................................................................................................... 31 5.5 AQUATIC INSECTS...................................................................................................................... 32 5.5.1 Baseline Information ............................................................................................................. 32 5.5.2 Proposed Monitoring Activities ............................................................................................ 32 5.5.2.1 Monitoring Sites ........................................................................................................... 33 5.5.2.1.1 Drift Sample Sites ................................................................................................... 33 5.5.2.1.2 Benthic Community Sample Sites........................................................................... 33 5.5.2.2 Methods and Data Analysis.......................................................................................... 34 5.5.2.2.1 Drift ......................................................................................................................... 34 5.5.2.2.2 Benthic Community Methods and Analysis............................................................ 35 5.5.3 Reporting............................................................................................................................... 35 5.6 GEOMORPHOLOGY ..................................................................................................................... 36 5.6.1 Baseline Information ............................................................................................................. 36 5.6.2 Proposed Monitoring Program............................................................................................. 36 5.6.2.1 Monitoring Sites ........................................................................................................... 37 5.6.2.2 Methods and Data Analysis.......................................................................................... 37 5.6.3 Reporting............................................................................................................................... 37 5.7 MITIGATION AND COMPENSATION WORKS ............................................................................... 38 5.7.1 Baseline Information ............................................................................................................. 38 5.7.2 Proposed Monitoring Activities ............................................................................................ 38 5.7.2.1 Fishway ........................................................................................................................ 38 5.7.2.2 Fish Compensation Channel......................................................................................... 38 5.7.3 Reporting............................................................................................................................... 39 6.0 6.1 6.2 7.0 7.1 7.2 8.0 IMPLEMENTATION AND REPORTING............................................................................... 40 MONITORING PROGRAM IMPLEMENTATION .............................................................................. 40 ANNUAL AND FINAL REPORTING .............................................................................................. 40 ASSESSMENT OF EFFECTS.................................................................................................... 42 ASSESSING RESULTS OF MONITORING ACTIVITIES ................................................................... 42 ESTABLISHING THRESHOLDS ..................................................................................................... 42 REFERENCES............................................................................................................................. 43
LIST OF TABLES
Table 1 Summary of Riparian and Instream Habitat Loss Areas from Sigma 2004.................................. 11 Table 2 Water Levels, Temperature, and Flows ........................................................................................ 21 Table 3 Water Quality Monitoring............................................................................................................. 24 Table 4 Fish Habitat Monitoring................................................................................................................. 27 Table 5 Fish Community Monitoring ........................................................................................................ 31 Table 6 Aquatic Insects Monitoring........................................................................................................... 35 Table 7 Channel Morphology Monitoring ................................................................................................. 37 Table 8 Fishway and Compensation Channel............................................................................................ 39 Table 9 Summary of Monitoring Components .......................................................................................... 41
LIST OF FIGURES
Figure 1 Power Project - Monitoring Site Locations ................................................................................. 18
1.0 INTRODUCTION
1.1 Background
Ashlu Creek Investments Limited Partnership (ACILP) completed construction and testing of the Ashlu Creek Hydroelectric Project (Project) in late 2009. Project operations and delivery of electrical energy was contingent upon successful completion of an Operations Environmental Monitoring Plan (OEMP) by March 15, 2010. In February 2010, the tunnel and penstock were inspected to assess any potential integrity issues in the tunnel, which delayed final commissioning and the start of operations until later in March 2010. A draft (Revision A) of the Five Year, Post-Construction Aquatic Monitoring Program Revision A submitted to Fisheries and Oceans Canada (DFO) in May 2009. A follow-up letter was sent to DFO in October 2009 with description of the specific plan to confirm ramping rates during plant commissioning. On December 18, 2009, ACILP received comments from the British Columbia (B.C.) Ministry of Environment (MOE), Water Stewardship Division (WSD), requesting ACILP to retain the services of a registered professional biologist and revise the OEMP as indicated by their comments. The ACILP retained Focus Environmental Inc (Focus) to review existing background information and revise the OEMP to capture both regulatory compliance and effects based monitoring components. Focus was given a tour of the site on March 9, 2010. The plan was shut down at the time of the site tour and flows in Ashlu Creek were relatively low and clear. The site tour was beneficial as it provided a good overview of site access and viability of sampling conditions during operations. 1.2 Available Background Information
The primary aquatic baseline and assessment information was collected by Sigma Engineering Ltd (Sigma) from 2001 through 2004, reported in Sigma (2002 and 2004a), and a habitat balance report compiled by Sigma (2004b). A vegetation and wildlife assessment was compiled by Dunster & Associates Environmental Consultants Ltd (Dunster) in September 2001 (Dunster, 2001). Additional wildlife addendums were prepared by Sigma in 2003 and 2004, which in addition to vegetation and wildlife included amphibians. An Environmental Assessment Addendum for the Project compiled by TRC Biological Ltd. (TRC) in 2005 (TRC, 2005) provided information on invertebrate and water quality sampling as well as wildlife sightings. Water quality monitoring was reported in TRC (unpublished) during the construction phase and potential for Acid Rock Drainage (ARD) and metals leachate from tunnel water and waste rock was reported in Mesch Engineering (2008). Regulatory information and compliance requirements were outlined in the following documents: Conditional Water License No. 102203 (CWL) issued by B.C. Ministry of Environment (MOE), Water Stewardship Division (WSD); Canadian Environmental Assessment Act (CEAA) Screening Report prepared by Fisheries and Oceans Canada (DFO) issued by DFO, 2004)
DFO Authorization No. 04-HPAC-PA2-000-000530 (Authorization) under Section 32 and 35(2) of the Fisheries Act issued on July 31, 2006; and, Approval under Section 5(1) of the Navigable Water Protection Act (NWPA) issued on June 21, 2006
1.3
Purpose of the OEMP
The overall goal of ACILP is to minimize effects on aquatic resource values over the life of the facility. The OEMP is a key document in the regulatory process with the objective of monitoring for compliance with sufficient scientific rigor in approach and implementation to assess the actual effects of the Project, taking into account external influences not associated with the Project. The OEMP will be implemented during the operations phase. The OEMP outlines the technical methods to be used for data collection, analysis, and presentation to the Regional Water Manager, under requirements of the CWL dated July 31, 2006, and to DFO under requirements of the DFO Authorization. The post-construction monitoring period, as described in the Fisheries Authorization, is five (5) years from the date of commercial operation of the Project, which is anticipated to be the period from March 2010 to December 2014.
2.0 PROJECT OVERVIEW

The Project is a 49 MW run-of-river hydroelectric generating facility with a total head of 224 m and a generating capacity of 230 GWh per year. The Project is located approximately 20 km northwest of the Town of Squamish. The main components of the Project include headworks, tunnel, powerhouse/tailrace/switchyard, and an overhead 230 kV transmission line. Each of these components is described in the following sections. 2.1 Headworks
Water is diverted from Ashlu Creek at the headworks structure consisting of the intake, sluiceway, rockfill weir, and spillway. Communication between the powerhouse and intake and the power supply to the intake is provided by cables which are embedded in the Forest Service Road between the powerhouse and the intake. A radio system with a repeater station at the Mile 25 bridge location provides redundancy for communication if for any reason the fiber optic cable is not functioning. 2.1.1 Intake
The intake is a concrete structure that is located on the south side of the overall intake/diversion structure that spans Ashlu Creek. The intake diverts water from the head pond into the vertical tunnel shaft, the horizontal tunnel, the penstock, the distribution pipe and finally to the powerhouse. The conveyance system is designed for the maximum licensed flow of 29 m/s. Coarse and fine trash racks prevent debris from entering the tunnel shaft. The elevation of the intake inlet sill at the invert of the coarse trash rack is 272.0 m. A gate is installed between the fine trash rack and the tunnel shaft. The intake gate is open during normal operation. The gate is closed during head pond and tunnel/penstock filling and draining and in emergency situations that require a complete shut down of flows from the intake. Such an emergency situation could occur during a load rejection condition at least one of the Turbine Inlet Valves or at least one of the Energy Dissipation System (EDS) bypass valves fail to operate as intended and a complete depressurization of the water conveyance system is required. The intake gate contains within itself a small 600 mm butterfly valve, which acts as a bypass to the intake gate for the purpose of the, controlled filling of the water conveyance system. 2.1.2 Sluiceway
The sluiceway is a 7 meter wide concrete channel that extends from the headpond to the downstream side of the weir/intake structures. The left (south) abutment wall of the sluiceway upstream of the sluicegate contains the intake opening with the coarse trash rack. The sluiceways purpose is to flush sediment that may accumulate in the headpond in front of the intake inlet and to manage flows in excess of the intakes flow capacity (i.e. greater than 29 m/s). The sluiceways design capacity is 150 m/s, but it is intended to operate the sluiceway only to 70 m/s. The base elevation of the sluiceway channel inlet is 270.5 m. The flow through the sluiceway is controlled by the vertical sluiceway gate, located approximately mid-way along the sluiceway channel. The sluiceway gate is operated through a hydraulic power unit located near the sluiceway gate. The operation of the gate is controlled by a local automated system located in the intake control building atop of the rockfill weir.
2.1.3
Rockfill Weir
The rockfill weir extends 55 m between the sluiceway channel and the bypass spillway. The weir has an impermeable glacial till core with a series of increasing coarse filter layers and a final armored layer of rip rap. There is an upstream liner blanket keyed into the impermeable core which extends up into the headpond. The overall design of the intake weir with the midstream rock fill weir allows the effective management of sediments under both average and high flow events. The weir crest elevation is 279.0m. 2.1.4 Spillway
The spillway is a 35 meter wide channel cut into natural rock on the left bank of Ashlu Creek across from the intake and sluiceway. The spillways primary purpose is to pass flows that are in excess of the combined intake and sluiceway flow capacity (i.e. greater than 29 m/s + 70 m/s). Flow through the spillway is controlled by a 5.5 m high, Obermeyer weir that is comprised of five steel plate flap gate sections which in turn are raised by five inflatable rubber bladders. To provide enhanced control, the Obermeyer weir and gates are divided into two sections: one gate panel (referred to as Section 1) and a section comprised of four gate panels (referred to as Section 2/5). The elevation of the fully deflated (open) bladder and gates is elevation 271.0 m; the elevation of the fully inflated (closed) bladder and gates is 276.5 m, for a total height of 5.5 m for the fully inflated weir. The flow capacity of the spillway with fully deflated Obermeyer gate is 918 m/s. The flow capacity of the spillway with Section 1 deflated and Section 2/5 inflated is 184 m/s (20% of full capacity). 2.2 Water Conveyance System
The water conveyance system consists of a 115 m vertical shaft, 4,442 m horizontal tunnel, and 160 m long penstock. The vertical shaft commences at the intake structure and transitions into the horizontal tunnel through a blasted chamber (commonly referred to as "boot"). The chamber is approximately 7.0 m wide and 8.0 m long. This enlarged cross section results in a reduced velocity of the flow through the chamber and reduced head losses due to the nearly 90 degree deflection of the flow. The tunnel commences at an average slope of 1.5% downwards towards the tunnel portal. A concrete plug is installed approximately 180 m upstream of the tunnel portal. The tunnel from the portal to the plug is lined with a 2.8 m diameter steel pipe which is sealed into the tunnel plug. The tunnel liner is welded to the steel penstock just outside the tunnel portal. The penstock is then buried and it passes under the Forest Service Road before following more or less the natural slope from the road down to the powerhouse. Three concrete thrust blocks are installed at each of the penstock alignment changes. The total volume of the system, when filled with water, is approximately 62,000 m. The total gross head from the full headpond level to the tail race water level at the powerhouse is 224 meters (276.0 to 52.0m). 2.3 Powerhouse, Tailrace, and Switchyard
The powerhouse building is a pre-engineered steel clad building with the overall footprint of 55.0 m by 14.5 m and an eave height of 13 m (55 masl to 68 masl) and contains three horizontal-shaft Francis turbines, each with a rated output of 16.5 MW. Each turbine is directly coupled to a synchronous generator. Within the powerhouse and 80 ton gantry crane, the ancillary equipment for the turbine generators, and the mechanical and electrical station services, including lighting, heating, ventilation and the back up
generator. The hydraulic power units and generator bearings use fully biodegradable oils. All floor drains are connected to an oil-water separator system. The building also includes a security and fire alarm system tied into the plants control system. The tailrace is 55 m wide x 12 m long between the powerhouse and the tailrace weir. The diverted water flows back into the creek over the low profile tailrace weir on the creek side of the tail race. Three draft tube gates allow isolation of the individual turbines from the tailrace in order to service the turbines without draining the tail race and allowing the other two units to operate while one unit is isolated for inspection, service or repair. The switchyard is located approximately 20 meters adjacent to the powerhouse. It houses the main power step up transformer, circuit breaker, secondary revenue metering. The switchyard is equipped with a ground grid and perimeter security fencing. An oil-water separator is installed between switchyard and powerhouse and connected to the outlet of the main transformer perimeter drain. 2.4 Energy Dissipation System
The EDS is housed within the powerhouse structure. It consists of a set of six 30 inch ball valves that are connected to the penstock by an extension of the header pipes past the turbine branches. The valves in turn are connected to vertical pipes that end in dissipation baskets located in the dissipation chamber beneath the valve room. The EDS is capable of diverting and dissipating the full licensed flow of 29.0 m/s or 4.83 m/s per branch. The ball valves are capable of fully opening and closing within 30 seconds which is approximately the same time for the TIVs to close under a load rejection trip (see section 3.6.2). The valves are not designed for gradual increase and decrease of flows, mainly due to expected cavitation under partially opened condition. In order to allow controlled gradual incremental changes of flows through the EDS, two of the six dissipation baskets are equipped with adjustable sleeve valves (adjustable EDS valves). The adjustable sleeves can be operated at minimum increments of 1% of branch flow or 0.048 m/s per step. 2.5 Transmission Line and Interconnection
The 230 kV overhead transmission line is a 3 phase unshielded 795 kcmil ACSR 26/7 Drake conductor mounted on timber poles with a total length of 3.2 km. From the Ashlu switchyard, the transmission line follows the Ashlu Forest Service Road (FSR) for its entire length, spanning over Ashlu Creek approximately 600 m downstream of the powerhouse. The line connects to the Point of Interconnection (POI) to a 500 m long spur tap line constructed by BCTC. The tap line connects to BCTC's 2L12 transmission line which subsequently connects to BCTCs Cheekye substation near Squamish. 2.6 Access Road
General access to the site is provided by the Ashlu FSR. Access to the switchyard and powerhouse site is provided through a new 200 meter long all-weather spur road branching off the Ashlu FSR. Access to the intake site is provided through a 400 meter all-weather long spur road branching off the FSR in the upper reaches of the Ashlu Creek valley. Both roads are gated to control public access to the sites.
2.7 2.7.1
Plant Operations Operators
During plant operations, there will be minimal activity at the Project site except periodically during extensive maintenance activities. Operations staff will consist of a minimum of two operators. One or, possibly, both operators will conduct daily trips to the Project site to collect data and inspect facilities, operating equipment (turbines, generators), and energy production. Annual maintenance will be required, but generally takes place during low flow periods when the plant is not producing energy to minimize losses in revenue. Once construction is complete, all temporary roads built to access the line right of way will be decommissioned or vehicle access will be blocked. Transmission line operations will require periodic inspection and maintenance, which may require recommissioning the temporary access roads within the transmission line right-of-way, depending upon maintenance requirements. 2.8 Instream Flow Requirement Delivery
The primary hydrometric gauge for Instream Flow Requirement (IFR) measurement is at the first suitable location approximately 250 m downstream of the intake. The channel is in a transition from a relatively flat, braided, gravel and boulder channel into a bedrock canyon. The hydrometric station consists of a pressure transducer (water level sensor) connected to the intake control building by a tech-cable suitable for burial. The sensor was tied into a benchmark in November 2009 following calibration of the 2.42 m/s IFR required under the DFO Authorization. The benchmark serves as a visual reference to calibrate the level probe. Water levels are measured on a continuous basis and relayed to the powerhouse control system in real time. A hydrometric station with water level sensor and data logger was installed approximately 800 m downstream of the intake at the Mile 25 bridge during the review and planning phase of development. This station has been monitored on a regular basis and has a proven stage-discharge curve. The station also provides flow data and houses a kayaker warning system as required by Transport Canada (TC) Navigable Waters Protection Division (NWPD). Approximately 10% of the flows measured at this location are contributed to a small tributary between intake and this location. Therefore, the IFR immediately downstream of the intake is approximately 90% of the flow measured at this location. ACILP is interested in continuing operation of the hydrometric station located 250 m downstream of the intake and transferring its obligations to NWPD, regarding on-line water levels/flows, from the Mile 25 bridge station to this one. The primary reason for this is the fact that the data recorded at the upper station is wired directly into the control system, as opposed to the Mile 25 bridge station, which is not. The mile 25 bridge station should be maintained during the first year of operation to provide backup data and support calibration of the new station located 250 m downstream of the intake.
3.0 SUMMARY OF POTENTIAL EFFECTS

Sigma Engineering Ltd (Sigma) conducted baseline studies, assessed the potential effects of the Project on the aquatic environment, and identified measures, either through design, construction methods and operational management that would mitigate those effects (see Sigma 2002, 2004a, and 2004b). 3.1 Potential Effects
The potential effects of Project development on the aquatic environment identified in Sigma (2004) and in the CEAA Screening Report include: Alteration or loss of habitat due to instream footprint of the intake structure and powerhouse tailrace; Loss and alteration of riparian vegetation cover at the intake, tunnel, powerhouse, tailrace, switchyard, and at overhead transmission line stream crossings; Loss of habitat due to diversion of flow in the diversion reach for power generation; Fish survival at the intake (injury or mortality of fish due to impingement and entrainment); Fish Passage (blockage of upstream fish movement) at the intake; Alteration of habitat in the headpond; Reduction of water quality due to temperature increases in summer, anchor ice formation in winter, increase in gas super-saturation or total gas pressure (TGP), the introduction of deleterious and/or toxic substances, erosion and sediment deposition, metals leachate, and acid rock drainage; Alteration of habitat in the diversion reach caused by trapping large woody debris in the headpond; Changes to channel morphology due to trapping of sediment and bed material in the headpond; and, Habitat loss and mortality of fish due to inappropriate flow ramping during a plant shut down or start-up event.
3.2
Mitigation Measures
Many of the potential effects of Project development were mitigated during the construction phase. Other mitigation measures implemented included the construction of a fishway at the intake. Also, ramping rates were assessed during plant commissioning and have been set for plant shut down during operations.
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3.3
Residual Effects
Residual effects encompass those effects that are not able to be mitigated either through design, layout, construction methods, and operational procedures. The residual effects on the aquatic environment following mitigation, based on preliminary design of the Project are summarized from Sigma (2004b) in Table 1 below.
Table 1 Summary of Riparian and Instream Habitat Loss Areas from Sigma 2004
Project Component Intake Tunnel Powerhouse Tailrace Culverts Transmission Line Totals Riparian Loss Area (m2) 1,860 0 600 0 2,700 5160 Instream Habitat Loss Area (m2) 1,095 0 600 (30) 0 1,665 Total (m2) 2,955 0 1,200 (30) 2,700 6,825
Residual effects have been compensated for based on the habitat balance presented in Table 1 (Sigma 2004b). Compensation for the loss of instream and riparian habitat has been implemented by constructing an extension to the existing salmon spawning and rearing channel in the alluvial fan adjacent to Reach 1. The compensatory habitat will be deemed to be successful if, after a period of five years, the constructed habitat is physically stable, maintains a suitable flow, and has been demonstrated to provide rearing habitat for Coho salmon or rainbow trout (steelhead).
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4.0 REGULATORY FRAMEWORK

4.1 Provincial Requirements
In July 2006, the Regional Water Manager with the B.C. Ministry of Environment (MOE), Water License Division (WSD) issued the CWL. Conditions of the CWL relevant to the OEMP include: Maximum quantity of water which may be diverted and used under the licence is 29.00 m3/s; Water may be diverted and used throughout the whole year subject to the requirements of a minimum In-stream Flow Release (IFR) directly below the intake structure; The licensee must operate the works authorized in accordance with an order of the Regional Water Manager that; o o o o o Sets the value for the parameter of minimum IFR, Requires a monitoring program suitable to determine the nature of any impacts of the project on fish and wildlife, Requires a monitoring program to evaluate the effect of the regulation of works set by the IFR, Outlines all requirements that need to be met by the licensee prior to commencing construction and operation, and Requires disclosure of how the works will operate.
4.2
Federal Requirements
In conducting the Scoping exercise or principle project/accessory test, under the Canadian Environmental Assessment Act (CEAA), the Canadian Environmental Assessment Agency (CEA Agency) determined the principle project encompassed the construction, operation and maintenance of the Project including; the weir, intake, headworks, tunnel diversion, penstocks, power plant, tailrace, transmission lines, and associated roadworks and staging/laydown areas. The Responsible Authorities identified by the CEA Agency were Fisheries and Oceans Canada (DFO) related to approval under sections 32 and 35(2) of the Federal Fisheries Act, and Transport Canada (TC) related to approval under section 5(1) of the Navigable Waters Protection Act (NWPA). The Project triggered a Screening level of review under CEAA. Preparation of the Screening Report was delegated to the Major Projects Review Unit of DFO. The Screening Report assessed the potential effects, mitigation measures, residual effects, and cumulative effects resulting from the Project and concluded the Project would not cause significant adverse environmental effects, which allowed DFO to issue a Section 32 and 35(2) Fisheries Act
Ashlu Creek Investments Ltd. Partnership
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Authorization and NWPD to issue an Approval under Section 5(1) of the NWPA. For the Project to proceed, ACILP would be required to operate in compliance with the Federal Fisheries Act and the NWPA and to monitor specified environmental and operational parameters in accordance with a Section 32 and 35(2) Fisheries Act Authorization. Further, the ACILP would also be required to adhere to specific mitigation measures provided by NWPD, Environment Canada, and the Canadian Wildlife Service. 4.2.1 Department of Fisheries and Oceans Canada
In July 2006, the DFO issued Authorization #04-HPCA-PA2-000-000530 (Authorization). During operations, the aquatic environment monitoring requirements were identified in the following sections of the Authorization: (c) Conditions That Relate to Flow Release in numbers 1, 2, and 3 of the Authorization; (d) Description of Compensatory Works in numbers 1, 2, 9, and 15 of the Authorization; (g) Determination that Compensatory Habitat is Functioning as Intended in numbers 1 and 2 of the Authorization.
4.2.2
Transport Canada
Approval #8200-T-10595.2 issued by NWPD requires the IFR to range between 16 m3/s and 32 m3/s during twelve (12) weekends between May and September if flow release is pre-booked by kayakers through an online booking system maintained by ACILP.
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5.0 PROPOSED MONITORING PROGRAM

There are two primary aspects to the monitoring program; one for compliance monitoring and the second related to verifying effects of the Project on the aquatic biological environment. Compliance monitoring will address requirements identified in the CWL, the DFO Authorization, and other applicable permits and licenses. Biotic response monitoring addresses the complexity of the biological response to altered flow conditions. The monitoring program will measure the effect of flow releases on target aquatic resources (i.e. hydrology, fish populations, fish habitat, water quality, and invertebrate abundance) and is designed to verify effects of the Project and predictions made during the review phase. The approach developed by Hatfield et al (2007) for Independent Power Projects (IPPs) in British Columbia follows a quantitative, site effectiveness monitoring approach with a before-after controlimpact (BACI) approach. Under this approach, control sites (i.e. portions of Ashlu Creek or reaches without water withdrawal) are monitored simultaneously with impact sites (i.e. reaches with water withdrawal) for a predetermined period both before and after project implementation. Typically, the control sites are upstream of the Project area, and impact sites are within the diversion reach of the Project. Temporal variation is assessed over two monitoring periods; baseline (prior to operation) and operations over the 5 year monitoring period. Spatial variation is assessed by monitoring control sites and selected sites that are potentially affected by the Project. Biological baseline data provides key information for the project; aquatic species of concern, life history information, and potential limiting factors such as water quality (nutrients, temperature), habitats and streamflow. To reduce the natural variation in Ashlu Creek, time of year and flow range at the time of sampling should be standardized with baseline conditions to the extent possible. As well, field studies will be planned to target a specific flow and/or life history stage rather than aiming solely for a particular calendar date each year. In the case of the Ashlu Project, baseline studies were carried out from 2001 to 2006 by Sigma and TRC Biological Ltd (TRC, 2005) according to B.C. Resource Inventory Standards Committee (RISC) standards, but prior to the Provincial guidelines compiled by Hatfield et al (2007). The proposed aquatic environment monitoring program consists of the following key elements: Water levels, temperature, and flow monitoring; Water quality monitoring; Fish Habitat monitoring Fish Community monitoring; Aquatic Insects monitoring; and, Fish Passage monitoring;
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Compensation works monitoring.
Figure 1 identifies the proposed monitoring site locations for the Project. The key areas where these monitoring components will be performed are described below and are shown on Figure 1. All locations are referenced to the distance along the Ashlu Forest Service Road (Ashlu FSR) originating from the Squamish River bridge. Headpond - The headpond is located approximately 9 km along the Ashlu FSR and is directly upstream of the intake and weir. When the headpond is filled to its normal operating elevation of 276.0 metres, it will extend approximately 400 metres upstream of the intake and weir. Intake and Weir - are located approximately 9 km along the Ashlu FSR and are directly downstream of the headpond. The intake comprises a fixed concrete structure and earthfill dam with sluice and intake gates; the weir comprises a fixed concrete sill and an inflatable, rubber, Obermeyer weir. The fish ladder is located within the intake/weir structures. Mile 25 Bridge - is located approximately 7 km along the Ashlu FSR and crosses Ashlu Creek just upstream of the Ashlu Canyon. The bridge was built by previous logging companies who worked within Tree Farm License 38 area where Ashlu Creek is located. There is a fork in the Ashlu FSR just 100 metres prior to reaching the Mile 25 Bridge, and this fork leads to the intake, weir and headpond areas. Tunnel rock spoil area is located approximately 6.5 km along the Ashlu FSR. The site contains approximately 20,000 m of tunnel muck that was excavated during the construction of the tunnel. The slopes have been graded to stable slopes and the muck has been covered with a layer of topsoil and reseeded. Gravel Bar in the Ashlu Canyon - is located approximately 5.5km along the Ashlu FSR and is not accessible from the road. The area is defined at a widening of the Ashlu Canyon where the flow energy of the stream decreases and forms a large gravel bar. Both upstream and downstream of this location are narrow, bedrock canyons. Mile 23 is located approximately 4.0 km along the Ashlu FSR and is immediately adjacent to the creek, therefore providing safe all year access to the stream. A solar powered radio system as part of the kayak warning system is installed at this location. Powerhouse/Tailrace/Switchyard - powerhouse and tailrace are located approximately 2.8km along the Ashlu FSR. The powerhouse comprises a fixed concrete building with turbines and generators within, and the tailrace comprises a fixed concrete and bedrock pool and overflow sill into Ashlu Creek. The powerhouse and tailrace are located approximately 300 m downstream of the mouth of the narrow Ashlu Canyon. Adjacent to both structures is the electrical switchyard, and slightly uphill is the tunnel portal and adjoining penstock (buried beneath the Ashlu FSR).
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Double Bridges - are located approximately 2.5km along the Ashlu FSR and cross Ashlu Creek in two places. Like the Mile 25 Bridge, these bridges were built by previous logging companies who worked within the Tree Farm License 38 area. The double bridges mark the area where Ashlu Creek changes to a wide, low energy, meandering stream. This location is generally known to be the upstream limit for salmon spawning in Ashlu Creek. Fish Compensatory Habitat - is located approximately 1.5 to 2km along the Ashlu FSR and covers the area to the north and south of the FSR, including along the transmission line right-of-way. This area also connects DFOs small intake and fish habitat ponds and channels that were established in the late 1990s. The fish compensatory habitat comprises a network of narrow, low energy riffles and pools that criss-cross the transmission line right-of-way and enter into the forested area on the Ashlu Creek delta. Transmission Line - begins at the electrical switchyard and extends for approximately 3 km to the BC Hydro switch beside the Squamish River Bridge. The transmission line parallels the Ashlu Forest Service Road and crosses over Ashlu Creek at the double bridges.
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5.1 5.1.1
Water Levels, Temperatures, and Flows Baseline Information
Ashlu Creek rises in the Tantalus Range of the Coast Mountains and flows in a south-easterly direction to its confluence with the Squamish River, approximately 20 km north of the Town of Squamish, B.C. It is a fifth order stream with a length of approximately 34 km and a drainage area of 324 km2. The catchment area of Ashlu Creek at the proposed intake location is 295 km2. Ashlu Creek is a highly dynamic stream characterized by flashy flows and extremes between peak and low flows. Glacial runoff turns Ashlu Creek fairly turbid throughout most of the spring, summer and fall season and the creek does not begin to clear up until later in the fall when air temperatures begin to drop and the glaciers stop melting. ACILP retained Knight Piesold Consultants Ltd (KPC) to compile hydrologic data from other nearby watersheds that do have long term records to produce a 20-year (1982 to 2002) synthetic hydrological record for Ashlu Creek (KPC, 2004). Ashlu Creek has been gauged intermittently since 1991 and consequently longer term flow records were synthesized from data obtained from a nearby Water Survey of Canada (WSC) gauging station on the Elaho River. The watershed is snowmelt dominated with contributions in late summer from glacier melt. The mean annual flow (MAF) in Ashlu Creek at the intake site is estimated to be 27.1 m3/s (KPC, 2004).The lowest mean monthly discharges of 3 m3/s to 5 m3/s occur in winter (December to March), the highest mean monthly discharges of 60 m3/s to 65 m3/s occur in the summer (June and July), with the shoulder months of September and October being more dependent on precipitation and temperature. The drainage area between the intake and powerhouse is approximately 11 km2, which could provide a mean annual flow of 0.92 m3/s.
5.1.2
Proposed Monitoring Activities
The Project will change the flow regime in Ashlu Creek by diverting a portion of flow at the intake, convey the water through a tunnel/penstock, and return the flow to the mainstem at the powerhouse tailrace. Changes to flow regime can change the productive capacity and impact fish survival by increasing temperatures and changing water quality (i.e. lowering dissolved oxygen concentrations), and affecting reproduction by impacting spawning and migratory behavior. Continuous monitoring of flows through the diversion reach is required for compliance with the CWL, DFO Authorization, and approvals from NWPD. Changes to the flow regime during plant shut-down and start-up requires determination of ramping rates to protect fish and fish habitat. During plant commissioning, Cascade Environmental Resource Group Ltd. (Cascade), conducted a study to verify ramping rates, which is reported in Cascade (2009).
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5.1.2.1 Monitoring Sites

The primary objective of water levels and flow monitoring is to verify the delivery of the minimum IFR in the diversion reach for compliance with the DFO Authorization, to monitor ramping rates in the event of a plant shut down, and to monitor and verify that flows are capable of transporting sediment and bed load through the diversion reach and into the lower reaches of Ashlu Creek. Water levels, temperatures, and flows will be monitored at the following hydrometric station sites: WL1 water level and temperature sensors located a short distance downstream of the intake to verify minimum IFR compliance and total flow, which includes flows from the IFR pipe, fish ladder, sluiceway, emergency spillway, seepage under the structures and overflow from the Obermeyer weir. It is ACILPs preference to replace the present Mile 25 bridge station with this one for providing real-time flow for kayakers; WL2 recording water level is not necessary, but it is recommended that a flow measurement be obtained immediately upstream of the powerhouse at the same time calibration flows are taken at WL1 to verify flow contribution through the diversion reach. WL3 water level and temperature sensors in the mainstem immediately downstream of the tailrace to monitor water levels changes during plan shut-down and start-up.
The hydrometric station at WL1 and the Mile 25 bridge station were operating at the time of the site tour by Focus and ACILP. Calibration of the two stations with the IFR delivery pipe had been completed by Northwest Hydraulics Consultants (NHC), which is reported in NHC (December 9, 2009). The Mile 25 bridge station is a duplicated station and could be abandoned since the calibration of the WL1 station with the IFR delivery had been verified. The sensors at WL2 and WL3 will be installed prior to the onset of freshet in the first year of operation. The added temperature sensors will assist in the analysis of water quality and linkages to fish habitat and fish community discussed later on. Although not a condition of compliance, water level sensors will be installed in the headpond adjacent to the headworks structure to monitor headpond levels. This information will feed into the plant control system to assist with plant operations. The flow passing through the turbines in the powerhouse can be accurately measured through a turbine efficiency test that will be completed during commissioning of the Project. These tests provide measured data on turbine flow output that can be correlated with tunnel/penstock pressures and then used to develop a program that can convert real time energy and pressure measurements into flows that are diverted through the plant. Inflow into the headpond will be calculated as the sum of diverted flow and flows measured 250 m downstream of the intake.
5.1.2.2 Methods and Data Analysis

The water level sensors will be installed according to provincial Resource Inventory Standards Committee (RISC) standards such as RISC (1998a, 2009) and Land and Water BC (LWBC) hydrometric methods (LWBC, 2005). Each hydrometric station will consist of water level and/or temperature sensors. The stations, will record water levels to the nearest millimeter (mm) and temperatures in degrees Celsius
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(oC). The pressure and temperature sensors will be placed in a suitable location that will provide an accurate record of water levels and temperature and protected from being dislodged during high runoff events or by impact from large debris. The pressure transducers will be rated to 5 psi, which provides the accuracy needed to monitor water level changes up to approximately 3.5 m. The sensors will record water levels on a continuous basis with a recording frequency of 1 minute. Sensors will be surveyed into a benchmark so that any movement of the sensors can be detected and corrected as required. A cross section of Ashlu Creek at each of the hydrometric stations will be surveyed into the benchmark at the time the sensors are installed, and checked periodically to verify cross section and accuracy of the sensor data. A staff gauge or simple manual method of verifying water levels will also be installed at each station to provide operators and monitoring personnel with a check of water levels. Normally, calibration of the water level sensors with flows involves several flow measurements over a range of flows to establish a stage-discharge curve (also referred to as rating curve). However, the primary purpose of recording water levels is to verify compliance with delivery of the IFR and meet ramping rates. Regardless, calibration flow measurements will be conducted adjacent to the nearby water level sensor locations suited to the method of measurement (i.e. wading versus salt dilution) over a range of flows from IFR to less than 200% MAF to confirm rating curves and to track shifts in the rating curve. Staff gauges may also be installed to provide operators with a visual reference, although there is a high probability the staff gauges will be damaged or dislodged by debris. 5.1.3 Reporting
A Station Report will be compiled for each hydrometric station complete with a description of each site (drawing and photos), bench mark locations, elevations of sensors, data logger download records, calibration flows, and stage-discharge curve. The Station Report will be updated after each field trip including the stage-discharge curve for the purpose of reporting as necessary. Data from WL1 downstream of the intake will be recorded and available on the Project web site on a real-time basis throughout the life of the Project. The Proponents plant operator can provide on-site DFO and/or MOE staff with the instantaneous water level and flow data for compliance purposes. Details of the water flow monitoring program are summarized below in Table 2.
Table 2 Water Levels, Temperature, and Flows Attributes Objective Description Criteria Location Frequency/Duration Methods Sample area Commitments To ensure compliance with minimum IFR and track ramping rates during plant shut-down and start-up. Water level pressure and temperature sensors, calibration flow measurements. Water levels (m) and calibration flow measurements over a range of flows (between minimum IFR and 200% MAD); temperature in degrees Celsius (oC). WL1, WL2, WL3 as illustrated in Figure 1 Water levels continuous, recording at 1 minute intervals; temperature recording at 2 hr intervals. Continuous pressure transducers; calibrated with manual velocity meters. Headpond; in stream channel downstream of intake, upstream and downstream of
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Units Sensitivity/accuracy Sample no. Frequency
Timing Measure constraints
Analytical test
powerhouse/tailrace. Water level in mm and flow in m3/s; temperature in oC. +/- 2 mm for pressure transducers. To calibrate pressure sensors, minimum of three (3) discharge measurements (20+ vertical stream measurement slices) per transect; for headpond sensors, three (3) measurements. 1 minute log for water level sensors (headpond, d/s intake, d/s powerhouse); 2 hr log for temperature sensors (u/s headpond, d/s intake, u/s powerhouse, d/s powerhouse, compensation works) Continuous. For pressure transducers, select location on stream with adequate protection from debris for the standpipe; avoid placing transducer downstream of major local inflow, and avoid sites that dewater in low flow. n/a (compliance monitoring).
5.2 5.2.1
Water Quality Baseline Information
Water quality in Ashlu Creek was monitored by Sigma (2002) and TRC Biological Ltd (TRC). Sigma (2002) reported sampling physical water chemistry during field sample surveys at two locations; immediately below the powerhouse and intake. Water quality samples were collected on eight occasions in July, August, and October 2001, and in February, March, April, and June 2002. Physical parameters taken as a field measurement included; pH, turbidity, temperature, dissolved oxygen, conductivity, and hardness using a calibrated hand held field instrument. Total gas pressure (TGP) was also measured. Water chemistry samples (grab samples) were collected for laboratory analysis of nutrients and metals and were delivered to Philip Analytical in Burnaby, B.C. within 12 hours with chain of custody records. Field measurements of turbidity and water temperature were measured in April, July, September, and November 2001. Although there was no mention of quality assurance/quality control or RISC standards, examination of water quality results found in the Appendix C of Sigma (2002) revealed laboratory analysis using U.S. public health standards with analysis of duplicates and spike summaries. Additional water quality sampling was conducted prior to construction by Sigma from 2002 through 2004 and by TRC in 2005, and during the construction phase by TRC as part of the environmental monitoring program. Samples were sent to CanTest labs in Vancouver. These results are presented in Sigma (2004a), and TRC (2005) and TRC (unpublished). 5.2.2 Proposed Monitoring Activities
The objective of the water quality monitoring program is to detect any changes to water quality in Ashlu Creek as a result of the Project. Water quality through the diversion reach could change either because of altered flow through the diversion reach or by water diverted through the tunnel and being returned to Ashlu Creek at the powerhouse tailrace. During commissioning, issues related to arsenic and total suspended solids (TSS) were raised by DFO. Golder Associates Ltd (Golder) responded to these
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concerns in technical memorandums dated November 8 and 10, 2009. Recommendations made by Golder (2009) are incorporated into the long term monitoring of water quality for the Project. Water quality samples will be collected at control and impact sites within the diversion reach and results compared with pre-project baseline and among sites during operations monitoring.

Water quality parameters will be monitored at the following five (5) locations: WQ1 control site located upstream of the headpond, but downstream of Pokosha Creek to monitor changes in the watershed upstream of the Project; WQ2 located at the upstream end of the diversion reach, near the WL1 station located downstream of the intake, to characterized water quality conditions at the upstream end of the diversion reach; WQ3 located adjacent to WL3, upstream of the powerhouse tailrace to capture changes to water quality through the diversion reach; WQ4 located a short distance downstream of the tailrace to capture water quality from the diversion reach in addition to water through the project components including the tunnel; WQ5 waste rock spoil areas will be monitored for pH and metals leachate to determine whether acid rock drainage (ARD) becomes an issue.
Figure 1 illustrates the location of water quality monitoring sites.

Water quality monitoring parameters as outlined in Lewis et al. (2004) will be monitored through the operations phase for the 5 years of operations. Each of the sites will be monitored using combination of in-situ measurements and grab sampling methods on a quarterly basis. Monitoring on a quarterly basis means sampling at various times of the year coincident with the following runoff events; winter low flow (February), spring high flow (June or July), summer low flow (August or September) and late fall early winter (November) rainfall events typical of coastal watersheds. The parameters of interest for purposes of monitoring include: Physical parameters pH, temperature, turbidity, total suspended solids (TSS), electrical conductivity, dissolved oxygen, and total dissolved gas pressure (TGP); Anion and Nutrients - nitrate, nitrite, ammonia, total phosphate, SRP, total alkalinity; Metals total and dissolved (including hardness and sulphate);
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ARD and Metals Leachate waste rock spoil seepage monitored for pH and metals leachate.
Physical parameters will be measured using equipment that is properly calibrated and meets industry standards. Stream temperature will be monitored continuously at the water level sites as well as at the WQ1 control site upstream of the intake. Anions, nutrients and metals will be obtained by grab sampling at the same sites. Total gas pressure (TGP) will be measured using a TGP meter semi annually at WQ1, WQ3, and WQ4. All grab samples will be collected, filtered and preserved as necessary, and shipped to an accredited laboratory according to strict protocols outlined in Cavanah et al. (1994). Quality assurance (QA) and quality control (QC) measures include replicate sampling and field blanks. Changes to water quality will be assessed by comparing baseline and operations values and among sample sites for each of the parameters using Cavanah et al. (1998). The analysis will also include comparison with British Columbia Approved Water Quality Guidelines (Ministry of Environment, 2006), using the criteria for aquatic life. Seepage water from waste rock spoil piles will be analyzed and results compared with B.C. Acid Rock Drainage Guidelines and CCME for metals leachate concentrations. 5.2.3 Reporting
Water quality results will be reported annually along with the other monitoring components. Details of the water quality monitoring program are summarized in Table 3.
Table 3 Water Quality Monitoring Attributes Objective Approach Methods Criteria/Metrics Location/Sites Time Frame/Duration Frequency No of Samples/Area Accuracy Statistical Analysis Monitoring Constraints Commitments To document changes to water quality resulting from the Project. Quantitative assessment of water quality using BACI approach.
Physical parameters include: pH, temperature (oC), turbidity (NTU), total suspended solids (mg/L), specific conductance, dissolved oxygen (mg/L), and total gas pressure (%) Anions include: nitrate, nitrite, ammonia, total phosphate, SRP, total alkalinity (all as mg/L)
Physical parameters, anions and nutrients, total and dissolved metals, ARD, and metals leachate described above. Water Quality monitoring sites WQ 1 through WQ 5 described above. Quarterly for five (5) years. Quarterly for physical measurements and grab samples, semi-annually for TGP. n/a Physical measurements to accuracy of accredited instruments, and grab samples to laboratory limits of detection. Values will be compared to BC Water Quality Guidelines for protection of aquatic life, ARD and leachate will be compared with B.C. guidelines and CCME respectively. None
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5.3 5.3.1
Fish Habitat Baseline Information
The ACILP retained Sigma to conduct fish habitat studies, which are described in Sigma (2002, 2004a, and 2004b). TRC conducted spawning surveys in 2003 (reported in TRC, 2004). Sampling and reporting standards and protocols for the inventory and analysis of fish habitat were available at the time Sigma conducted baseline programs, such as Fish Habitat Assessment Procedures (FHAP) outlined in Johnston and Slaney (1996) and the Reconnaissance1:20,000 Fish and Fish Habitat Inventory: Standards and Procedures (RIC, 1999a, 1999b, and RISC, 2001). Sigma (2002) did not refer to these documents, although we suspect, given the type of discussion in Sigma (2002 and 2004a) that they were aware of them, but simply omitted to reference them. Sigma (2002) describes macro-habitat (reaches) in Ashlu Creek either directly or indirectly affected by the Project follows: Reach 1 confluence with Squamish River extending 3.3 km upstream characterized by 2.5%gradient (range 0.6 to 3.5%), 15m average channel width, substrate composed of gravel (60%),fines (20%), and large boulders (20%), instream cover provided by boulders, no LWD, no undercut banks, low bank height (1.5m), low riparian cover (10%), and habitat mix of riffle (80%), glide (5%), and boulder cascade (15%), no pools; Reach 2 - marks the beginning of the lower Ashlu canyon extending 2.6 km upstream characterized by high velocity turbulent flow, a 4% to 8% gradient with several small (1.5 m) falls, 10 to 15m channel width, substrate composed of large rock (50%), bedrock (20%), and boulders (25%), and gravel and fines (5%), instream cover provided by boulders, no LWD, high bank height (10m), and habitat is cascade-chute (80%) with no glides or pools; Reach 3 contained entirely within a steep walled canyon characterized by high velocity turbulent flow, a 8.5% gradient with several 2.0 m falls, 10m average channel width, substrate composed of large rock and boulders (70%), bedrock (25%), and gravel and fines (5%), only 2% instream cover provided by boulders, no LWD, high bank height (10m), and habitat is cascade-chute (100%) with no glides or pools; Reach 4 starts at a 6 m falls and extends upstream 7.4 km to Pyhett Creek, characterized by 2.5%gradient, 10m average channel width, substrate composed of predominantly gravel with occasional boulders, several small islands, side and back channels, instream cover provided by boulders, LWD, and some deep pools, low bank height (1-2 m), minimal riparian cover, and habitat mix of riffle (60%), glide (30%), and shallow pools (10%).
The Project is situated in the upper portion of reach 1 and extends through reaches 2 and 3 and the lower portion of Reach 4. Reaches 5 and 6 extend beyond the Project area. Sigma (2002) provided qualitative descriptions of both riparian and instream habitat. The riparian assessment examined large woody debris (LWD), stream shading, bank stability, back channel habitat,
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cut banks, water use, and physical impacts. Copies of the field forms (site cards) could not be found in Sigma (2002), although physical descriptions were embedded in the text. Table 1 in Sigma (2002) provided the percent of each riparian habitat type in each reach. However, without the field forms and more precise UTM coordinates, it would not be possible to track changes to riparian habitat based on the information presented in Table 1. Riparian plant communities were located, examined, and described in Dunster (2001) at the site series level at 14 locations. The information presented in Dunster provides the baseline information required to assess changes to riparian vegetation condition during operations monitoring. Instream habitat was assessed by Sigma (2002) using the Stream Survey Field Guide (referenced as DFO and MoELP, 1989). Macro-habitat or reach characteristics were described along with photos to show the representative hydraulics and fish habitats in each reach, and a figure to illustrate the location of reach breaks and sample sites were presented in Sigma (2002). In order to track changes (baseline versus operations), it would have been helpful to have tables summarizing sit coordinates (UTMs), instream characteristics in each reach such as; channel width, wetted width, residual pool depth, depth at channel bankfull, and stage to list a few as presented in RISC (2001). 5.3.2 Proposed Monitoring Activities
Table 1 of the CEAA Screening Report identifies the habitat monitoring requirements as per the DFO Authorization as follows, Post-construction monitoring will include: flow monitoring and corresponding habitat evaluations in the bypassed reach to determine the quality of habitat at varying flows, benthic diversity and abundance, qualitative changes in channel substrate, channel width and riparian vegetation. The monitoring program will concentrate on documenting qualitative changes to instream habitat (i.e. spawning, instream rearing), and riparian habitat potentially caused by the Project footprint and reduced flow regime during operations. A substantial effort was spent on baseline studies assessing spawning potential in the diversion reach and in the anadromous section downstream of the Project. The diversion reach was found to have low potential for spawning due to the lack of suitable substrate and swift, turbulent flows, which could change with reduced flows during operations. Rearing habitat was not assessed as thoroughly, as such there is limited baseline information with which to compare during operations monitoring. Baseline studies also determined that riparian habitat, particularly through the steeply walled bedrock canyon would not be affected, although attention was drawn to one particular location where moist air caused by turbulent flow through the canyon contributed to riparian growth along the rim of the canyon walls. Riparian growth will also be monitored in areas where disturbed areas have been replanted following construction.

The following locations will be monitored to provide a qualitative assessment of changes to instream and riparian habitat: Habitat 1 located upstream of the headpond to act as a control site in Reach 4; Habitat 2 located downstream of the intake, but within Reach 4;
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Habitat 3 located at the Mile 25 Bridge crossing in Reach 3; Habitat 4 alternative site located adjacent to the canyon at the gravel bar mid-way through Reach 2; Habitat 5 alternative site located in Reach 2 at the Mile 23 radio tower; and, Habitat 6 located upstream of the powerhouse at the downstream end of the diversion reach.
These monitoring sites correspond approximately with baseline habitat descriptions provided in Sigma (2001, 2004a, and 2004b), and using the same riparian plant communities identified in Dunster (2001).

Monitoring changes to instream habitat will be accomplished by assessing instream habitat at each of the sites listed above. Habitat descriptions will be completed using measurement standards according to RISC (2001) site cards and photo-documentation from set angles at representative habitat types (i.e. pools, riffles, runs) at each site. The parameters included in these site cards will provide a reasonable qualitative assessment of habitat conditions. Additional information such as habitat suitability for species of interest (i.e.steelhead/rainbow trout or coho salmon) for spawning, rearing, and overwintering life history stages will be assessed using professional judgment at IFR. Riparian plant cover at the same locations and documented at each site as per Dunster (2001). The sites identified above do not include riparian areas disturbed during construction and that must be re-planted. Monitoring success of riparian vegetation planting at sites disturbed during construction within 30 m of Ashlu Creek mainstem is required. Otherwise, the habitat balance used to calculate riparian compensation could be open for revision by DFO. 5.3.3 Reporting
Results of fish habitat monitoring will be reported annually along with the other monitoring components. Details of the habitat monitoring program are summarized in Table 4.
Table 4 Fish Habitat Monitoring Attributes Objective Approach Methods Commitments To document changes to instream and riparian habitat. Qualitative assessment of instream habitat parameters, riparian cover, and riparian planting at areas disturbed during construction. Professional observation in each habitat type (i.e. pool, riffle, run) and riparian area at each monitoring site.
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Criteria/Metrics Location/Sites Time Frame/Duration Frequency No of Samples/Area Accuracy Statistical Analysis Measure constraints
Instream parameters according to RISC (2002) site cards, riparian parameters using site series. Habitat monitoring sites Habitat 1 through 6 described above. Annually for five (5) years. Annually at minimum IFR n/a n/a No statistical analysis, but qualitatively compare baseline with operations information High water clarity required for instream assessment
5.4
Fish Community
Fish community monitoring will provide information such as relative abundance and distribution, size and age classes, and condition factor or health of fish at diversion and control sites, including the headpond, for comparison with baseline information. 5.4.1 Baseline Information
Ashlu Creek contains rainbow/steelhead trout (Oncorhynchus mykiss) in the upper reaches above the canyon and all 5 species of salmon, winter run steelhead, coastal cutthrouat trout, rainbow trout, and Dolly Varden char in the lower reaches downstream of the canyon. Rainbow/steelhead trout fry were stocked in the upper reaches (Reaches 4, 5 and 6) of Ashlu Creek by the Fisheries Branch of Ministry of Environment, Lands and Parks (MoELP) from 1978 to 1997, and residual populations of these steelhead/rainbow trout inhabit the reaches above the Ashlu Canyon. Sigma conducted spawning surveys, rearing surveys, and low flow surveys during seven field trips (total 14 days) spread out over the open water period from April to November, 2001. Spawning surveys were conducted in spring and fall and consisted of field observations but no physical sampling (i.e. traps, nets, electrofishing). Rearing surveys were conducted using enclosed (stop nets) site electrofishing to establish fish population densities, primarily in late August and early September at a total of 10 sites. Five of the sites were sampled twice. In addition numerous sites in each reach were sampled without stop nets to check for fish presence-absence throughout Ashlu Creek including the diversion reach. Total fish capture in 2001 recorded in Table 2 in Sigma (2002), by reach was; 39 fish in Reach 1, 8 fish in Reach 2, zero capture in Reach 3, 32 fish in Reach 4, 11 fish in Reach 5, and zero capture in Reach 6. Sampling effort was concentrated in Reaches 1, 4, and 5 likely due to access and suitable sampling conditions. Sigma (2004) reported on additional reconnaissance sampling conducted from 2001 to 2003 on aquatic environment components including; benthic invertebrate, water quality, spawning habitat, and habitat in the mainstem channel adjacent to the powerhouse. A very general discussion of fish presence/absence and distribution is provided in Sigma (2002 and 2004). Table 2 in Sigma (2002) summarizes electrofishing results in each Reach, but no record of individual fish capture, catch/unit effort (CPUE), population density, length, weight, age structure, or
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health is provided that would usually be reported according to Fish Collection Methods and Standards (RIC, 1997) or RISC (2001). Sigma conducted salmon spawning surveys in Reach 1 in 2003 (see Sigma 2004a). It appears no further fish sampling was conducted by either Sigma or TRC. 5.4.2 Proposed Monitoring Activities
Fish community baseline sampling resulted in low fish capture in the Project diversion reach (i.e. reaches upper portion of 1, all of 2 and 3, and lower portion of 4). The low fish capture numbers during baseline sampling in the Project area, do not provide suitable information for statistically based comparison with operations monitoring. As such, only trends in fish community metrics can be used for comparison with baseline. However, depending upon the results of fish sampling during the 5 year monitoring period, comparison of fish community metrics would be possible and could potentially provide sufficient information to assess the effects of the project on the fish community. The target species for monitoring of fish abundance and biomass will be rainbow/steelhead trout, which were encountered in the upper end of the diversion reach; the secondary target species will be coho salmon, encountered at the lower end of the diversion reach. Rainbow trout were primarily observed upstream of the Mile 25 Bridge, although some were found in the Ashlu Canyon as they were recruited from upstream as survivors of the stocking program carried out by the MoELP in the upper reaches of Ashlu Creek. Coho salmon were observed in the lower end of the diversion reach (approximately 300 metres upstream of the powerhouse and tailrace location).

Monitoring activities will consist of fish sampling at sites selected from the baseline sampling programs in 2001 to 2004 that are representative of the various habitat types found in the diversion reach of Ashlu Creek. In addition, the headpond and control sites located a short distance upstream of the headpond will be sampled. Habitat types representative of the diversion reach will be samples such as pools, riffles, and runs, plus less frequent habitat types such as shallow margins, and secondary and tertiary channels. The upstream control sites would be of similar habitat to those selected in the upper portion of the diversion reach (i.e. both in Reach 4). A summary of recommended sample areas in the diversion reach and matching habitat types in the upstream controls and anadromous zone downstream of the powerhouse tailrace are broken down by reach and site number as follows: Control Sites (upstream of headpond, upper Reach 4) Headpond Sites Diversion Reach (lower Reach 4 downstream of the intake at Mile 25 Bridge); Diversion Reach (Reach 2 alternative sites at the gravel bar); Diversion Reach (Reach 2 alternative sites at the Mile 23 radio tower);
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Diversion Reach (Reach 2 immediately upstream of the Powerhouse tailrace); Downstream of Powerhouse Tailrace (Reach 1 between the Powerhouse tailrace and the double bridges).
Sample sites in Reach 4 will target rainbow/steelhead trout for comparison with results of sampling in diversion sites in Sigma (2002). Sampling in Reach 2 and Reach 1, upstream and downstream of the powerhouse will target coho salmon, rainbow trout, coastal cutthroat, and Dolly Varden char. Additional sites may be chosen at the discretion of the biologist conducting the sampling depending upon function of various meso-habiats in maintaining fish populations, such as shallow margins, cascade/pool complexes, and side channels (i.e. tertiary and secondary). Fish sample site locations are illustrated in Figure 1.

Monitoring and sampling activities will be undertaken in accordance with Resource Inventory Standards Committee (RISC) sampling and recording protocols including RISC (1997, 1999, and 2001), provided it can be done without compromising worker safety. Duplicate sampling will be performed at each site. Efforts will be made to locate and sample the same sites sampled by Sigma (2002). The same sampling sites will be used each year for consistency and to allow paired comparisons of the fish capture in statistical tests and thereby increase statistical reliability as the program is performed over the five year period. The sampling sites will be georeferenced, photographed, and marked in the field to allow the same location to be used repeatedly each year. For example, at Site R4F1 two representative pools will be sampled to reduce sampling variability. Fish sampling will be conducted during the low flow period in late fall when sampling conditions are most favorable (i.e. water temperature >5 oC, conductivity > 30 S, and suitable water clarity). The primary sampling methods will be electrofishing, angling, and minnow trapping using G-Traps. Where feasible, sample sites will be enclosed with 9.5 mm stopnets, and electrofished using total removal methods to allow for calculation of a simple site population estimate (fish/100 m2). Sites that are too deep to effectively enclose using stopnets will be angled, electrofished using reconnaissance methods (no stopnets), and/or minnow trapped (baited Gee traps over 24 hrs). Swim (Snorkel) methods could also be implemented provided water clarity is appropriate. However, none of the baseline information was compiled from snorkel methods. Therefore snorkel methods for BACI would not apply to comparisons of baseline and operations monitoring data, but could provide useful information for comparison over the course of the 5 year monitoring program. To be an effective method, snorkel surveys would have to be calibrated against electrofishing to verify snorkel sampling efficiency and combined with a mark-recapture method. This approach is suggested as an alternative to electrofishing and angling pending the results of the first year of sampling using those methods, but ultimately would be left to professional judgement and further consultation with regulatory agencies. The headpond is relatively long and narrow, confined by the original channel banks (except near the intake where the channel widens), and will increase depths by approximately 3 to 4 m near the intake. This feature may attract fish from upstream habitat, particularly during the overwintering period, and may
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offer refuge habitat along the margins of the headpond during high runoff events, particularly for yearlings and parr. The headpond may also influence downstream recruitment. Over time, the benthic community may also change, depending upon the influx of sediment and bed load. In year one (1) of monitoring, due to the greater depth of the headpond than the pre-project creek, angling and minor trapping will be used as the primary methods of fish capture. Again, professional judgement is required during subsequent years of operations monitoring to develop a suitable sampling approach that will track changes to the fish community in the headpond. Captured fish will be anaesthetized and measured for fork length to the nearest millimeter (mm) and weighed to the nearest centigram (cg). Scale samples for aging will be collected from 50% of the fish (rainbow trout only) with a fork length greater than 75 mm. Scale samples will be analyzed to determine age. Stomach contents of captured fish will also be examined (visual field check only, not retained for taxonomy) using a stomach pump. This will provide insight into food (insect) preferences of fish downstream of the project. All fish captured will be recovered and released. Photos will be taken of each fish to verify species. However, no voucher samples will be taken unless identification is uncertain. Fish capture data analysis will include density (fish/100m2) based on three-pass total removal population estimates for enclosed sampling, and catch-per-unit-effort (CPUE) based on fish captured or observed per 100 seconds of electrofishing time for non-enclosed (reconnaissance) sampling. Angling and minnow trap data will provide indicators of fish presence, life stage, and relative abundance, as these methods will be size selective and not readily associated with clearly defined sample areas. A photographic record of sample sites and activities will be included for each site in each year of sampling. Fish cards will be compiled for each sample site in each year of sampling. Quantitative multivariate analysis of the data with power analysis to assess the biological change will be performed if possible. However, since fish capture numbers were low during baseline sampling, there may be insufficient baseline information to apply the BACI approach with any statistical reliability. The only analysis that can be performed will be to compare results from control sites and diversion sites over the 5 year monitoring period. 5.4.3 Reporting
ACILP must report any evidence of fish mortality to DFO within 24 hours and take action immediately to mitigate further incidents in order to remain in compliance with the Authorization. Fish sampling results will be reported annually along with the other monitoring components. Details of the fish community monitoring program are summarized in Table 5.
Table 5 Fish Community Monitoring Attributes Objective Approach Methods Commitments To document changes to the fish community resulting from the Project. Quantitative assessment of fish community metrics using BACI approach. Electrofishing, angling, gee traps at representative and repeatable habitat units (i.e. pools, riffles, runs), fish ID to species, and on-site measurement of fork length and weight, scale
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Criteria/Metrics Location/Sites Time Frame/Duration Frequency No of Samples/Area Accuracy Statistical Analysis Monitoring Constraints
collection, lab analysis for age determination, and photo documentation according to RISC (2001) standards. Fish presence, distribution, population density, catch-per-unit-effort, length frequency, age classes, and health. Fish sample sites described above. Annually for five (5) years. Annually in late summer/fall. n/a n/a Due to low fish capture during baseline sampling, no statistics, only trends in each metric. Sampling restricted to periods when flows, water temperature, and water clarity are appropriate for efficient sampling.
5.5
Aquatic Insects
Changing the flow regime in the diversion reach could affect productive capacity and the resultant supply of food to resident fish through the diversion reach and to resident and anadromous fish populations downstream of the Project. Monitoring aquatic insects (benthic invertebrates and drift organisms) will provide information on changes to productive capacity and linkages to limitations to the resident fish populations in Ashlu Creek resulting from the Project. However, the emphasis of the monitoring program will be on the fish community, with lesser importance placed on aquatic insects. If a significant change in the fish community occurs, aquatic insect information will be one of many variables to consider and may require alteration after the first year of sampling at the discretion of the professional biologist in consultation with the agencies. 5.5.1 Baseline Information
Sigma (2002) reported benthic invertebrate sampling using a Surber type sampler, and drift sampling using a 0.5 m diameter drift net conducted in June 2001. Drift samples were taken upstream of the canyon (no indication of site location) and at the compensation channel intake immediately downstream of the double bridges. Benthic invertebrate sampling was conducted on the same date and same locations. The same sampling effort was repeated in August 2002. Additional sampling was conducted by Sigma and TRC following the Sigma (2002) assessment report in 2003, 2004, and 2005 and is summarized in TRC (2005). Throughout the baseline benthic and drift sampling, taxonomy was to the order and family only. There was no analysis of biometrics other than to describe basic dominance, abundance, and distribution. 5.5.2 Proposed Monitoring Activities
The difficulty in setting up an operations monitoring program lies in the baseline sampling methods, which may not be comparable during operations monitoring due to differing sample techniques. A Surber sampler was used to obtain benthic invertebrate samples, which tend to include a portion of the drift in the water column. Presently, the preferred method of sampling benthic invertebrates is to use a Hess sampler,
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which isolates the benthic sample from the drift component. The operations monitoring program could continue with Surber sampling, but it is recommended the program be upgraded to using a Hess sampler, which would provide more meaningful information over the course of the 5 year monitoring period. With respect to drift sampling, the protocols used today are also more rigorous than five years ago. Regardless, implementing present drift sampling protocols identified in Hatfield et al (2007) will also improve the data collection and ability to analyze the data after five years of data collection. Based on the site tour conducted in March 2010, suitable sites for both benthic and drift sampling looked feasible, although not without challenges.

5.5.2.1.1
Drift Sample Sites
Aquatic insect drift sample sites were chosen to spatially assess the quantity and diversity of insects moving through the diversion reach. Sample sites were chosen to quantify the abundance of drift available at a control site upstream of the headpond, at the lower portion or Reach 4 and lower end of the diversion reach through Reach 1 to the powerhouse. Sites were laid out in three key locations (see Figure 2): D1 - located immediately upstream of the headpond and will function as watershed control; D2 - located at the gravel bar in the middle portion of the diversion reach to provide information on drift organisms transported within the diversion reach; and, D3 alternative in the diversion reach at the Mile 23 radio tower to provide information on drift organisms transported within the diversion reach; D4 - located upstream of the tailrace to provide information on drift organisms transported through the lower portion of the diversion reach.
5.5.2.1.2
Benthic Community Sample Sites
Benthic invertebrate sample sites were chosen to assess the health of the stream during the operations phases as follows: H1 - located immediately upstream of the headpond and will function as watershed control; H2 - located at the gravel bar in the middle portion of the diversion reach to provide information on benthic community within the diversion reach; and, H3 alternative in the diversion reach at the Mile 23 radio tower to provide information on benthic community within the diversion reach
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D4 - located upstream of the tailrace to provide information on benthic community in the lower portion of the diversion reach.
Sample sites will be in shallow riffles, since these are the most productive habitats and will be chosen as similar as possible in all characteristics (substrate type and size, gradient, current velocity, and depth) so that inter-sample variance is reduced and to increase the sensitivity of the technique in detecting environmental change.

5.5.2.2.1
Drift
Provincial standards for drift sampling described in Hatfield et al (2007) is unclear and therefore relies on professional judgment to set up a program that will result in sufficient sampling effort (i.e. replicates and distribution of nets), suitable timing both on a daily and seasonal basis, and taxonomic enumeration, and biometric analysis of the data. Water quality data suggests that Ashlu Creek has relatively low turbidity and suspended solids, although some deposition of fines and sand was observed in the headpond during the March 2010 site tour. What this is telling us is that drift sampling should not be encumbered by suspended solids, which can significantly reduce sampling efficiency. The suggested drift sampling program is recommended based on the experience Focus has gained in recent years at other similar projects. Drift sampling will take place during low flow conditions in September and repeated in October of each year of monitoring to collect sufficient samples to minimize variability. Sampling for drift at all stations will take place simultaneously from early morning to mid-day in order to standardize sample timing (drift rates vary over a 24-hour cycle). Drift sampling will be done with five (5) fixed drift nets arranged across the channel in riffle habitat and all nets will be combined into one sample (n=1). At each of the four locations, nets will be set up in the downstream half of a productive riffle. Drift nets will cover the entire depth of water (in order to collect both aquatic and terrestrial insects), and have a mesh size of 250 m in order to sample small fish-food organisms such as chironomids. Measurements of water depth (inside the drift net opening) and water velocity will be obtained at each net at the beginning, mid-point, and end of each sample period so that volume of water passing through each net can be calculated. The drift nets will be set for a minimum of 4 hours during early morning periods from one hour before sunrise to mid-morning. These sampling protocols will be adhered to so that data can be effectively analyzed and compared spatially and temporally. In the event the nets begin to clog with suspended sediment and detritus, the nets can emptied more frequently to retain sampling efficiency and result in increased number of samples. For example, at Site D-1, a set of 5 nets (n=1) for 1 hour (emptied and replaced), repeated for 4 hours provides a total of 4 samples (n=4) as opposed to a set of 5 nets set for a period of 4 hours (n=1). At 1 hour intervals, the same process over all four sites yields a total of 16 samples. If sampling occurs once in September and once again in October, the total sample number for each year increases to 32. The purpose of this exercise is to
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collect enough samples such that the variability can be tested to increase the confidence in the analysis of data. However, due to the total number of samples collected each year, sub-sampling for enumeration may be required to establish the degree of variability. The variables being measured are the difference in drift biomass and abundance between the control and treatment locations. Changes in these variables will be compared among sites over the course of the five year monitoring period. The BACI approach would not be possible given the different techniques used during baseline compared with those being proposed. However, the approach proposed will provide the information combined with fish community information to determine whether changes to fish community are connected to changes to the supply of food.
5.5.2.2.2
Benthic Community Methods and Analysis
Sampling for benthic invertebrates and drift organisms will take place during low flow conditions in September and again in October to capture stable aquatic life stages. This timing allows sampling during the critical invertebrate growth season, but avoids high flows which make consistent sampling difficult to achieve. Benthic invertebrate sampling will employ standard Hess (250 m mesh) sampling methods with five replicates at each site and sample date following RISC (1998b) sampling protocols. Replicates will be stored in individual sample jars in 70% ethanol and shipped to an accredited taxonomist for enumeration to the Family or Genus level where possible. Photos will be taken to provide a visual reference of the habitat at each site and flow condition. Physical water quality parameters will be recorded at each site. Benthic invertebrate samples will be analyzed for relative abundance and diversity for comparisons with baseline and among monitoring sites during operations over the course of the monitoring program (i.e. BACI analysis). 5.5.3 Reporting
Benthic invertebrate and drift sampling results will be reported annually along with the other monitoring components. Details of the invertebrate abundance and biomass density monitoring program are summarized in Table 6.
Table 6 Aquatic Insects Monitoring Attributes
Objectives Approach Methods Drift sampling (250m mesh) with sub-samples enumerated. To ensure consistency among samples, sampling will take place at the same Hess sampler (250 m mesh) with all samples enumerated. Sampling at similar flows on similar substrates (baseline versus operations). Follow
Drift Monitoring Commitments

Change in drift abundance and potential effect on food supply to d/s fish community
Benthic Monitoring Commitments

Change in the health of the creek due to reduced flows in the diversion reach
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Criteria (units)
time of day (drift follows a diel pattern), nets will be located in similar flow velocities and depths on all sampling dates. Number of insects/volume over time (#/m3/t), taxonomy to family or genus, biomass. 4 Sites D1 through D4. Annually in September and October for 5 years during Operation. Sample in September and October at each site. -4 sites @ 4 hour intervals in September and repeated in October = 8 samples, alternatively - 4 sites @ 1 hour intervals over 4 hours in September and repeated in October = 32 Confidence = 95% Variance = 50% or less Repeated-measures Anova, biomass, abundance Sampling must be done during low flow conditions
RISC (1998b) sample protocols Number of organisms/m2, taxonomy to family or genus. 4 Sites H1 through H4. Same time as drift over 5 years of Operation. Sample in September and October at each site September: 5 replicates/site x 4 sites = 20 samples October: sampling repeated = 20 samples. Total samples/year = 40. .Confidence = 95% Variance = 50% or less Relative abundance and diversity biometrics Sampling must be done during low flow conditions
Location/Sites Time Frame Frequency/ Duration No. of Samples
Accuracy Stats Analysis Monitoring Constraints
5.6
Geomorphology
Transport and deposition of suspended sediment and bed material was not collected during pre-Project baseline, partly because at the time the baseline program was being conducted, facilities were being designed with the ability to flush sediments trapped in the headpond during operations. The commitment to flush sediments and bed material has been considered standard design and practice for water power projects. Recently however, the effects of run-of-river projects on the transport of suspended sediment and bed material through the diversion reach has come into question. Although there is no baseline data, the proposed approach will provide the information required to determine if substantial changes are taking place within the headpond, diversion reach and in the channel downstream of the Project. 5.6.1 Baseline Information
Geomorphology studies designed specifically to establish bed load transport and deposition characteristics through the Project area were not conducted as baseline prior to construction of the Project components. 5.6.2 Proposed Monitoring Program
The purpose of monitoring changes to channel morphology are to verify whether suspended sediment and bed material are being transported through the Project area and not impacting fish habitat or sediment and bed load supply to the alluvial fan or the Squamish River downstream of the Project. The movement of sediment and bed material will be monitored using an analysis of historic air photos and site data collection to analyze the changes in channel morphology. Changes in turbidity and suspended sediment regime will be picked up in the water quality program.
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Monitoring will be concentrated at the following four locations including: CM 1- the headpond comprising from the upstream limits of the headpond at normal operating water level to the diversion structures; CM 2 located downstream of the intake but upstream of the falls in Reach 4; CM 3 located between the powerhouse tailrace and the top of Reach 2 where the canyon begins; and CM 4 located downstream of the tailrace but upstream of the Double Bridges.
These sites are general locations, which will be pin-pointed in the field at the outset of the monitoring program to select specific features to be picked up by the monitoring program.

A review of historical air photos through the watershed since 1940 will establish the changes that have been taking place prior to the Project. In years 1, 3, and 5 of monitoring, site data collection will require real-time kinetic Global Positioning System (GPS) survey and/or low level aerial photography at the sample sites listed above to monitor changes to channel features. Stream bed material sampling using either a gravelometre or pebble count methods will document changes to bed material at each site. 5.6.3 Reporting
Channel morphology results will be reported annually along with the other monitoring components. Details of the channel morphology monitoring program are summarized in Table 7.
Table 7 Channel Morphology Monitoring
Attributes Objective Approach Methods
Commitments To document changes to the channel morphology characteristics resulting from the Project and to measure bed load and sediment retained in the headpond. Quantitative assessment of channel features using air photos and site measurements Historic air photo analysis, low level aerial photography taken year 1, 3, and 5 of monitoring and site survey of specific locations, and pebble count measurements to analyze changes to channel features. Ground survey or bathymetric survey at specific locations (CM 1, CM 3) Changes to channel features (i.e. bars, islands, banks) and bed material Channel Morphology sites CM 1 to 4 Years 1, 3, and 5 of monitoring. Once per year during low flow periods in September or October.
Criteria/Metrics Location/Sites Time Frame/Duration Frequency
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No of Samples/Area Accuracy Statistical Analysis Monitoring Constraints
n/a 0.1 m for air photos, 0.1 cm for pebble counts, and 1.0 cm for ground survey Comparison of surveyed sites over time Sampling restricted to low flow periods and good water clarity (not temperature dependent).
5.7
Mitigation and Compensation Works
Compensation works completed during construction include the fishway and the compensation channel. 5.7.1 Baseline Information
The baseline fish community at the compensation work will be given a value of nil since the fishway and compensation channel represent new channel and habitat. 5.7.2 Proposed Monitoring Activities
5.7.2.1 Fishway
The efficacy of rainbow trout passage past the water intake will be evaluated qualitatively by a visual inspection of fish movement through the fishway each year during the period of rainbow trout movement (typically in April/May). Observations will also be made at the fishway entrance to determine whether fish are stalled and not entering the fishway. Periodic observations will be made to check on fish passage either in the fishway or at the fishway entrance. Measurements of depth and velocity will be obtained at the entrance, exit cell, and several cells mid-way to verify flows and as a check to verify the fishway design flows are being met, and in the event any adaptive measures are required to improve fishway function.
5.7.2.2 Fish Compensation Channel

As-built drawings of the compensation channel along with measurements of rearing habitat and spawning platforms have been completed by ACILP to verify the channel contains the compensation areas required by the habitat balance and DFO Authorization. The compensation works will be monitored (see Figure 1) by a combination of observations of channel structure integrity, ability of the intake to deliver the design flow and fish presence/absence Channel structure integrity will be monitored by annual inspection of the channel substrate (bed movement and siltation) and bank stability. Fixed points will be established as photo-documentation points. Fish utilization will be monitored initially by angling, snorkeling, and/or minnow trapping methods to verify fish presence/absence. Temperature sensors will be installed at the inlet of the compensation channel downstream of Hawkeye Pond, and at the two outlet channels in Spirit Pond and Toad Pond (see Figure 1). Monitoring will be conducted for a five (5) year period or until it can be shown that the compensation channel is functioning as intended, which in this case is for Coho rearing. The plant
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operator will carry on the monitoring of flow in the channel (i.e. monitor water levels at the staff gauge) while at the same time inspecting the channel integrity and functionality. 5.7.3 Reporting
The results of fishway and compensation channel monitoring will be compiled annually over the five (5) year monitoring period. Details of the fishway and compensation channel monitoring program are summarized in Table 8.
Table 8 Fishway and Compensation Channel Attributes Objective Approach Methods Commitments To document integrity and function of fishway and compensation channel. Observations of fish using fishway and compensation channel. Fishway monitored to verify fish use and passage upstream into headpond. Compensation channel monitored for integrity and use of rearing habitat by Coho salmon. Sampling in compensation channel and temperature monitoring Integrity using observations and photographic record from fixed points/angles, Utilization using observations, sampling, and monitoring temperature Fishway entrance and egress. Various locations in compensation channel, temperature at inlet (Hawkeye Pond) and outlet (Spirit Pond and Toad Pond). Annually for 5 years. Once per year during low flow periods in September or October. n/a 0.1 oC for temperature. n/a Water clarity in fishway and compensation channel.
Criteria/Metrics Location/Sites Time Frame/Duration Frequency No of Samples/Area Accuracy Statistical Analysis Monitoring Constraints
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6.0
6.1
IMPLEMENTATION AND REPORTING

Monitoring Program Implementation
The proposed monitoring programs will commence in the first year following plant commissioning and will continue through operations for the specified period of five (5) consecutive years. The proposed monitoring program encompasses both engineering and biological information needs. Tables 2 to 8 provide a summary of the monitoring program commitments. Refer to Figure 1 for sample site locations. The OEMP results will be reviewed annually and adjustments made to the monitoring program and/or mitigation/compensation measures as required in consultation with regulatory agencies. Table 9 summarizes the sample locations and monitoring components. Water level and temperature sensors will be installed in year 1 of monitoring and will collect data continuously over the five year monitoring program. Fish, benthic invertebrates, and drift sampling will be initiated in September and/or October of the first year of monitoring and continue on an annual basis for the five year monitoring period. Water quality grab samples will be collected by the operator on a quarterly basis for the five year period. A survey of the headpond was conducted during the period of plant shut down in March 2010 and the results will be reported in the first annual report. The historical air photo analysis will be implemented in the first year of operation and follow-up site measurements will be conducted in years 1, 3, and 5 of the monitoring program. 6.2 Annual and Final Reporting
Monitoring Reports for each yearly monitoring program will be submitted to MOE and DFO within 6 months following the completion of that years monitoring. The annual monitoring reports will consist of data and discussion of any substantial changes or issues encountered. The intent of submitting yearly reports is to obtain feedback from MOE and DFO so that any improvements to monitoring and data analysis can be planned and implemented in the following years program. At the end of the 5th year of monitoring, a final report summarizing the results of the program and project effects will be submitted for review by MOE and DFO.
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Table 9 Summary of Monitoring Components
Site/frequency
Water Quality quarterly
Temperature continuous (2 hrs)
Water Level
Water Flow
Fish Community
Fish Habitat
Benthic Invertebrate / Drift annually
Stream/Channel Morphology
Upstream of Headpond Headpond
annually continuous (1 min.)
annually
annually continuous (1 min.)
year 1, 3, 5
Downstream of Intake (250 m) Mile 25 (km 7.3)
quarterly
continuous (2 hrs)
continuous (1 min.)
annually
annually
annually
annually
Tunnel rock spoil site (km 6.5) Gravel bar Mile 23 (radio tower, km 4.0) Upstream of Powerhouse Powerhouse Downstream of Powerhouse Compensation Works inlet Compensation Works outlet
quarterly (annually as alternative) (annually as alternative) continuous (2 hrs) quarterly flow measurement continuous (1 min. diverted flow) quarterly continuous (2 hrs) continuous (2 hrs) continuous (2 hrs) continuous (1 min.) annually year 1, 3, 5 annually (annually as alternative) (annually as alternative) annually
annually (annually as alternative) annually year 1, 3, 5
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7.0 ASSESSMENT OF EFFECTS

Monitoring programs should be set up with goals and objectives such that at the end of the program, statements regarding effects to environmental components can be made with confidence (i.e. based on science) that effects of the project are due to the project and not some external condition or activity. At the end of the monitoring program, conclusions should be reached that establish the level or degree of change and limits or thresholds established to support the need for either a change to the project to further minimize effects or additional compensation to offset those effects. 7.1 Assessing Results of Monitoring Activities
The BACI approach can be applied to the majority of the components of the monitoring program. 7.2 Establishing Thresholds The term thresholds refers to the degree of change or level of effects based on professional opinion and/or supported by the literature in consultation with regulatory agencies. For water quality, the BC Water Quality Guidelines would be used to assess changes. However, for fish and fish habitat, and benthic communities, there are no specific thresholds to which the project is liable for and will therefore be based on professional opinion.
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8.0 REFERENCES
B.C. Ministry of Environment, Water Stewardship Division, Management and Standards Branch. 2006. Conditional Water Licence. Prepared by Water Stewardship Branch. B.C. Ministry of Environment. December 19, 2009. Memo response to Version B of OEMP prepared by ACILP. Cavanah, N., R.N. Nordin, L.G. Swain, and L.W. Pommen. 1994. Ambient Freshwater and Effluent Sampling Manual. British Columbia Ministry of Environment, Lands, and Parks. Cavanah, N., R.N. Nordin, L.G. Swain, and L.W. Pommen. 1998. Guidelines for Designing and Implementing a Water Quality Monitoring Program in British Columbia. Prepared for Ministry of Environment, Lands, and Parks. Cascade. 2009. Memorandum on Ashlu Creek flow monitoring during ramping. Prepared for ACILP on December 14, 2009. CEA Agency: DFO, Oceans, Habitat and Enhancement Branch, Major Projects Review Unit. CEAA Screening Report Ledcor Power Inc. Proposed Run-of-River Hydro Project on Ashlu Creek, BC. Prepared by Department of Fisheries and Oceans Canada, Oceans, Habitat and Enhancement Branch, Major Projects Review Unit, Vancouver, BC. DFO, Lower Fraser River Division, Habitat and Enhancement Branch. 2004. Authorization under Section 32 and 35(2) of the Fisheries Act. Dunster. (2001). Unpublished. Golder. 2009. Technical Memorandum response to DFO on 10 November, and water quality management plan for energy dissipation system testing and tailrace/penstock discharges. Hatfield, T., A.F. Lewis, and S. Babakaiff. 2007. Guidelines for the collection and analysis of fish and fish habitat data for the purpose of assessing impacts from small hydropower projects in British Columbia. Prepared by Solander Ecological Research Ltd. And Ecofish Research Ltd. for the BC Ministry of Environment, Surrey BC. Knight Piesold Ltd. 2010, Ashlu Creek Hydrology Update. LWBC. 2005. Hydrological Guidelines for Waterpower Projects. Completed by the Surrey Regional Office, Land and Water Management Division, Suite 200-10428 153rd Street, Surrey BC V3R 1E1. 20 pp. July 2005.
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Johnston, N.T. and P.A. Slaney. 1996. Fish Habitat Assessment Procedures. Watershed Restoration Technical Circular No. 8, revised April 1996. Watershed Restoration Program. BC Ministry of Environment Lands and Parks and Ministry of Forests. NHC. 2009. Memo to ACILP on the subject of IFR flow measurement. RIC. 1997. Fish Collection Methods and Standards. Version 4.0. Prepared by the BC Ministry of Environment Lands and Parks, Fisheries Inventory Unit for the Aquatic Ecosystems Task Force, Resource Inventory Committee. 67 pp. With Errata March 1999. RISC. 1998a. Manual of Standard Operating Procedures for Hydrometric Surveys in British Columbia. Prepared by Ministry of Environment, Lands & Parks, Resource Inventory Branch for the Aquatic Inventory Task Force. RISC. 1998b. Biological Sampling Methods. Prepared for the Resource Inventory Standards Committee. RISC. 2001. Reconnaissance (1:20,000) Fish and Fish Habitat Inventory Standards and Procedures. Prepared by B.C. Fisheries Information Branch. Prepared for the Resource Inventory Standards Committee. RISC. 2009. Manual of British Columbia hydrometric standards (Version 1.0). Prepared by the BC Ministry of Environment, Science and Information Branch, Victoria, BC. Sigma. 2002. Ashlu Creek Aquatic Environmental Assessment. Sigma. 2004a. The 2003 Environmental Assessment Addendum for the Ashlu Creek Hydroelectric Project. Sigma. 2004b. Ashlu Creek Hydroelectric Project, Habitat Balance Report (September 2004 updated from March 2004). TRC. 2005. The 2005 Environmental Assessment Addendum, prepared for the Ashlu Creek Hydroelectric Project.
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March 18, 2010 Tim Bennett, P.Eng. Section Head - Water Allocation Ministry of Environment 10470 152nd Street, 2nd Floor Surrey, BC, V3R 0Y3 Tel: (604) 582-5235 Email: timothy.Bennett@gov.bc.ca Re: Ashlu Creek Green Power Hydroelectric Project Operations Environmental Monitoring Plan, Revision C, Application for Leave to Commence Operations and Project Status
Dear Tim; Pursuant to the requirements of Conditional Water Licence #102203 (file #2001264) Ashlu Creek Investments LP (ACILP) hereby submits the Aquatic Life Operating Environmental Monitoring Plan, Revision C for the Ashlu Creek Project (the OEMP). The OEMP in a previous form was submitted to DFO on May 19, 2009 under the title Five Year, Post-Construction Aquatic Monitoring Program, Revision A. A follow up letter describing the method to confirm ramping rates during commissioning has been sent to DFO on October 14, 2009. We have yet not received comments from DFO to Revision A or the follow up letter. Revision B was issued to your office with copy to DFO on November 27, 2009. In an email dated December 18, 2009 you expressed various concerns with regards to Revision B, one of them the unknown authorship. ACILP has retained Bill Johnson, R.P.Bio who authored the new revision of the OEMP. Please note that the Operating Parameters and Procedures Report for the Ashlu Creek Project (the OPPR) as submitted to your office on November 24, 2009 has some minor inconsistencies with the new revision of the OEMP, mainly with respect to water temperature, water level and flow monitoring stations. We plan to revise the OPPR to implement those changes once the OEMP has been accepted by your office. We understand that the OEMP was the last remaining document required to issue a Leave to Commence Operation and ACILP hereby reapplies for the LTC Operation. ACILP and its Consultant Bill Johnson remain available to meet with MOE staff to discuss the OEMP or OPPR for the Ashlu Creek project. As per my voicemail to you on March 9, 2010 the plant is not diverting water since February 28, 2010 due to increased number of rocks that went through the turbines which caused us to perform a tunnel inspection. The inspection revealed that some localized areas in the tunnel require repairs which commenced in early March and are expected to be completed by March 29. Commissioning activities have been interrupted by the current shut down and the final index testing of the turbines has been consequently delayed. We further intend to extend the commissioning activities to the repaired tunnel with a two week monitoring program for rock break in the turbines and tail race in order to confirm that the initial tunnel works and current
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repairs are functioning as intended. Should the LTC Operation not be available by the time we expect to re-water the penstock/tunnel and recommence commissioning, we would apply in due time with the Independent Engineer for an extension of the LTC commissioning. If you have any further questions, comments, or require additional information please contact me at 604-984-8600 local 224. Sincerely, Innergex Renewable Energy Inc.
Robert Kulka, P.Eng. Construction Manager
Encl. Cc. (per email only): MEO: Scott Babakaiff, Fish Protection Hydrologist George Steeves, P.Eng., Independent Engineer MOE Bill Johnson, R.P.Bio., Focus Environmental, Inc. ACILP: Richard Blanchet, Kelly Boychuk
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Your C.O.C. #: 8554802, 85548-02
Attention: ROBERT J. KULKA ASHLU CREEK INVESTMENTS LIMITED PARTNERSHIP VANCOUVER SUITE 303-38 FELL AVENUE NORTH VANCOUVER, BC CANADA V7P 3S2 Report Date: 2010/04/09
CERTIFICATE OF ANALYSIS
MAXXAM JOB #: B020784 Received: 2010/04/09, 07:55 Sample Matrix: Water # Samples Received: 1 Date Extracted N/A N/A N/A N/A N/A N/A N/A N/A Date Analyzed 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/08
Analyses Hardness Total (calculated as CaCO3) Hardness (calculated as CaCO3) Na, K, Ca, Mg, S by CRC ICPMS (diss.) Elements by ICPMS Low Level (dissolved) () 1 Na, K, Ca, Mg, S by CRC ICPMS (total) Elements by ICPMS Low Level (total) () 1 Filter and HNO3 Preserve for Metals Total Suspended Solids
Quantity 1 1 1 1 1 1 1 1
Laboratory Method
Analytical Method
BRN SOP-00206 BRN SOP-00206 BRN SOP-00206 BRN SOP-00206 BRN WI-00006 R1.0 BRN SOP-00277 R5.0
Based on EPA 200.8 Based on EPA 200.8 Based on EPA 200.8 Based on EPA 200.8 Based on EPA 200.2 Based on SM - 2540 D
* Results relate only to the items tested.
(1) SCC/CAEAL
Validated by : DAVE HUANG BBY Scientific Specialist
Total cover pages: 1

Maxxam Analytics International Corporation o/a Maxxam Analytics Burnaby: 8577 Commerce Court V5A 4N5 Telephone(604) 444-4808 Fax(604) 444-4511
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ASHLU CREEK INVESTMENTS LIMITED PARTNERSHIP Maxxam Job #: B020784 Report Date: 2010/04/09
RESULTS OF CHEMICAL ANALYSES OF WATER

Maxxam ID Sampling Date COC# Units Preparation Filter and HNO3 Preservation Physical Properties Total Suspended Solids N/A mg/L T52441 2010/04/08 20:15 85548-02 TAIL RACE LAB 100
RDL N/A 4
QC Batch ONSITE 3871044
N/A = Not Applicable RDL = Reportable Detection Limit
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LOW LEVEL DISSOLVED METALS IN WATER (WATER)

Maxxam ID Sampling Date COC# Units Misc. Inorganics Dissolved Hardness (CaCO3) Dissolved Metals by ICPMS Dissolved Aluminum (Al) Dissolved Antimony (Sb) Dissolved Arsenic (As) Dissolved Barium (Ba) Dissolved Beryllium (Be) Dissolved Bismuth (Bi) Dissolved Boron (B) Dissolved Cadmium (Cd) Dissolved Chromium (Cr) Dissolved Cobalt (Co) Dissolved Copper (Cu) Dissolved Iron (Fe) Dissolved Lead (Pb) Dissolved Lithium (Li) Dissolved Manganese (Mn) Dissolved Molybdenum (Mo) Dissolved Nickel (Ni) Dissolved Selenium (Se) Dissolved Silicon (Si) Dissolved Silver (Ag) Dissolved Strontium (Sr) Dissolved Thallium (Tl) Dissolved Tin (Sn) Dissolved Titanium (Ti) Dissolved Uranium (U) Dissolved Vanadium (V) Dissolved Zinc (Zn) Dissolved Zirconium (Zr) Dissolved Calcium (Ca) Dissolved Magnesium (Mg) Dissolved Potassium (K) Dissolved Sodium (Na) Dissolved Sulphur (S) mg/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L mg/L mg/L mg/L mg/L mg/L T52441 2010/04/08 20:15 85548-02 TAIL RACE 70.8 73.3 2.29 35.7 25.8 <0.01 <0.005 1610 <0.005 12.6 0.039 1.94 14 0.011 79.3 0.34 7.01 0.17 0.39 9560 <0.005 182 0.002 0.02 <0.5 3.59 11.9 0.5 <0.1 18.8 5.81 3.20 90.9 18
RDL 0.5 0.2 0.02 0.02 0.02 0.01 0.005 50 0.005 0.1 0.005 0.05 1 0.005 0.5 0.05 0.05 0.02 0.04 100 0.005 0.05 0.002 0.01 0.5 0.002 0.2 0.1 0.1 0.05 0.05 0.05 0.05 10
QC Batch 3872204 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3872205 3872205 3872205 3872205 3872205
RDL = Reportable Detection Limit
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LOW LEVEL TOTAL METALS IN WATER (WATER)

Maxxam ID Sampling Date COC# Units Calculated Parameters Total Hardness (CaCO3) Total Metals by ICPMS Total Aluminum (Al) Total Antimony (Sb) Total Arsenic (As) Total Barium (Ba) Total Beryllium (Be) Total Bismuth (Bi) Total Boron (B) Total Cadmium (Cd) Total Chromium (Cr) Total Cobalt (Co) Total Copper (Cu) Total Iron (Fe) Total Lead (Pb) Total Lithium (Li) Total Manganese (Mn) Total Molybdenum (Mo) Total Nickel (Ni) Total Selenium (Se) Total Silicon (Si) Total Silver (Ag) Total Strontium (Sr) Total Thallium (Tl) Total Tin (Sn) Total Titanium (Ti) Total Uranium (U) Total Vanadium (V) Total Zinc (Zn) Total Zirconium (Zr) Total Calcium (Ca) Total Magnesium (Mg) Total Potassium (K) Total Sodium (Na) Total Sulphur (S) mg/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L mg/L mg/L mg/L mg/L mg/L T52441 2010/04/08 20:15 85548-02 TAIL RACE 151 1820 3.68 59.9 68.0 0.04 0.082 1630 0.232 14.4 1.47 19.5 1860 2.45 81.3 54.2 7.13 2.32 0.39 14500 0.067 273 0.008 1.82 109 4.75 14.0 155 2.2 48.5 7.37 3.46 89.6 17
RDL 0.5 0.2 0.02 0.02 0.02 0.01 0.005 50 0.005 0.1 0.005 0.05 1 0.005 0.5 0.05 0.05 0.02 0.04 100 0.005 0.05 0.002 0.01 0.5 0.002 0.2 0.1 0.1 0.05 0.05 0.05 0.05 10
QC Batch 3872203 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3872206 3872206 3872206 3872206 3872206
RDL = Reportable Detection Limit
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QUALITY ASSURANCE REPORT
Matrix Spike % Recovery QC Limits 120 80 - 120 110 80 - 120 109 80 - 120 116 80 - 120 113 80 - 120 108 80 - 120 105 80 - 120 NC 80 - 120 104 80 - 120 117 80 - 120 115 80 - 120 120 80 - 120 107 80 - 120 Spiked Blank % Recovery QC Limits 104 80 - 120 100 80 - 120 98 80 - 120 108 80 - 120 106 80 - 120 110 80 - 120 107 80 - 120 102 80 - 120 104 80 - 120 101 80 - 120 107 80 - 120 104 80 - 120 104 80 - 120 Method Blank Value Units <0.02 ug/L <0.01 ug/L <0.005 ug/L <0.1 ug/L <0.005 ug/L <0.05 ug/L <0.005 ug/L <0.5 ug/L <0.02 ug/L <0.04 ug/L <0.002 ug/L <0.2 ug/L <0.1 ug/L <0.2 ug/L <0.02 ug/L <0.02 ug/L <0.005 ug/L <50 ug/L <1 ug/L <0.05 ug/L <0.05 ug/L <100 ug/L <0.005 ug/L <0.05 ug/L <0.002 ug/L <0.01 ug/L <0.5 ug/L <0.1 ug/L <0.02 ug/L <0.01 ug/L <0.005 ug/L <0.1 ug/L <0.005 ug/L <0.05 ug/L <0.005 ug/L <0.5 ug/L <0.02 ug/L <0.04 ug/L <0.002 ug/L <0.2 ug/L RPD Value (%) QC Limits 7.4 20 NC 20 NC 20 NC 20 7.6 20 0.2 20 NC 20 3.0 20 8.8 20 NC 20 2.5 20 NC 20 5.0 20 3.6 20 NC 20 1.9 20 NC 20 NC 20 5.9 20 2.4 20 1.4 20 3.8 20 NC 20 0.6 20 NC 20 NC 20 NC 20 NC 20 4.1 20 NC 20 0.3 20 NC 20 5.3 20 6.8 20 4.6 20 2.2 20 5.1 20 0.2 20 3.0 20 NC 20
QC Batch 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868071 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3868077
Parameter Dissolved Arsenic (As) Dissolved Beryllium (Be) Dissolved Cadmium (Cd) Dissolved Chromium (Cr) Dissolved Cobalt (Co) Dissolved Copper (Cu) Dissolved Lead (Pb) Dissolved Lithium (Li) Dissolved Nickel (Ni) Dissolved Selenium (Se) Dissolved Uranium (U) Dissolved Vanadium (V) Dissolved Zinc (Zn) Dissolved Aluminum (Al) Dissolved Antimony (Sb) Dissolved Barium (Ba) Dissolved Bismuth (Bi) Dissolved Boron (B) Dissolved Iron (Fe) Dissolved Manganese (Mn) Dissolved Molybdenum (Mo) Dissolved Silicon (Si) Dissolved Silver (Ag) Dissolved Strontium (Sr) Dissolved Thallium (Tl) Dissolved Tin (Sn) Dissolved Titanium (Ti) Dissolved Zirconium (Zr) Total Arsenic (As) Total Beryllium (Be) Total Cadmium (Cd) Total Chromium (Cr) Total Cobalt (Co) Total Copper (Cu) Total Lead (Pb) Total Lithium (Li) Total Nickel (Ni) Total Selenium (Se) Total Uranium (U) Total Vanadium (V)
Date 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09
112 107 115 110 110 105 105 106 NC 114 114 111
80 - 120 80 - 120 80 - 120 80 - 120 80 - 120 80 - 120 80 - 120 80 - 120 80 - 120 80 - 120 80 - 120 80 - 120
98 101 98 105 103 105 108 103 103 102 109 100
80 - 120 80 - 120 80 - 120 80 - 120 80 - 120 80 - 120 80 - 120 80 - 120 80 - 120 80 - 120 80 - 120 80 - 120
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QUALITY ASSURANCE REPORT
Matrix Spike % Recovery QC Limits NC 80 - 120 Spiked Blank % Recovery QC Limits 99 80 - 120 Method Blank Value Units <0.1 ug/L <0.2 ug/L <0.02 ug/L <0.02 ug/L <0.005 ug/L <50 ug/L <1 ug/L <0.05 ug/L <0.05 ug/L <100 ug/L <0.005 ug/L <0.05 ug/L <0.002 ug/L <0.01 ug/L <0.5 ug/L <0.1 ug/L <4 mg/L RPD Value (%) QC Limits 5.9 20 1.5 20 1 20 0.2 20 NC 20 NC 20 0.4 20 3.6 20 0.4 20 4.3 20 NC 20 1.2 20 4.2 20 NC 20 NC 20 NC 20 NC 25
QC Batch 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3868077 3871044
Parameter Total Zinc (Zn) Total Aluminum (Al) Total Antimony (Sb) Total Barium (Ba) Total Bismuth (Bi) Total Boron (B) Total Iron (Fe) Total Manganese (Mn) Total Molybdenum (Mo) Total Silicon (Si) Total Silver (Ag) Total Strontium (Sr) Total Thallium (Tl) Total Tin (Sn) Total Titanium (Ti) Total Zirconium (Zr) Total Suspended Solids
Date 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/09 2010/04/08
97
80 - 120
100
80 - 120
N/A = Not Applicable RPD = Relative Percent Difference Duplicate: Paired analysis of a separate portion of the same sample. Used to evaluate the variance in the measurement. Matrix Spike: A sample to which a known amount of the analyte of interest has been added. Used to evaluate sample matrix interference. Spiked Blank: A blank matrix to which a known amount of the analyte has been added. Used to evaluate analyte recovery. Method Blank: A blank matrix containing all reagents used in the analytical procedure. Used to identify laboratory contamination. NC (Matrix Spike): The recovery in the matrix spike was not calculated. The relative difference between the concentration in the parent sample and the spiked amount was not sufficiently significant to permit a reliable recovery calculation. NC (RPD): The RPD was not calculated. The level of analyte detected in the parent sample and its duplicate was not sufficiently significant to permit a reliable calculation.
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Validation Signature Page

Maxxam Job #: B020784
The analytical data and all QC contained in this report were reviewed and validated by the following individual(s).
DAVE HUANG, BBY Scientific Specialist
==================================================================== Maxxam has procedures in place to guard against improper use of the electronic signature and have the required "signatories", as per section 5.10.2 of ISO/IEC 17025:2005(E), signing the reports. For Service Group specific validation please refer to the Validation Signature Page.
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From: Sent: To: Cc: Subject: Attachments: Steeves, George [gsteeves@ameresco.com] Saturday, May 1, 2010 7:36 AM Bennett, Timothy A ENV:EX; Babakaiff, Scott C ENV:EX; Stoddard, Erin M ENV:EX; vince.busto@dfo-mpo.gc.ca; francesca.knight@dfo-mpo-gc.ca Richard Blanchet; rkulka@innergex.com Leave to Construct - Generating Equipment Commissioning - 4th Extension (File No: 2001264; Licence No: 102203) Authorization - LTC - Generating Equipment Commissioning -4th Extension v2.doc; Ltr_to_T_Bennett_re_OEMP_Framework_for_Ashlu_Creek_Hydro_-_Ecofish.pdf
Tim PleasefindtheLeavetoConstructGeneratingEquipmentCommissioning4thExtension attached.Thankyouforyourassistance. George ***NOTE:ThisemailmaycontainPRIVILEGEDandCONFIDENTIALinformationandisintended onlyfortheuseofthespecificindividual(s)towhichitisaddressed.Ifyouarenotan intendedrecipientofthisemail,youareherebynotifiedthatanyunauthorizedreview, use,dissemination,disclosure,distributionorcopyingofthisemailortheinformation containedinitorattachedtoitisstrictlyprohibited.Ifyouhavereceivedthisemail inerror,pleaseimmediatelynotifythepersonnamedabovebyreplyemailanddestroyall copiesoftheoriginalmessage.Thankyou.***
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TRUE NORTH ENERGY

April 30, 2010 Water Stewardship Lower Mainland Ministry of the Environment nd 10470 152 Street Surrey, BC V3R 0Y3 Attention: Dear Sir: RE: ASHLU CREEK INVESTMENTS LIMITED PARTNERSHIP ASHLU HYDROELECTRIC PROJECT TH LEAVE TO CONSTRUCT GENERATING EQUIPMENT COMMISSIONING - 4 EXTENSION Mr. Timothy Bennett, P. Eng. Section Head, Water Allocation File No. 2001264 Water Licence No.102203
Further to the original Authorization for the Leave to Construct Generating Equipment Commissioning, the request by ACILP to extend the commissioning period a further 60 days to June 29, 2010 is hereby approved. All the conditions included in the original Leave to Construct dated October 20, 2009 are still applicable. This letter constitutes granting of permission to continue the generating equipment commissioning until June 30, 2010. This of course is conditional upon the continued implementation of the water quality monitoring and management program and other ongoing activities as required under the OEMP and as presented in the Ecofish Research letter dated April 30, 2010. This extension is also conditional upon ACILP complying with the following conditions: 1) ACILP must provide a workplan and schedule for facility (e.g., bypass spillway) modifications to prevent fish stranding in the bypass weir spillway, to the satisfaction of the Assistant Regional Water Manager, within 30 days. In the interim, commissioning activities should be undertaken in such a way as to minimize the potential for fish stranding; Commissioning activities must not result in ramping rates within the stream that exceed DFO guidance, i.e., DFO's default hourly ramping rates of 2.5 cm/hr; The IEM must continue to undertaken monitoring activities throughout the commissioning period, and continue to provide weekly EM reports; and,
2)
3)
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4)
Any activities that result in fish stranding and/or salvage, exceedances of ramping rates, or non-compliance with licence or authorization conditions (i.e., IFR) must be reported to DFO and MoE within 24 hours.
ACILP will require the issuance of the Leave to Commence Operations prior to June 30, 2010 to be allowed to commence commercial operations.
Yours very truly,
George L. Steeves, P. Eng. Independent Engineer BC Licence #27528 Ontario Licence #44231017 True North Energy o/a 1169417 Ontario Inc. 30 Catherine Avenue Aurora, Ontario L4G 1K5
Office: Direct: Cell: Fax: 647-788-6000 x 6028 647-778-6028 416-452-4715 416-218-2288
Suite 360 2608 Granville Street Vancouver, BC V6H 3V3

Office: 604-684-4984
Could you please issue the extension for the Leave for commissioning, subject to the following conditions: 1) the proponent must provide a workplan and schedule for facility (e.g., spillway) modifications to prevent fish stranding in the weir spillway, to the satisfaction of the assistant regional water manager, within 30 days. In the interim, commissioning activities should be undertaken in such a way as to minimize the potential for fish stranding; 2) commissioning activities must not result in ramping rates within the stream that exceed DFO guidance, i.e., DFO's default hourly ramping rates of 2.5 cm/hr; 3) the IEM must continue to undertaken monitoring activities throughout the commissioning period, and continue to provide weekly EM reports; and, 4) any activities that result in fish stranding and/or salvage, exceedances of ramping rates, or non-compliance with licence or authorization conditions (i.e., IFR) must be reported to DFO and MoE within 24 hours.
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From: Sent: To: Subject: Attachments: Bennett, Timothy A ENV:EX Friday, January 29, 2010 11:58 AM Babakaiff, Scott C ENV:EX; Stoddard, Erin M ENV:EX; Davies, James W ENV:EX FW: Clarification of EM staff (Ashlu - 2001264) 2009-04-17 Ashlu - Enrivonmental Monitor.pdf; 090310 Environmental Monitoring Proposal NC Rev.pdf; 090422 Scope of Information and Reports by the Environmental Monitor.pdf; Ashlu CEMP - Rev J (contractors defined).pdf; Christine_Becker.pdf; Corporate CV_Ken.pdf; 090806_Resume_Long_MikeNelson.pdf
Hiall, FYI,asIdmentioned,IdrecentlynotednewbodiesactingasdelegatesatAshluandaskedMike(Cascade)forsome info. Inparticular,youmightwanttolookattheworkplanprovidedfortheEMroleonthisproject.Idbeinterestedin anycomments/concerns(lateastheymightbe)andthismightbehelpfulinyourreviewoftheBearEMworkplan andguidance/templatedevelopment. Thanks!

TimothyBennett,M.Sc.,P.Eng. SectionHead,WaterAllocation WaterStewardshipDivision MinistryofEnvironment
From: Mike Nelson [mailto:mnelson@cerg.ca] Sent: Tuesday, January 26, 2010 9:49 AM To: Bennett, Timothy A ENV:EX Cc: XT:Busto, Vince DFO EAO:IN; Robert Kulka Subject: RE: Clarification of EM staff (Ashlu - 2001264)
Tim, Pleasefindattachedforyourrecords: OurletterofEngagement:20090417AshluEnvironmentalMonitor.pdf TheCascadeEnvironmentalpreparedScopeofworkandworkplan:090310EnvironmentalMonitoring ProposalNCRev.pdf SignedscopeofInformationandreportbytheEM:090422ScopeofInformationandReportsbythe EnvironmentalMonitor.pdf ConstructionEnvironmental PlanAshluCENPRevJ(Contractorsdefined).pdf S22 ResumeforChristineBecker ChristineBecker.pdf ResumeforKenMcNamara:CorporateCVKen.pdf ResumeforMikeNelson:090806ResumeLongMikeNelson.pdf enolonginvolvedwiththeproject, S22 S22 S. 22 S22 Ken ,and
S22
Iwillendeavourtosignallremainingreportsemanatingfromouroffice,butIhavereadandreviewedeachreport sofar.AsnotedinourDecember731reportdatedJanuary14,2010,constructionhasbeensubstantially completed,andourmonitoringfromthispointforwardwillbelimitedtomonthlyinspectionsandwaterquality sampling(aspertheWaterQualityManagementPlan,Dec8,2009),untilMOEgrantsleavetooperateatwhich

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pointenvironmentalconstructionmonitoringwillbediscontinued,andtheOperationalEnvironmentalMonitoring Programwillbeimplemented. Itrustthisinformationmeetsyourinformationrequirements. Cheers,

MIKE NELSON, R.P.BIO. Principal Cascade Environmental Resource Group Ltd. Whistler and Squamish, BC | Whitehorse, YT | San Diego, CA nd Unit 203 - 38026 2 Avenue | Squamish | BC | Canada | V8B 0C3 TEL: 604 815-0901 | CELL: 604 815-9973 | FAX: 604 815-0904 mnelson@cerg.ca | www.cascade-environmental.ca
From: Bennett, Timothy A ENV:EX [mailto:Timothy.Bennett@gov.bc.ca] Sent: January-22-10 11:51 AM To: Mike Nelson Cc: XT:Busto, Vince DFO EAO:IN Subject: Clarification of EM staff (Ashlu - 2001264)
HiMike, Ivehadaquicklookoverourfileandcannotfindcopiesofsomeinformation. CouldyoupleasereforwardmeacopyoftheagreementfortheEMrole,andyourworkplanasspecified? http://www.env.gov.bc.ca/wsd/water_rights/waterpower/cabinet/appendix_h.pdf Couldyoualsopleaseconfirmwhoyourdelegatesare,ensurewehavecopiesoftheirCVsforour review/approval/filing,andthatallfutureEMreportsarereviewedandsignedbytheEM(you). Thankyou.

TimothyBennett,M.Sc.,P.Eng. SectionHead,WaterAllocation WaterStewardshipDivision MinistryofEnvironment 10470152Street,Surrey,BCV3R0Y3 Ph.(604)5825227 Fx.(604)5825235 Timothy.Bennett@gov.bc.ca
Page 401 FNR-2011-00265/ Part 1
CONSTRUCTION ENVIRONMENTAL MANAGEMENT PLAN
ASHLU CREEK GREEN POWER PROJECT
November 8, 2006
Revision J (updated with new contractor and emergency contacts)
Modified by Ledcor Power Inc.

Original prepared by Sigma Engineering Ltd. 1444 Alberni Street Vancouver, B.C. V6G 2Z4
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Ashlu Creek Construction Environmental Management Plan
Rev. J 08 Nov 06
Table of Contents 1.0 General Information...................................................................................................1 1.1 Project Description.......................................................................................... 1 1.2 Purpose of CEMP............................................................................................ 1 1.3 CEMP Procedures ........................................................................................... 1 1.4 Definition of Key Parties and Terms................................................................ 2 2.0 Project Information ....................................................................................................2 2.1. Project Components and Structures ................................................................. 2
2.1.1 2.1.2 2.1.3 2.1.4 2.1.5 2.1.6 2.1.7 2.2.1 2.2.2 2.2.3 2.2.4 2.2.5 2.2.6 2.2.7 2.3.1 2.3.2 2.3.3 2.3.4 2.3.5 2.3.6 2.3.7 2.4.1 2.4.2 2.4.3 2.4.4 2.4.5 2.4.6 2.3.7
2.2
Construction Activities.................................................................................... 3
Access Roads ..................................................................................................................... 2 Intake and Weir.................................................................................................................. 2 Tunnel ............................................................................................................................... 2 Powerhouse and Tailrace; Switchyard and Substation ......................................................... 2 Transmission Line.............................................................................................................. 3 Staging and Spoil Areas ..................................................................................................... 3 Construction Work Site ...................................................................................................... 3 Access Roads ..................................................................................................................... 3 Intake and Weir.................................................................................................................. 4 Tunnel ............................................................................................................................... 4 Powerhouse and Tailrace; Switchyard and Substation ......................................................... 4 Transmission Line.............................................................................................................. 4 Staging and Spoil Areas ..................................................................................................... 4 Construction Work Site ...................................................................................................... 5 Access Roads ..................................................................................................................... 5 Intake and Weir.................................................................................................................. 6 Tunnel ............................................................................................................................... 6 Powerhouse........................................................................................................................ 6 Transmission Line.............................................................................................................. 7 Staging and Spoil Areas ..................................................................................................... 7 Construction Work Site ...................................................................................................... 7 Access Roads ..................................................................................................................... 8 Intake and Weir.................................................................................................................. 8 Tunnel ............................................................................................................................... 8 Powerhouse........................................................................................................................ 8 Transmission Line.............................................................................................................. 8 Staging and Spoil Areas ..................................................................................................... 8 Construction Work Site ...................................................................................................... 9
2.3
Project Operation and Maintenance Activities ................................................. 5
2.4
Project Decommissioning Activities................................................................ 8
2.5 Technology, Equipment, Resource and Material Requirements ....................... 9 2.6 Land Requirements ......................................................................................... 9 2.7 Water Requirements........................................................................................ 9 2.8 Work Schedule................................................................................................ 9 3.0 Responsibilities..........................................................................................................9 3.1 Site Contact..................................................................................................... 9 3.2 Responsibilities for Obtaining Permits and Approvals ....................................10 3.3 Environmental Monitor ..................................................................................10
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4.0 Environmental Features ...........................................................................................10 4.1 Terrain ...........................................................................................................10 4.2 Vegetation......................................................................................................10 4.3 Aquatic Resources..........................................................................................11
4.3.1 4.3.2 4.3.3 4.3.4
4.4 Wildlife and Habitat .......................................................................................12 4.5 Socio-Economic .............................................................................................13 4.6 Archaeological and Heritage Resources..........................................................13 5.0 Potential Environmental Impacts..............................................................................14 5.1 Construction and Operations ..........................................................................14 5.2 Cumulative Impacts of the Project..................................................................17 6.0 Planning and Regulatory Requirements....................................................................17 6.1 Construction Windows ...................................................................................17 6.2 Sensitive Periods ............................................................................................17 6.3 Restricted Access Areas .................................................................................18 6.4 Regulatory Agencies ......................................................................................18 7.0 Environmental Protection, Mitigation and Compensation Measures .........................20 7.1 Construction and Operational Guidelines .......................................................20
7.1.1 7.1.2 7.1.3 7.1.4 7.1.5 7.1.6 7.1.7 7.1.8 7.1.9 7.2.1 7.2.2 7.2.3
Water Quality................................................................................................................... 11 Drainage and Surface Water ............................................................................................. 11 Groundwater use .............................................................................................................. 11 Fish and Fish Habitat........................................................................................................ 11
7.2
Reclamation and Re-vegetation ......................................................................24
Safety and People Management........................................................................................ 20 Fire Protection ................................................................................................................. 21 Fuelling, Fuel Storage, Equipment Maintenance and Spill Contingency............................. 21 Spill Contingency and Emergency Response Plan ............................................................. 21 Waste Management.......................................................................................................... 22 Materials Storage and Handling........................................................................................ 22 Concrete .......................................................................................................................... 23 Sedimentation and Runoff Control.................................................................................... 23 Initial Flushing of Tunnel/Penstock .................................................................................. 23 Vegetation Clearing ......................................................................................................... 24 Restoration....................................................................................................................... 24 Wildlife Protection/In-stream Works ................................................................................ 24
7.3 Archaeological Findings.................................................................................25 8.0 Environmental Monitoring and Incident Reporting ..................................................25 8.1 Environmental Monitor ..................................................................................25
8.1.1 8.1.2 8.1.3 8.1.4 8.2.1 8.2.2 8.2.3 8.2.4 8.2.5
8.2
Construction Monitoring Plan ........................................................................27
Qualifications and Responsibilities ................................................................................... 25 General Requirements ...................................................................................................... 25 Communications .............................................................................................................. 26 Work Standards................................................................................................................ 26 Routine ............................................................................................................................ 27 Construction Commencement Inspections......................................................................... 27 Activity Dependent Inspections ........................................................................................ 27 Routine Inspections.......................................................................................................... 28 Soil/Water Sampling ........................................................................................................ 28
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8.2.6 8.2.7 8.2.7 8.4.1 8.4.2 8.5.1 8.5.2 8.6.1 8.6.2 8.6.3
Rev. J 08 Nov 06
8.3 8.4 8.5 8.6
Emergency/Environmental Response - Non-compliance with Specifications ..31 Monitoring Documentation ............................................................................31
Tunnel Waste Rock Testing Requirements........................................................................ 29 Material Handling Procedure............................................................................................ 29 Tunnel Rock Sampling Intervals....................................................................................... 30 Written & Photographic ................................................................................................... 31 Environmental Incident Reporting .................................................................................... 32 Inspection Summary Report ............................................................................................. 33 Final Report ..................................................................................................................... 33 Restoration and Reclamation Activities ............................................................................ 33 Post-construction Monitoring Aquatic and Instream Habitat........................................... 34 Post-construction Monitoring Wildlife ........................................................................... 34
Reporting .......................................................................................................33 Post-Construction Monitoring ........................................................................33
Appendices
Project Development Schedule Project Area Footprint Maps Boundaries of License of Occupation
Right-of-Way Areas for License of Occupation (Sheets 1 to 4) Proposed Utilisation of Area B1 Site Layout Schedule A1 Schedule A2 Schedule A4 Schedule A6 Schedule A3 Schedule A5 Schedule A7
Spill Contingency and Emergency Response Plan Daily Environmental Inspection Report Halted Work Report Emergency Report List of Contacts
Emergency Response Numbers
Emergency Response Diagram
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1.0 General Information

A 49 MW run-of-river water power project (the Project) is proposed on Ashlu Creek (the Creek), located approximately 35 km north-west of Squamish, B.C. Ashlu Creek rises in the Tantalus Range of the Coast Mountains and flows in a south-east direction to meet the Squamish River approximately 20 km north-west of the Town of Squamish. It has a length of approximately 34 km and a drainage area at the stream's confluence with the Squamish River of approximately 324 km2. The powerhouse for the project is located on Ashlu Creek approximately 3 km upstream from its confluence with the Squamish River; the intake is 5.6 km further upstream. The proposed Project will operate as a run-of-the-river scheme utilizing the naturally occurring flows from Ashlu Creek. The Project was awarded an Electricity Purchase Agreement (EPA) from BC Hydro in November 2003 under BC Hydros Green Energy call for proposals. All federal and provincial approvals have been received for the Project.
1.1
Project Description
1.2
All projects constructed under a BC Hydro EPA must provide a Construction Environmental Management Plan (CEMP) as part of the pre-construction submission documents. This CEMP is also designed to meet the requirements of the Water Management Branch of the Ministry of Environment (formerly Land and Water BC Inc.) and Fisheries and Oceans Canada (DFO), and will provide guidance on specific actions and activities that will be implemented in order to decrease the potential for environmental degradation.
Purpose of CEMP
1.3
This CEMP includes processes and systems to ensure compliance during construction with all applicable laws, and describes measures to minimize, to the extent practicable, adverse environmental impacts associated with construction of the Project. It provides a prescription for completing on-site work in an environmentally sound way and a framework for discussing environmental issues at briefings with contractors. It is also designed to ensure that environmental aspects and impacts of the project will be identified, investigated and communicated to all relevant staff, contractors and regulatory authorities, and that responsibilities for environmental management are defined and understood. Any change in project design (location of works, scheduling, etc.) initiated by the Project Engineer or Civil Contractor will be discussed with the Environmental Monitor to identify any likely impacts that may result as consequence of the design modifications. Any impacts identified and mitigation measures required will be provided as an addendum to the CEMP and will be distributed to and discussed with the Contractor by the Owner and Environmental Monitor.
CEMP Procedures
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1.4
The following definitions refer to key parties or terms in the CEMP: Owner Civil Contractor Tunnel Contractor Environmental Monitor Independent Engineer Design Engineer NW Squamish DFO MOE MOF ILMB Ashlu Creek Investments Limited Partnership (Ledcor Power Inc. is the General Partner) Ledcor CMI Ltd. Frontier Kemper Constructers Inc. TRC Biological Consulting Ltd. (Tom Cleugh, R.P.Bio.) True North Energy (George Steeves, P.Eng.) Klohn Crippen Berger North-west Squamish Forestry Partnership Fisheries and Oceans Canada (Lower Mainland Branch) Ministry of Environment (Lower Mainland Branch) Ministry of Forests (Squamish Branch) Integrated Land Management Bureau (Lower Mainland Branch)
Definition of Key Parties and Terms
2.0 Project Information

2.1.1 Access Roads
2.1. Project Components and Structures

The existing Forest Service Road will be used to access all areas of the Project. The intake will be accessed via a new construction road (approximately 350m long) on either side of the Creek from the existing Forest Service Roads. The powerhouse, switchyard and tunnel portal areas will be accessed via a new road (approximately 100m long) off of the Forest Service Road. 2.1.2 The intake will comprise an approximately 3m high by 25m wide Bridgestone-type, inflatable weir. The weir will be adjustable to create a small head pond in order to enable the water to flow into the intake. 2.1.3 The weir will direct water into a sediment flushing channel and then into the shaft of a 4.08 metre diameter tunnel. The tunnel will be approximately 4,500m long and will transport the diverted water to the powerhouse. Where the tunnel daylights at the ground surface near the powerhouse, a steel penstock will be installed to transport the water from the tunnel to the powerhouse. 2.1.4 The powerhouse will be a steel-clad building measuring approximately 20m by 40m and will house three, horizontal Francis turbines, three 13.8 kV, synchronous generators, a Powerhouse and Tailrace; Switchyard and Substation Tunnel Intake and Weir
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control room, and all electrical control equipment. The tailrace will comprise an open channel and will transport the discharged water from the turbines back into the Creek. The switchyard and substation will be located in a fenced area measuring 20m by 35m and will be situated next to the powerhouse. The switchyard will house a step-up transformer (13.8 to 230 kV), 3 phase circuit breaker, disconnect switch, relaying protection, synchronising equipment, metering, substation grounding and transmission line terminal structure.
The exterior of the powerhouse and switchyard will be landscaped with natural vegetation and trees to minimise the visual impacts. 2.1.5 A new, 3km long, 230 kV transmission line will connect the powerhouse to the existing BC Hydro 230 kV transmission line. The new transmission line will be located alongside the existing Forestry Service Road in order to minimise the amount of tree clearing and new road construction. 2.1.6 Staging areas during construction will be located along the transmission line right-of-way on the Ashlu delta and next to the intake. Spoil from tunnelling activities will be used as road wearing course and any excess material will be hauled off site to the Upper Squamish Valley or to the abandoned rock quarry on Squamish Nation Indian Reserve IR11 near Mile 9. Topsoil clearing and spoils from localised excavations at the intake and powerhouse locations will be deposited at designated areas approximately halfway between the powerhouse and intake. 2.1.7 A temporary construction work site area is proposed to be located along the new transmission line right-of-way on the Ashlu delta. The work site is required for the Contractors office trailers, vehicle/equipment parking, construction supplies laydown area, fuel storage, and a batch plant for concrete preparation (if concrete is not purchased from a local supplier). Gravel aggregate borrow areas and a tunnel water settling pond will be located in a separate area on the delta that will be reclaimed as fish habitat once the borrow areas are completed. The size of the construction work site will be minimised to limit any impact to the delta, which is of value to grizzly bears in the area (MOE) and to fish for habitat (DFO). All of these areas are temporary and will be used during construction only; once construction has been completed, these facilities would be removed, with the exception of the gravel borrow pit reclamation. Construction Work Site Staging and Spoil Areas Transmission Line
2.2
2.2.1
Construction Activities
Access Roads
Any new access roads will be constructed using best construction and management practices, and will include ditching and drainage for tributary creek flow so that erosion and sedimentation to Ashlu Creek is minimised. Roads will be designed and
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constructed as per the BC Forest Practice Code standards and Forest Road Engineering guidelines. 2.2.2 At the intake, all in-stream work will be conducted in the dry and in isolation of flowing water during the Fisheries In-Stream Work Window or otherwise as approved by DFO. Cofferdams will be constructed upstream and downstream of the intake works to divert the Creeks flow around the intake excavation(s). The diversions will be designed to withstand the 20-year peak daily flow in the creek. 2.2.3 Tunnel construction will be performed by use of a tunnel-boring machine (TBM). Construction will start from the lower end of the tunnel near the powerhouse and proceed towards the intake. A near-vertical shaft will be constructed from the intake to connect to the tunnel. 2.2.4 At the powerhouse, excavation of the tailrace will also be done during the Fisheries InStream Work Window and will utilise best construction management measures to minimise erosion and sedimentation. For this work, no diversion dams will be required; the majority of the excavation will be completed prior to breaching the final portion of the tailrace channel to let the water into the excavation. Construction of the powerhouse, switchyard and substation will occur at any time, as they do not impact the Creek. 2.2.5 The transmission line right-of-way will parallel the existing Forest Service Road to the greatest extent possible to reduce tree and shrub clearing and construction of new roads through the Ashlu delta. Efforts will be made to preserve as many trees as possible along the transmission line corridor by trimming tree tops to prevent against accidental tree falls in the future. The areas around the poles will be revegetated with shrubs after their installation. 2.2.6 The powerhouse laydown area, located along the transmission line right-of-way, will be cleared and graded during clearing for the transmission line. The gravel borrow areas will be cleared in a manner to minimize any unnecessary tree felling. These areas will be graded to prevent any unnecessary runoff from directly spilling into the existing DFO fish enhancement channels and pools. The footprint of any gravel borrow areas will be minimised by first excavating to the maximum depth possible (i.e. to the water table) and then expanded laterally. Any gravel borrow areas will be developed such that they can be transformed into pools and interconnected to the existing DFO channels once construction has been completed. The tunnel water settling pond, also located in the DFO fish enhancement area, will be excavated with the purpose of reclaiming the pond for fisheries purposes once construction has been completed. For all work in the vicinity Staging and Spoil Areas Transmission Line Powerhouse and Tailrace; Switchyard and Substation Tunnel Intake and Weir
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of the DFO fish enhancement area, a 30m buffer adjacent to creeks and existing ponds will be maintained. The intake laydown area will be located in a previously logged area where existing access is present. The area will be cleared and the access road improved. Initially, spoil from tunnelling activities will be used as road wearing course to cover the Forest Service Road (between the Squamish River bridge up to the intake location) to improve its durability, especially during the winter. Afterwards, any excess material will be hauled off site to a designated area. Topsoil clearing and spoils from localised excavations at the intake and powerhouse locations will be deposited at the designated area(s) approximately halfway between the powerhouse and intake. Care will be exercised to avoid spoiling material in areas where tree replanting has occurred. 2.2.7 To develop the construction work site, tree clearing will be required, and some levelling of the ground surface is likely. Due to the gravel in the area, the work site should be relatively free draining, which will limit any entrainment of silt from surface runoff into the existing DFO enhancement channels and ponds located in close proximity. A new channel crossing will be installed directly upstream of the existing DFO bridge, using the existing 1.6m diameter culverts that were previously used by DFO to cross the channel or a new, temporary bridge. A minimum riparian set back of 30m from any existing channels (or dry channels) would be respected for tree clearing and ground levelling. Effort would be made to maintain existing trees in the proposed laydown area in between the various proposed construction facilities to maintain natural, visual buffers. The existing access road through the DFO enhancement area would be used as the principal access road for the construction work site. Excavations for gravel borrow material would be done with the long-term intent of turning these borrow areas into ponds for additional fish habitat in the area. The lateral extents of these ponds would be minimised to the extent possible by excavating the ponds to the greatest practical depth possible using conventional earthmoving equipment. Gravel will be excavated only as required. Construction Work Site
2.3
2.3.1
Project Operation and Maintenance Activities

Access Roads
The Owner will be responsible for maintaining the secondary access roads, which come off of the existing Forestry Service Roads, to the intake and powerhouse; the Forest Service Roads will continued to be maintained by NW Squamish who are responsible for road maintenance in Tree Farm License (TFL) 38. The Owner has entered into a Road Use Agreement with NW Squamish and the Ministry of Forests (MOF) for the roads.
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Ashlu Creek Construction Environmental Management Plan 2.3.2 Intake and Weir
Rev. J 08 Nov 06
Water levels at the intake will be controlled using an adjustable Bridgestone-type inflatable weir. The weir will be operated in a manner as to provide stable water in the head pond and flow into the intake during most flow conditions. At flows less than the design flow, the weir will be in the fully raised position, and a level control sensor at the intake will regulate turbine discharge in order to maintain the normal operating water level in the head pond. Minimum fisheries flows will be provided by an instream flow release (IFR) pipe located in the intake. During times when creek flows exceed the design flow, the additional flow will pass over the weir and into the bypassed reach; during intense flows, the weir will simply be deflated to allow all of the flow to pass unobstructed into the bypass reach. Sediments accumulating behind the weir freshet (typically May to July) by lowering gate(s) and allowing natural flows to move sediments accumulating in the intake will sediment flushing gate and pipe. will be flushed at regular intervals during the weir and/or opening the radial flushing the sediments into the bypass reach. Fine be flushed to the bypass reach using the
Maintenance work at the intake will include cleaning the trash rack of accumulated, water-borne debris (i.e. logs) on a regular basis. Regular maintenance of the air pump(s) for inflating the weir will also be carried out. Oil changes and regular maintenance of the back-up diesel generator, which is used for providing power to the air pump and any necessary lighting, will be performed; a permanent power supply cable may be installed from the powerhouse up to the intake which would negate the need for a diesel generator. The riparian area along the banks of the Creek will be replanted with trees and shrubs once construction has been completed as per DFOs fisheries authorization. 2.3.3 The tunnel will be inspected periodically throughout the life of the project, but not on an annual basis due to the time required to drain the tunnel and inspect along its entire 4.5km length. 2.3.4 Flows from the tunnel will pass through the turbines and discharge back into the Creek via the tailrace. An operator will visit the powerhouse as required to monitor operation. Visual inspection of the water in the tailrace and its discharge into the Creek will be part of the regular operation procedure. Synchronous bypass valves will be used in emergency situations (i.e. load rejection from BC Hydro) or during flow releases for recreational users to steadily decrease flows (ramping) into the tailrace while correspondingly increase flow release at the intake. Maintenance work at the powerhouse will include oil changes of the hydraulic pressure units, filter changes on the cooling water system, and oil and filter changes on the Powerhouse Tunnel
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lube/oil units. Regular inspections of the turbines and generators will be performed on a regular basis and any required maintenance will be carried out. The riparian area along the bank of the Creek and any cleared areas from construction activities that are not needed during operations will be replanted with trees and shrubs as per DFOs fisheries authorization once construction has been completed. 2.3.5 Trees located alongside and within the right-of-way of the transmission line will be inspected on an annual basis and be pruned or removed to ensure that the treetops will not contact the transmission cables. Danger trees alongside the right-of-way will also be monitored and removed if deemed necessary to protect against toppling. Visual inspections of open bottom culverts, which will replace the existing culverts in the Forest Service Road along the transmission line route, will be carried out to ensure that water is freely flowing through them. Shrubs will be planted along the transmission line right-ofway once construction of the transmission line is completed. 2.3.6 The powerhouse laydown area, located in the middle of the existing DFO enhancement channel area, will be decommissioned and replanted with trees and shrubs to return the area back to its original state. The area will be regraded to prevent runoff from directly spilling into the existing enhancement channels and pools. Any gravel borrow areas developed during construction, including the tunnel water settling pond, will be reclaimed as fisheries ponds and interconnected to the existing DFO channels. The intake laydown area will be replanted with trees and shrubs and any access roads required for construction will be reclaimed. Topsoil clearing and spoils materials, deposited from localised excavations at the intake and powerhouse locations, will be graded to minimise surface runoff. 2.3.7 Once construction is completed and operations begin, the temporary construction work site will be reclaimed. Any buildings or man-made structures (i.e. fuel tanks) would be demobilised from the site, and berms and other temporary earthworks would be levelled back to the natural ground shape. The culvert or bridge for the DFO channel crossing would be removed to return the channel to its previous form. Trees and shrubs would be replanted in cleared areas, and DFO, MOE and NW Squamish would provide input into maintaining any cleared areas, if required. The existing access road through the DFO enhancement area would remain. The riparian area of the ponds will be planted with shrubs. Any areas of mass wasting or erosion will be planted with long rooted legumes or grasses. The gravel borrow areas would be developed into ponds to provide additional fish habitat. Development work would include laying back the slopes to a stable angle of repose, replacing any previously stripped, surface organics in the base of the borrows, and connecting the ponds to existing channels to allow water to flood the borrow areas.
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Transmission Line
Staging and Spoil Areas
Construction Work Site
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The tunnel water settling pond would also be developed into fish habitat using similar methodology. Input from DFO would be solicited during this work.
2.4
2.4.1
Project Decommissioning Activities

Access Roads
Secondary access roads to the intake and powerhouse would be decommissioned according to the BC Forest Practice Code standards and Forest Road Engineering guidelines at the date of decommissioning, including the removal of any culverts. The main Forest Service Road, which is maintained by NW Squamish, would be exempt from the project decommissioning. Trees and shrubs would be planted along any decommissioned roads for stabilisation. 2.4.2 The inflatable weir and intake structure would be removed to restore a stable creek in the reach. Riparian vegetation in these areas replaced for decommissioning. 2.4.3 The tunnel portals would be plugged to ensure access into the tunnel is restricted. Signs would be placed at both ends of the tunnel to warn of a potential hazard. Any lengths of penstock and concrete anchor blocks would be removed and the area will be restored to its original grade with naturally draining material (or native material, if locally available) and replanted with trees and shrubs. 2.4.4 The powerhouse building, including the turbines, generators, and electrical control equipment, along with the switchyard and substation equipment would be removed. The powerhouse foundation and tailrace would be filled in with natural soil material from the area. Trees and shrubs would be planted and vegetation re-established in the area. 2.4.5 The transmission line and poles would be removed along the entire transmission line route. No additional planting is envisioned as natural vegetation would have reestablished itself along the route during the life of the Project from post-construction replanting. Any trees located within the transmission line right-of-way would not require trimming and would be allowed to grow to their natural height. 2.4.6 Decommissioning of the staging and spoil areas will take place immediately after construction has been completed. Staging and Spoil Areas Transmission Line Powerhouse Tunnel Intake and Weir
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2.3.7
Decommissioning of the construction work site will take place immediately after construction has been completed.
Construction Work Site
2.5
The proposed Project will be constructed using conventional construction techniques and equipment. Earthmoving equipment, such as excavators, loaders, bulldozers, graders and dump trucks, will be used for excavation and fill of overburden and ripable rock. Where possible, excavated material will be used for fill; the remainder will be hauled to designated spoil areas. Rock excavation for the foundations at the powerhouse and intake and for the tunnel portals will be performed by conventional drill and blast methods. Any in-stream work at the intake or powerhouse will be isolated from creek flows using cofferdams and diversions as required. Concrete for the intake and powerhouse would be cast in place. A batch plant will be installed close to the Project. No concrete will be poured within the creek perimeter without the work area being isolated. Wherever possible, local contractors and material suppliers will be used on the Project.
Technology, Equipment, Resource and Material Requirements
2.6
Tenure under the Land Act is required for the intake, tunnel, powerhouse, access roads, staging areas, spoil areas and transmission line. Land tenure has been granted for the Project by ILMB.
Land Requirements
2.7
A Conditional Water License is required for the diversion of water from Ashlu Creek for the purposes of power generation. The Conditional Water License has been granted for the Project by MOE.
Water Requirements
2.8
An updated construction schedule for the Project is shown in Appendix 1. The schedule includes construction of the intake, tunnel, powerhouse, switchyard, transmission line and access roads.
Work Schedule
3.0 Responsibilities
3.1
See Schedule A2, List of Contacts.
Site Contact
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The Owner has secured all applicable permits, licenses and approvals. The Contractor shall comply with the conditions of all permits, licenses and approvals (refer to Section 6 for details).
3.2
Responsibilities for Obtaining Permits and Approvals
3.3
The Environmental Monitor is a representative appointed by the Owner and Province to administer the environmental aspects of the Project. The Environmental Monitor will ensure that all construction activities are conducted in compliance with the guidelines presented in the CEMP. The Environmental Monitor will be present full-time on site during construction activities, will prepare inspection reports, and will liase with the Contractor, Owner and various federal and provincial regulatory authorities. The Environmental Monitor will have the authority to halt work if site conditions or actions by the Contractor represent a threat to the environment. Continuation of the work will only be approved when conditions detrimental to the environment have been rectified to the satisfaction of the Environmental Monitor and Owner. The Environmental Monitor is a key member of the inspection team and will report the findings of inspections to the Owner, MOE, DFO and MOF. The Environmental Monitor will be responsible for field communications with the Owner and Contractor. Environmental concerns are to be passed on to the Contractor for resolution between all affected parties. In the event of an environmental emergency, the Environmental Monitor will immediately notify the appropriate environmental agencies. The Environmental Monitor will be responsible for in-field communication with the public if environmental concerns due to construction activities are raised. The duties of the Environmental Monitor are outlined in the DFO Fisheries Authorization and MOEs Water Power handbook. The Owner will revise the CEMP to reflect any changes to project design. The changes will be communicated to the Environmental Monitor and Contractor.
Environmental Monitor
4.0 Environmental Features

4.1
The geology of the project area comprises a thin, surficial cover of glacial till over hard, durable plutonic rock (i.e. granodiorite). High cliffs of exposed bedrock are observed throughout the valley, and bedrock is exposed on the sides along the length of the Creek. Historic debris, rock slides and avalanches have occurred in several localised areas along the tunnel route.
Terrain
4.2
The vegetation and wildlife assessment conducted by Dunster and Associates in 2001 describes the vegetation within a 30 metre setback of Ashlu Creek. The lower elevation of the study area (<650 metres ASL) are found in the Coastal Western Hemlock Submontane Very
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Vegetation
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Wet Maritime biogeoclimatic subzone, while the upper elevations (650 to 1200 metres) fall within the Coastal Western Hemlock Southern Moist Submaritime biogeoclimatic subzone. The main tree species in the lower subzone are western hemlock, amabilis fir and western red cedar, with bigleaf maple and red alder in the riparian margins. The main tree species above 650 metres include western hemlock, amabilis fir, western red cedar and Douglas-fir, with Sitka spruce in moist, rich sites. The project is located entirely in the lower elevation (<650m) zone.
4.3
4.3.1
Aquatic Resources
Water Quality
Existing water quality of Ashlu Creek can be classified as pristine. There are no industrial, agricultural, or domestic sources of pollution above or within the Project affected area. However, silvicultural activities in the basin have possibly increased the magnitude and frequency of sediment input to the stream. Mining activities, located 2km upstream of the proposed intake and weir, have been abandoned since the late 1930s. Ashlu Creek rises in the Tantalus Range of the Coast Mountains and flows in a southeasterly direction to its confluence with the Squamish River, approximately 20 km north of the Town of Squamish. It is a fifth order stream with a length of approximately 34 km and a drainage area of 324 km2. The catchment area of Ashlu Creek at the proposed intake location is 295 km2. The mean annual flow in Ashlu Creek at the intake site is estimated to be 27.1 m3/s (per Knight Pisolds February 2004 report). As Ashlu Creek has been gauged intermittently since 1991; therefore flow records were synthesised from data obtained from a nearby Water Survey of Canada gauging station on the Elaho River. Lowest mean monthly discharges of 3 to 5 m3/s occur in winter (December to March), while highest mean monthly discharges of 60 to 65 m 3/s occur in the summer (June and July). These synthesised discharges were found to be representative based on the collected site data. 4.3.3 Minor groundwater seeps have been observed in local areas, and typically occur along the glacial till/bedrock interface. 4.3.4 The Ashlu Creek Aquatic Environmental Assessment Report (September 2002) and the Aquatic Environmental Addendum (April 2004) by Sigma Engineering describe the fish and fish habitat in detail. It is summarised in the following paragraphs. Reach 1 begins at Ashlu Creeks confluence with the Squamish River and extends up 2.8 km upstream to the upstream end of the double bridge island. This reach has a low gradient, highly productive side channels, and comprises primarily riffle habitat. Chinook, coho, chum, pink, and sockeye salmon, winter run steelhead, coastal cutthroat and rainbow trout, and Dolly Varden char were found in this reach. Fish and Fish Habitat Groundwater use 4.3.2 Drainage and Surface Water
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Reach 2 is the cascade section of the creek, with gradients ranging from 4 to 8%, several small falls, and riffle-chute habitat. It extends 2.7 km from the top end of the double bridge island up to the natural island in the middle of the Ashlu Canyon. This reach provides little to no spawning or rearing habitat due to the high velocity and minimal in-stream cover. An adult steelhead was found at the start of the reach at low flows in November 2001, and several smaller migratory fish were found at the top end of the reach at low flows in April 2002. A natural fish barrier is located in Reach 2 at approximately 0.8 km upstream of the double bridges; anadromous fish migration ends at the canyon. Reach 3 is located entirely within a vertical walled canyon from the natural island to the 6m high waterfall. The habitat is continual rapid-chute with many waterfalls up to 2m in height. In-stream cover is minimal and banks are steep, providing little overstream cover. No fish were located in this reach. Reach 4 has low gradient and good fish habitat, with a mixture of riffles, glides and pools, and abundant in-stream cover. It extends 6.5 km upstream from the 6m high water fall, past the proposed project intake, up near Pykett Creek. Several islands exist, creating side and back channels, and the substrate is primarily gravels and boulders. Numerous rainbow were caught on all sampling dates. Reach 5 extends from near Pykett Creek to 3.5 km upstream of the confluence of Tatlow Creek. It has similar habitat to Reach 4, with low gradient, abundant cover, a mixture of riffles, glides and pools, and several side channels. Fish were caught throughout the lower reach. Reach 6 is characterised by high velocities and steep slopes in a narrow, confined channel. It extends from Reach 5 up to the headwaters of Ashlu Creek. There is minimal cover in the reach, the flows are cascades and riffles, and the substrate is mainly bedrock and boulder. No fish were located in this reach. Steelhead fry were stocked in the upper reaches (Reaches 4, 5 and6) of Ashlu Creek by the Fisheries Branch of MoELP from 1978 to 1997, and residual populations of these steelhead/rainbow trout inhabit the reaches above the Ashlu Canyon.
4.4
Dunster and Associates and Sigma found little evidence of wildlife use along the riparian area of Ashlu Creek. There were no sightings of active game trails, pellets or recent clipping or browsing along the roads or in the forest. This maybe due to the narrow canyons and steep cliff sides that create barriers to ungulates and other large mammals, which may use the existing Forest Service Road as a more convenient and barrier-free travel corridor. The lack of recent bear sightings may be due to the fact that the bears are utilising the shrubs in the cutblocks higher up in the Ashlu Creek valley and moving down the valley later in the autumn when the salmon start to spawn in the Squamish River and in Reach 1 of Ashlu Creek. A wildlife consultant is currently been contracted (spring 2004) to advise the Proponent on the grizzly bear habitat and migration routes within the Project area. The results of this study will be
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Wildlife and Habitat
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incorporated into the planning of the construction work site area, located on the Ashlu flood plain. Sigma Engineering and TRC Biological Consulting provided follow-up reports on wildlife in 2004 and 2005.
4.5
A socio-economic study commissioned for the Project describes the regional economy and labour force distribution of the district. The Ashlu Creek project is located in the Squamish Lillooet Regional District, near the District Municipality of Squamish. The regional district covers the area from Squamish in the south, to Bralorne in the north and Lillooet in the east. The main industry in the Squamish area has historically been forestry, but the relative importance of this industry has declined in recent years. The proposed development falls within Crown Land designated as Tree Farm License 38, which is currently held by NW Squamish Logging Partnership (formerly owned by Interior Forest Products, or Interfor). The provincial government holds a current water licence on Ashlu Creek downstream of the proposed Project for the purpose of Conservation Construction Works. An active application for power generation purposes is held by private interests on a stream upstream of the Project. Ledcor Power Inc. holds the only active water license for power generating purposes on Ashlu Creek or any of its tributaries. No existing land tenures have been identified in the project area. One Mineral Claim (Gazdar No. 1) straddles Ashlu Creek downstream of the proposed intake location. A Mineral Reserve by Ledcor Power Inc. contains the project area between the proposed intake and powerhouse locations and provides for no staking, subject to conditions. Recreational use of the area includes whitewater kayaking. The Owner has consulted with the Whitewater Kayaking Association of BC and Transport Canada (formerly the Canadian Coast Guard) and has received authorization to develop the Project with sufficient mitigation measures to offset any perceived impacts by kayakers. An abandoned gold mine is located approximately 2.5 km upstream of the proposed projects intake and weir. The mine has been non-operational since the late 1930s and there are currently no indications that the mine will resume operations in the near future.
Socio-Economic
4.6
The discussion section of the Ashlu and Sigurd Creeks Traditional Use Study by First Heritage Consulting concludes that, There are users of the Ashlu and Sigurd Creek drainages, and it is likely that traditional use would be dependant on 1) resource availability and 2) access to the watershed Once the developments are established, rehabilitation of the impacted areas would minimise or eliminate any traditional use conflict in the area.
Archaeological and Heritage Resources
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No archaeological sites were found in the project area; however, monitoring of excavation activities near the powerhouse location is recommended due to the high potential for subsurface archaeological sites1.
5.0 Potential Environmental Impacts

5.1
The anticipated impacts to wildlife and habitat of construction and maintenance of the proposed waterpower project are summarised in Table 5.1-1. The potential impacts are rated according to the magnitude, severity, duration, frequency and reversibility of environmental impact. Magnitude is rated as L (low), M (medium) or H (high). Severity is rated as L (low), M (medium) or H (high). Duration is rated as S (short term) or L (long term). Frequency is rated as C (continuous) or O (occasional), and Reversibility is rated as reversible (R) or irreversible (I), depending whether it is either temporary or short term, or permanent or on-going. Table 5.1-2 outlines potential impacts of any accidents or malfunctions that may occur. Magnitude, severity and duration have also been rated as V (variable) for unplanned activities, depending on the nature and scope of the potential impact.
Construction and Operations
Section 6 of the Preliminary Field Reconnaissance of the Ashlu/Sigurd Creek Hydroelectric Projects by First Heritage Consulting
1
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Ashlu Creek Construction Environmental Management Plan Table 5.1-1 Potential Impacts of Planned Activities
Phase Pre-construction Activity Survey activities, geotechnical investigations Vegetation removal Habitat alteration and disturbance Disturbance from human & machinery activity Riparian and habitat alteration, erosion, sedimentation Riparian and habitat alteration, erosion, sedimentation Habitat alteration Habitat and some riparian alteration Entrainment of aquatic wildlife Intake structure & Weir Bypass reach Habitat loss Powerhouse Tunnel Transmission Line Effective habitat loss due to avoidance Habitat alteration Habitat alteration Potential Effects Magnitude L L L Severity L L M Duration S S L
Rev. J 08 Nov 06
Frequency O O -
Reversibility R R I
Construction
Development of diversion, intake, powerhouse Tunnel excavation Transmission line
There is low probability of serious or long-term environmental impacts as a result of survey and geotechnical activities. Clearing will be kept to a minimum, and areas will be re-planted immediately after construction. An erosion control plan will be followed. Project footprint is relatively small, so impacts will be localised. Avoidance of human/wildlife conflicts to be a priority with strict waste management of attractants (i.e. food) .to be enforced. Tunnel avoids surficial impacts. Clearing along right-of-way will be kept to a minimum, and areas will be re-planted immediately after construction. Debris traps and collection facilities will be designed to enable wildlife to escape, ensuring that any impacts are short term, reversible, and localised. Suitable instream flow for aquatic organisms will be determined. Intake site impacts will be localised, so will preclude the usage of only a small area for other purposes. Vegetate to screen view and noise where possible. Small area will be occupied.
Comments
L M
L M
S L
O C
R R
M M L L L L
M M L L L M
S L L L L L
O O O C
R I/R I R R R
Operation and maintenance
Tunnel will be underground and will daylight only at the intake and powerhouse.
Vegetation along right-of-way will regrow and treetops will be trimmed and maintained.
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Ashlu Creek Construction Environmental Management Plan Table 5.1-2 Potential Impacts of Accidents and Malfunctions
Phase Activity Potential Effects
Terrestrial and aquatic habitat degradation Terrestrial and aquatic habitat degradation Terrestrial and aquatic habitat degradation
Rev. J 08 Nov 06
Magnitude
V
Severity
V
Duration
S
Frequency
O
Reversibility
I/R
Comments
Construction/ Operation
Industrial waste and fuel spills
Fire Failure of sediment control measures
V V
V V
S S
O O
I/R R
Fire prevention and fire fighting measures will be in place to ensure risk of fire is minimised. Monitor and inspect erosion control measures frequently
The probability that spills will spread beyond the area of occurrence is low. Maximum fuel volume that will be stored on-site will be specified at a later date.
System failure head pond
Terrestrial and aquatic habitat degradation
System failure tunnel System failure powerhouse
Terrestrial and aquatic habitat degradation Terrestrial and aquatic habitat degradation Terrestrial and aquatic habitat degradation
V V
V V
S S
O O
R R
System failure transmission line
The project facilities will be designed in accordance with all applicable codes and standards. Failure of the head pond would result in release of water downstream but the volume of water in the head pond is too small to cause flood damage to the streambed or downstream installations. Failure of the tunnel could cause water to back up into the head pond. Failure of turbines will be mitigated with bypass (energy dissipating) valves. Failure of transmission line would cause a load rejection, which would be mitigated by using bypass valves on turbines to ramp flow slowly to minimise the effect of a fluctuating water level in the bypass reach and headpond.
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The effect on the environment by the Project, when combined with those of other existing or future planned projects and activities, is expected to be minimal. Current recreational uses in the area include white water kayaking, angling, hunting and camping. Most of the hunting and angling occur near the mouth of Ashlu Creek, and two camping sites are present near the confluence of the Squamish River and Ashlu Creek. These areas are downstream of the Project and are being considered for closure by MOE in the future. The Ashlu watershed lies within TFL 38. Past logging activities in the watershed have likely increased the magnitude and frequency of sediment input to the stream. No impacts on water quality are expected except for minor increases in turbidity during instream and near-stream construction in the short term.
5.2
Cumulative Impacts of the Project
6.0 Planning and Regulatory Requirements

6.1
In-stream construction activities are permitted in the following period: July 15 to September 15 Fisheries window for performing in-stream works at the intake and powerhouse (as defined by DFO)
Construction Windows
6.2
Construction activities will recognise the following sensitive periods for aquatic species and wildlife: April 1 to August 1 - Nesting season for migratory birds to be considered during vegetative clearing at the intake, powerhouse and along the transmission line route (as recommended by the Canadian Wildlife Service) April 1 to June 15 Grizzly bear spring emergence season to be considered during construction activities near the intake and powerhouse (by MOE from LRMP) November 15 to February 15 Bald eagle foraging/roosting period to be considered during construction activities near the Ashlu flood plain (by MOE) November 15 to April 15 Mountain goat migration period to highland areas near the proposed powerhouse to be considered during construction activities near the powerhouse and any construction access to the intake (by MOE) July 1 to September 30 Grizzly bear foraging season along lower Ashlu delta and Squamish River. Gravel extraction from delta to be avoided during this season (by MOE)
Sensitive Periods
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A pending restriction on access up the Ashlu valley from Mile 26 may be in effect by the time construction commences. This restriction would require a road closure from April 1 to June 15 on the Forest Service Road (the north road) as requested by MOE. The intake site and main construction access road are located just below Mile 26.
6.3
Restricted Access Areas
6.4
Federal, provincial, municipal or local acts or by-laws require applications, approvals or permits, including: Waste Management Permit (Effluent) (Waste Management Act, BC) The Contractor shall obtain appropriate permits to dispose of waste generated as a result of the construction activities. All wastes shall be removed from the site and disposed at an approved facility appropriate to the type of waste generated. Attractants (i.e. food waste) to be properly disposed of to prevent attraction of wildlife (i.e. grizzly bears) to the site and to avoid wildlife/human conflicts. Waste Management Permit (Air) (Waste Management Act, BC) The Contractor shall obtain a permit or approval, as required, for air emissions for any diesel generator. Waste incinerators will not be permitted on the project site during construction. Waste Management Permit and Approvals (Special Waste) (Waste Management Act, BC). Special Waste Regulations, B.C. Reg. 432/82 No storage or usage of special wastes shall be permitted on site. Approval of Potable Water (Health Act, BC) The Contractor shall obtain approval for the source and the distribution of a potable water supply, as required for the duration of the construction phase. Drinking water shall be provided at each workstation. Approval for Sewage Disposal (Ministry of Health, BC) The Contractor shall obtain approval for the handling and disposal of sewage wastes generated at the site during the construction phase. All sewage must be contained in portable construction outhouses and effluent facilities must be provided. Approval for the Storage of Fuel (Ministry of Municipal Affairs, Office of Fire Commissioner) The Contractor shall obtain approval for the storage of fuel greater than 22.5 litres or for storage tanks for diesel and oil (subject to variance of Section 5.1). Licenses for Explosives Magazines (Explosives Act, Canada) The Contractor shall obtain approval for explosive magazines required for storage of explosives. Final Inspection Certificate (Electrical Inspector)
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Regulatory Agencies
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Ashlu Creek Construction Environmental Management Plan The Contractor shall obtain this certificate during commissioning of the Project.
Rev. J 08 Nov 06
British Columbia Hydro / British Columbia Transmission Corporation The Contractor must notify BC Hydro of access, work and timing to be done under any existing power lines or new buried lines and across the right of way. The Owner is responsible for informing BC Hydro/BCTC of the interconnection of the Project to the existing grid. Water License Application (Ministry of Environment) The Owner is responsible for obtaining a water license to divert water for the Project. Application for Works In or About a Stream Section 9 of the Water Act Regulation Any work in and about a stream must have Federal and Provincial approvals prior to the work. The Owner shall obtain approval(s) and work with the Contractor to define the required work areas. Fisheries Act (Fisheries and Oceans Canada) The Owner shall obtain approval for activities that impact fish and fish habitat, including discharges of deleterious substances, and destruction of fish by any means other than fishing. Navigable Waters Protection Act (Transport Canada) The Owner shall obtain a permit for activities in, around, under or over navigable waters for commerce, transportation or recreation. Environmental Protection Act (Environment Canada) The Contractor will be responsible for ensuring environment and human health, toxic substances, water/air quality standards are upheld. Municipal Act and Regional and Municipal By-laws The Owner does not require temporary permits for construction or re-zoning for the Project. Heritage Conservation Act The Owner shall obtain approval to excavate or alter sites of archaeological or historical significance. Canadian Wildlife Act (Environment Canada) The Owner shall obtain permission for activities affecting wildlife and wildlife habitat in wildlife areas. License to Cut and Road Use (Ministry of Forests) The Owner shall obtain permits for clearing and removing trees and for access on the Forest Service Road(s). Mineral Claims (Ministry of Energy and Mines) The Owner shall establish a mineral reserve for the project area.
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Ashlu Creek Construction Environmental Management Plan The following provincial acts, regulations and guidelines will also be adhered to:
Rev. J 08 Nov 06
7.0 Environmental Protection, Mitigation and Compensation Measures

7.1
7.1.1
BC Fisheries Act BC Wildlife Act BC Environmental Management Act BC Land Act BC Pollution Control Act BC Transportation of Dangerous Goods Act BC Heritage Conservation Act BC Soil Conservation Act BC Forest Act BC Water Act BC Health Act Forest Fire Prevention Regulations, B.C. Reg. 557/78. Land Development Guidelines for the Protection for Aquatic Habitat (DFO and MoELP, 1992) Environmental Objectives and Procedures for Water Crossings (MoELP, 1984) Changes to the Guidelines for the Use of Explosives in or near Canadian Fisheries Waters (DFO, 2001) Freshwater Intake end-of-Pipe Fish Screen Guideline (DFO, 1995) for intakes Fish Screen Directive (DFO, 1999) for intakes Water Quality Criteria for Total Gas Pressure (MoELP, 1997) Canadian Environmental Quality Guidelines, Freshwater Aquatic Life, Winnipeg (Canadian Council of Ministers of the Environment, 1999) Approved and Working Criteria for Water Quality -1994 (MoELP, 1994) Guidelines for the Use of Explosives in or near Canadian Fisheries Waters (DFO, 1998) Species at Risk Act (Committee on the Status of Endangered Wildlife in Canada, 2003) Archaeological Impact Assessment Guidelines (Minister of Tourism and Minister Responsible for Culture, 1992)
Construction and Operational Guidelines

Safety and People Management
Safety and security controls will ensure safe working conditions and limit access to potentially dangerous areas by the general public. Contractors will comply with Workers Compensation Board regulations and Canadian Standards Association standards and codes. The Contractor shall effectively warn and protect the public from any danger as a result of the work being done, especially during blasting and tree felling.
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Ashlu Creek Construction Environmental Management Plan 7.1.2 Fire Protection
Rev. J 08 Nov 06
The potential for fire exists as a result of clearing and construction activities. Fire prevention and fire fighting measures will be outlined in the Spill Contingency and Emergency Response Plan to be developed by the Contractor to ensure that the risk of fire is minimised and that measures are in place to contain fires if they start. 7.1.3 1. Fuels, lubricants and hydraulic fluids for equipment used on site should be carefully handled to avoid spillage, properly secured to prevent unauthorised access, and provided with spill containment according to codes of practice. 2. All storage and handling of petroleum products and allied petroleum products be in accordance with the CCME Environmental Code of Practice for Above Ground Storage Tanks Containing Petroleum Products (1994). This applies to petroleum and allied petroleum products stored at the site during the construction phase of the project or as part of the permanent works. In addition, this applies to all temporary fuelling facilities. Due to the close proximity to fresh water streams, any on-site fuel storage will be contained in double walled storage tanks surrounded by a containment berm. No underground fuel storage will be permitted. 3. All work pertaining to the design of any above ground storage facility greater than 4000 litres capacity or any underground fuelling facility should be stamped by a qualified Professional Engineer. 4. All mobile equipment shall be fuelled from a properly equipped fuel truck. All portable equipment shall be fuelled from maximum 5-gallon containers provided with drip free spouts. 5. The Contractor shall inspect all construction equipment for leaks or worn hoses or fittings prior to access to site and on a regular basis thereafter. Leaks shall be fixed prior to continued equipment use on site. 6. No petroleum products, including fuel and oil, shall be disposed of on the site. Waste oil shall be contained and stored in approved containers. 7. The Contractor shall remove all used and unused fuel and oil, storage facilities, and any associated contaminated soils prior to completion of the work. 7.1.4 1. Within 15 days of Contract Award, the Contractor shall prepare and submit to the Environmental Monitor a Spill Contingency and Emergency Response Plan as further described in Schedule A1. Written Spill Contingency and Emergency Response Plan Fuelling, Fuel Storage, Equipment Maintenance and Spill Contingency
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authorisation to proceed with work will not be given by the Independent Engineer until the Environmental Monitor has received and reviewed the Spill Contingency and Emergency Response Plan. 2. The Contractor shall provide, at all times on-site, readily accessible spill response materials such as containment booms, absorbent sweeps and pads. 3. The Contractor shall periodically review the Spill Contingency and Emergency Response Plan for its appropriateness and shall ensure that all required response materials are on site and in adequate supply and their staff, including subcontractors are familiar with the requirements of the Plan. 4. In the event of a spill or emergency, the Contractor shall, at his cost, remove and appropriately dispose of (off-site) all waste and clean-up materials, equipment, and goods, including soils and water deemed to be contaminated by MOE or Environment Canada standards. 7.1.5 1. The Contractor shall secure permits for and manage, store, remove, and off-site dispose of all refuse generated at the site including construction, spill response, household and sewage wastes. Organic wastes will be stored in bear-proof containers. 2. The Contractor shall store construction waste in the Designated Spoil Area or within the boundaries as directed by the Independent Engineer, and shall remove all waste and unused materials from the site prior to the completion of the Work. 7.1.6 1. Prior approval of any spoil sites will be obtained from DFO and LWBC. 2. Stockpiles should be appropriately covered with coarse material to reduce wind and water erosion. 3. The Contractor shall exercise extreme care to prevent fly-rock entering any watercourse by employing such measures as stemming holes, providing padding material, or using blasting mats. Matting consisting of steel cables and/or rubber tires shall be used at all times. Waste rock shall be disposed of in Designated Spoil Areas or as directed by the Independent Engineer. No blasting will be done under water, or at a time with risk to fish. Any blasting will be completed within a tunnel or dewatered area of the immediate stream and any drainage will be collected and pumped to an up-land area. Materials Storage and Handling Waste Management
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4. On-site hazardous materials (i.e. fuels and lubricants) will be stored in appropriate containers and clearly labelled. MSDS sheets for each substance will be posted at all storage locations and will be appended to the CEMP. 7.1.7 1. Freshly cast concrete shall be isolated from flowing water for a minimum of 48 hours following the completion of the pour. 2. Wash down waters from exposed aggregate surfaces, cast-in-place concrete and from concrete trucks will be trapped on-site to allow sediment to settle out and reach neutral pH before the clarified water is released or allowed to percolate into the ground. 3. Raw or uncured waste concrete and grouts will be disposed of by removal from the development site. 7.1.8 1. The Contractor shall install sediment and erosion control devices such that run-off entering watercourses does not exceed background suspended solid levels by more than 25 mg/l during dry conditions and 75 mg/l during storm events as defined by DFO or MOE staff. 2. The Contractor shall be responsible for the continued effectiveness, maintenance and stability of erosion control devices. 3. The Contractor shall leave the zone of construction level, and free of ditches and hummocks. 4. The Contractor shall leave the zone of construction covered with a layer of organic material borrowed from the adjacent work area. Any branches from felled trees or other organic debris can be used to cover the zone of construction. 5. A tunnel water settling pond will be established to collect discharge water from tunnel construction prior to its release into the environment. The settling pond will be used to settle suspended particles out of solution, and to collect and remove grease and/or any oil from the discharge water. 7.1.9 The Contractor shall closely monitor the quality of the initial water discharge from the tunnel/penstock when the Project is ready for commissioning to ensure that the discharged water does not contain significant amounts of residual particulate matter from tunnelling activities, rust from the penstock, etc. A potential method to allow any particulate matter or rust to settle out prior to discharging the water into the Creek is to block off the tailrace discharge. Efforts will be made to avoid Initial Flushing of Tunnel/Penstock Sedimentation and Runoff Control Concrete
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the initial water discharge into the Creek during fish incubation and fry rearing periods; the preferred start-up period would be during freshet (May to August).
7.2
7.2.1
Reclamation and Re-vegetation

1. Clearing shall be kept to a minimum. 2. No clearing shall be carried out within 30m of any watercourse unless written authorisation to do so has been previously obtained from the DFO and/or the MOE. 3. Hand clearing shall be carried out on the banks of any watercourse and on all ground that has a slope in excess of 30%, and in any area where the Environmental Monitor shall so direct. 4. Trees shall be felled away from watercourses and standing timber. 5. Cleared debris (defined as non-merchantable timber) shall be limbed in designated areas. The trunks can be used for erosion control. Vegetation Clearing
7.2.2
1. The Contractor shall clean-up all construction areas including removal of equipment, wastes, construction materials, fuels and fuel storage facilities, temporary buildings, fencing, boundary markings, construction mitigation facilities, etc. prior to completion of the Work. 2. The Contractor shall grade and contour any disturbed areas to promote drainage and conform to adjacent topography prior to completion of the Work. 3. The Contractor shall be responsible for leaving the site in compliance with all Acts and Regulations including site runoff conditions and quality. The Contractor shall re-vegetate equipment areas, access roads, and any other disturbed areas with a suitable mixture of rapidly growing grass, legume and woody species. All disturbed stream banks shall be stabilised and re-vegetated with native species. Steep slopes must be stabilised to ensure safety and erosion control. The Contractor will liase with the Environmental Monitor for techniques to be used for erosion control.
Restoration
7.2.3
1. In-stream work shall be carried out in accordance with the required permits, licenses and approvals. The Owner is responsible for obtaining an Approval for Work in and about a Stream from the MOE and/or DFO where applicable.
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Wildlife Protection/In-stream Works
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2. Stream-bank vegetation shall be retained in accordance with the Land Development Guidelines. Where not possible, banks shall be protected from erosion. 3. Activities will be scheduled to avoid sensitive periods and clearing will be kept to a minimum. 4. Effective habitat loss due to avoidance will be mitigated by using vegetation to screen project components.
7.3
Should the Contractor discover any unpredicted archaeological finds during the course of construction, the Contractor shall, in accordance to the Archaeological Impact Assessment Guidelines (1992), cease construction activities in the affected area immediately and notify the Environmental Monitor. Work in the area shall be suspended pending investigations and recommendations by a qualified archaeologist retained by the Owner.
Archaeological Findings
8.0 Environmental Monitoring and Incident Reporting

8.1
8.1.1
Environmental Monitor
The Environmental Monitor is a representative appointed by the Owner and MOE to administer the environmental aspects of the Project. The Environmental Monitor will be an appropriately qualified professional with knowledge and experience in monitoring construction works. The Environmental Monitor must be approved by the regulatory agencies (DFO, MOE). The Environmental Monitor will be on site full-time during construction activities, prepare weekly inspection reports and liase with the Owner, Independent Engineer, MOE, DFO and Contractor. The Environmental Monitor will have the authority to halt work if, in his opinion, site conditions or actions by the Contractor represent a threat to the environment. He will approve continuation of the work only when conditions detrimental to the environment have been rectified. The Owner will provide a letter authorising that the Environmental Monitor has permission and authority to halt work, and this letter will be forwarded to the appropriate regulatory agencies.
Qualifications and Responsibilities
8.1.2
General Requirements
To inspect the Work for compliance with all relevant federal and provincial environmental regulations during the Project.
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To identify and assess conflicts between the construction activities and environmental features. To identify, monitor and report any situations of on-going or potential damage to the environment.
To recommend to the Contractor(s) additional mitigation measures should project activities have the potential to damage the environment. To inform the Owner and Independent Engineer, as well as environmental agencies, of environmental issues which arise during the construction phase. 8.1.3 Communications To monitor compliance with BC Hydro Green Criteria.
The Environmental Monitor is a key member of the inspection team and will report the findings of inspections to the Owner and Independent Engineer.
The Environmental Monitor will be informed of any revisions or changes to the construction specifications or design through the Independent Engineer.
The Environmental Monitor will inform the Owner and Independent Engineer of any proposed field modifications to the design or the environmental specifications. The Environmental Monitor will be responsible for field communications with the Owner and Independent Engineer. Environmental concerns are to be passed on to the Engineer for resolution between all affected parties.
In the event of an environmental emergency, the Environmental Monitor will immediately notify the appropriate environmental agencies. The Environmental Monitor will maintain liaison the DFO and MOE throughout the construction phase of the project.
8.1.4
Work Standards
The Environmental Monitor will be responsible for in field communication with the public if environmental concerns due to construction activities are raised. The Environmental Monitor will attend pre-construction meetings. The Environmental Monitor may also be requested to: i. Answer questions, concerns or complaints that may arise as a result of the construction activities.
ii. Participate in public meetings involving assigned projects.

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The Environmental Monitor will provide specialist recommendations to the Contractor on a site-specific basis if such work, in his/her opinion, is threatening or may threaten an environmentally sensitive area. In such a case, the Environmental Monitor will provide procedures to continue construction in a sound environmental manner. The Environmental Monitor, being an integral part of the inspection team which inspects Contractor activities for compliance with the Contract Specifications, will have the authority to initiate the stop work procedure. The Environmental Monitor will be required to take soil or water samples either as part of routine construction monitoring activities or as a result of an environmental emergency.
iii. Participate in the training of contractor staff on environmental issues.
8.2
8.2.1
Construction Monitoring Plan

The Environmental Monitor will inspect the Work for compliance with the Contract Specifications, including environmental specifications, proposed construction mitigation measures, all relevant federal and provincial environmental regulations concerning the project and the BC Hydro Green Criteria. 1. Prior to any site works, the Environmental Monitor, together with the Owner, Independent Engineer and the Contractor, will review sitespecific environmental requirements and areas of potential concern. 2. Prior to construction, the Environmental Monitor will meet with the Contractor to identify site-specific environmental requirements and areas of potential concern. 3. The Environmental Monitor will review the marking-off of any sensitive areas in advance of nearby construction activities. The Environmental Monitor will be responsible for inspection and monitoring of key construction activities such as all in-stream work. These activities will include, but are not limited, to the following as well as any others identified by the Environmental Monitor, Owner, Independent Engineer, and/or review agencies during the course of construction: Waste rock disposal Stream diversions Activity Dependent Inspections Construction Commencement Inspections Routine
8.2.2
8.2.3
Any other activities that are in the wet or within 30m of watercourses.
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Ashlu Creek Construction Environmental Management Plan Activity dependent inspections will include, but not be limited to, inspection for compliance and the contract specifications. 8.2.4
Rev. J 08 Nov 06
1. The Environmental Monitor will conduct inspections while construction activities are occurring at the site. Inspection/supervision will include all construction work, pits, excavations, waste areas, access roads, and other project structures. The inspection will include, but not be limited to, the following: o o o o
Routine Inspections
Inspection of the past work carried out for compliance with the Contract Specifications and Environmental Specifications. Inspection of construction area for signs of environmental spills or emergencies. Inspection of disturbance. sensitive and no construction areas for
Inspection of the markers used to fence off sensitive and no disturbance areas, as well as inspection of Spill Response equipment to ensure sufficient supply and appropriate type of supplies. Inspection of disposal and containment of food waste and other potential attractants to prevent attracting wildlife to the job site and avoiding potential wildlife/human conflicts. Inspection of the construction equipment for leaks.
o o
8.2.5
2. Any items not specified (regulation or other compliance) will be documented by the Environmental Monitor. The Independent Engineer, Environmental Monitor, and Contractor will resolve the issue at hand as soon as possible. The Environmental Monitor will submit a brief report to the Owner and Independent Engineer for the records. Soil/Water Sampling
1. In the case of an environmental emergency, the Environmental Monitor shall collect soil and/or water samples where and as applicable and if safe to do so. Physical parameters (turbidity, pH, temperature, and dissolved oxygen) will be measured in-situ. Further sampling may be requested by regulatory agencies. 2. Samples shall be sent to an accredited analysing laboratory as soon as practicable. Monitoring parameters include: o o Suspended solids, un-ionized ammonia, nitrates, nitrites, pH, oils & greases, COD for any drilling, blasting, excavation Suspended solids (turbidity) for any work in streams
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Suspended solids, pH for any aggregate processing, concrete production Gasoline, diesel, oil for any fuel, oil, hazardous waste spills
3. The Environmental Monitor shall be present for and inspect the environmentally sensitive activities (i.e. working near streams). 8.2.6 Tunnel Waste Rock Testing Requirements
1. All excavation rock generated by tunnelling during construction should be concurrently monitored for the presence of sulphide mineralisation and/or low bulk neutralisation potential. Monitoring should comprise identification of rock units, in-field estimation of sulphide mineral content and in-field semi-quantitative estimation of carbonate content by HCl (hydrochloric) acid testing. Any excavated rock with geological/geochemical characteristics that vary significantly from the samples tested during the 2003 sampling program (see Rock Geochemistry and Rock Leachate Chemistry Report, by David Yeager, May 28, 2004) should be laboratory tested for Acid-Base Accounting (ABA), trace element geochemistry and the BC Ministry of Energy and Mines (BCMEM) Shakeflask leachate chemistry. 2. In addition, confirmation of laboratory testing of representative samples of excavated rock should be performed on a regular basis to confirm the field monitoring assessment of rock chemistry. This testing should comprise ABA, trace element geochemistry and BCMEM Shakeflask leachate chemistry.
8.2.7
1. The most common causes of costly drainage chemistry mitigation requirements in the mining industry have been: Inadequate excavation rock geochemical characterisation, and Failure to segregate rock units having different geochemical and drainage chemistry characteristics. 2. These circumstances have often led to the situation where a relatively small volume of rock with poor quality drainage chemistry has been indiscriminately mixed with a large volume of benign rock, resulting in unnecessarily costly mitigation measures because of the large overall volume of rock that must be mitigated. The excavation rock handling and storage procedures of the Project should be designed to avoid these circumstances. It is recommended that a separate waste rock storage area be planned in the event that any excavated rock is identified that has the potential to create unacceptable drainage chemistry.
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Material Handling Procedure
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3. Recommendations for adequate evaluation of the excavation rock have been presented in Section 8.2.6. The inspection and sampling of excavated rock can be done in two ways: indirectly, by observing washed down faces of the freshly mined underground workings, or directly, by observing the excavation rock at the primary surface storage location. The indirect observation of the tunnel faces has the advantage of being able to observe the geology of the rock units with much clarity. However, if the assessment of rock chemistry is made underground, then the subsequent relocation of the excavation rock through the various stages of movement from the working face to its location in the surface storage area requires a considerable level of accounting effort. This often results in less than accurate records of the location of masses of excavation rock of specific chemical characteristics. It is a much better practice to evaluate and, if necessary, sample the excavation rock in a surface storage location where it is not likely to be moved to an unrecorded location before the evaluation is complete. It is recommended that the evaluation of excavation rock be performed at the primary surface storage location. 4. A material handling procedure should be developed that will allow for the lag time in assessment and possible sampling and laboratory testing of any excavation rock that appears to have potential to create unacceptable leachate chemistry. Any excavated rock so tested should not be covered by the next layer of excavated rock nor used for construction until the results of testing have been received by the Environmental Monitor and any potentially problematic rock has been segregated to allow for suitable long term storage. This general procedure will eliminate any costly and unnecessary multiple handling of poor drainage chemistry waste rock while allowing adequate time for its evaluation. 8.2.7 1. Samples should be taken on approximately 100m linear intervals during tunnelling or when significant changes in the host rock geology are observed in the tunnel. Samples would be taken from the waste material exiting the tunnel and not at the face of the tunnel for safety reasons. Tunnel Rock Sampling Intervals
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Ashlu Creek Construction Environmental Management Plan 2. A spray of the waste piles prior to being transported to their permanent storage site would remove any coating (i.e. dust) and expose the rock. 3. An HCl test for carbonates would be done on the samples on site to evaluate their acid neutralisation potential.
Rev. J 08 Nov 06
8.3
Emergency/Environmental Response - Non-compliance with Specifications
1. The Environmental Monitor will inspect the Contractors activities for noncompliance with environmental specifications.
2. The Environmental Monitor will, as the first step after identifying noncompliance, notify the Independent Engineer and Owner. If the noncompliance is not rectified and the significance of the non-compliance warrants it, the procedure to halt construction will be initiated. 3. The Environmental Monitor can also request the halt work procedure be initiated if: Construction activities unexpectedly and environmentally sensitive areas or features; significantly
affect
An environmental emergency has occurred or has the potential to occur if activities continue unmodified; A government agency has ordered the work halted.
8.4
8.4.1
Monitoring Documentation
1. The Environmental Monitor will be responsible for documenting and maintaining a detailed record of all public liaison activities including discussions, letters and meetings. 2. The Environmental Monitor will be responsible for documenting and maintaining a detailed record of all communication and correspondence with the Independent Engineer, other Site Inspectors and Contractor including discussions, letters, and meetings. 3. The Environmental Monitor will be responsible for developing and maintaining a detailed record of items inspected and recommendations made, if any. 4. The Environmental Monitor will be responsible for developing and maintaining a colour photographic record of construction activities, mitigation measures, environmental emergencies and halted work. Written & Photographic
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5. The Environmental Monitor shall submit a report if work is halted. The report will include items listed in Schedule A5. 6. For each day of site inspection, the Environmental Monitor will chronologically detail the events and discussions of the day by completing a Daily Inspection Report (see Schedule A3) including: a) b) c) d) e) f) 8.4.2 g) Dates, times, locations Weather conditions Inspection activities
Construction activities observed Discussions, meetings, and recommendations Concerns and follow-up actions required. Visitors to the Site
If work is halted, the Environmental Monitor shall submit a report to the Owner and Independent Engineer and relevant review agencies. The report will include:
Environmental Incident Reporting
a. Details of the events leading to the halting of work including date, time, location, staff involved, construction activities undertaken. b. Reference to the specific section of Technical or Environmental Specifications, required mitigation measure or environmental regulations that prompted the Work to be halted. c. Features of the environment that were of concern or at risk. d. Extent of environmental effect or damage incurred, if any.
e. Details and analysis of any samples taken in conjunction with the halted work. f. Remedial and due diligence actions undertaken by the Environmental Monitor, other Inspectors, the Contractor, the Owner and agencies.
g. Independent Engineer actions and communications. h. Other Site Inspector actions and communications. i. j. Contractor actions and communications. Agencies notified and their actions taken.
k. Details of how the issue(s) was (were) resolved and steps taken to clean up the emergency. l.
Detailed colour photographic record of issue area during and postemergency.
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8.5
8.5.1
Reporting
A Weekly Inspection Summary Report will be submitted to the Owner, Independent Engineer and DFO. A copy of all written documentation and records of verbal communication will be submitted as part of this report. The weekly report will also include:
Inspection Summary Report
a. General progress of the Project with special emphasis on work in environmentally sensitive areas.
b. Routine mitigation measures being used and monitoring of mitigation effectiveness.
8.5.2
c. Environmental concerns encountered, recommendations made, and new mitigative measures taken (if any), including a list and record of all parties notified of any changes. A Final Report will be prepared by the Environmental Monitor for submission to the Owner, Independent Engineer and DFO, and will include: Final Report
a. Summary of all work in environmentally sensitive areas, including procedures used, and success of the procedures. b. Routine mitigation measures used and mitigation effectiveness. c. Explanation of all design changes implemented for environmental reasons and/or recommended design changes.
d. Summary of environmental concerns encountered, new mitigative measures taken, and comments on avoiding these concerns on future project phases. e. A summary of all correspondence and communication government agencies, the public and the Contractor. f. with
g. Colour photographic histories of work in environmentally sensitive areas, with emphasis on mitigation measures, environmental concerns encountered, and design changes.
A copy of all reports for halted work or environmental emergencies.
8.6
8.6.1
Post-Construction Monitoring
The Environmental Monitor will detail all standards and best practices that were used in the site restoration and reclamation, and their effectiveness. As well, the Environmental Monitor will:
Restoration and Reclamation Activities
document the restoration and reclamation activities, events and milestones;

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detail any difficulties encountered in the mitigation of fish and wildlife habitat impacts, and how they were managed; and
8.6.2
As per MOE, Environmental Monitoring Report Format for In-stream Works, and in agreement with DFO: A 5-year study of all in-channel and riparian habitat restoration works at the intake and powerhouse, including the bypass reach, and along the transmission line route will be performed. An assessment of the effect of the minimum flow in the bypass reach will be part of this scope of work. A 5-year, post-construction follow-up assessment of aquatic and riparian habitat restoration works in the enhancement channel will be monitored with help from a known Stewardship Society. The Environmental Monitor will keep a detailed chronological account of actual assessment and maintenance activities, events and milestones for each year
Post-construction Monitoring Aquatic and Instream Habitat
detail all outstanding issues/conditions, and timelines for completion and reporting.
The Environmental Monitor will detail any difficulties encountered in the maintenance or performance of restoration works and how they were managed Any outstanding issues/conditions and timelines for completion and reporting will be detailed. The Environmental Monitor and the Owner are responsible for ensuring that all outstanding issues are dealt with. Further site specific activities may be added pending review. 8.6.3 As per Environment Canada/Canadian Wildlife Services recommendations: A one-year, post-construction follow-up study of pair and brood Harlequin Ducks will be performed. Based on the results of the study, the Environmental Monitor and Owner will consult with the Canadian Wildlife Service to determine the need for further studies. Post-construction Monitoring Wildlife
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Appendices
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Development Schedule
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Project Area Footprint Maps
Boundaries of License of Occupation Right-of-Way Areas for License of Occupation Proposed Utilisation of Area B1
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Schedule A1
Spill Contingency and Emergency Response Plan Guidelines
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SPILL CONTINGENCY AND EMERGENCY RESPONSE PLAN

1. Prior to construction commencement, the Environmental Monitor shall review the Spill Contingency and Emergency Plan the Contractor has prepared specific to their construction activities, location of construction areas, and equipment to be used. The Contractor shall provide sufficient and appropriate spill response equipment such as absorbent pads, oil booms, empty oil drums etc. During the pre-construction briefing of Contractor staff, the Contractor will review and summarise its Emergency Response Plan. The Contractor shall ensure that the Emergency Response Plan and the emergency contact numbers are visibly posted in a number of key locations throughout the construction area for the duration of construction activities. In the event of an environmental emergency, the Environmental Monitor will ensure the Spill Contingency and Emergency Response Plan prepared by the Contractor are being followed. Response steps are: a) b) c) Ensure safety of personnel, and the general public, and protect other dangerous site materials Stop flow or stabilize/control the emergency Secure the area - limit access to only those involved in control or cleanup.
2. 3.
4.
d)
Contain the emergency (spill). The Contractor may consult the Environmental Monitor for specialist guidance with respect to: Protecting the surrounding environment (i.e. contain/control the emergency if possible) Ensuring due diligence on the part of the Environmental Monitor and the Contractor.
e)
If possible this will be done in consultation with the General Contractor.
Report the emergency to the Provincial Emergency Program (PEP) (1-800-663-3456) if quantities warrant PEP notification.
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Substance
PEP Notification (1-800-663-3456)

>100 litres onto soils Any amount off-site > 1 litre > 5 litres 200 litres 5 litres Amount
PEP Notification DFO & MOE PEP
Flammable liquids Special Waste and Oil
Any amount to water
Miscellaneous (oil with PCB >50ppm) corrosive (class 8) Hazardous antifreeze
PEP PEP PEP PEP
Other Substances
f)
5.
g) Take Samples. The Environmental Monitor will take samples for analysis, as appropriate and as instructed by the Owner and/or regulatory agencies, prior to and post-clean-up.
Clean-up as appropriate. In consultation with the Environmental Monitor, the Owner and the appropriate regulatory agencies, the Contractor shall remediate the environmental emergency (i.e. clean-up). The Contractor will be responsible for disposal of clean-up materials, equipment, and contaminates liquids or solids (soils), in accordance with MOE and DOE requirements.
If the Environmental Monitor is not at the site at the time of an environmental emergency, the Environmental Monitor, once notified, will visit the site as soon as transportation can be arranged. The Environmental Monitor will then continue with on-site Spill Contingency and Emergency Response Plan monitoring. After clean-up, the Environmental Monitor will prepare a detailed report concerning the environmental emergency including: a) b) c) d) e) f) Details of the events leading to the environmental emergency including date, time, location, staff involved, construction activities undertaken and weather conditions. Details of the type, quantity, area of spill. Details of the extent and nature of the damage.
6.
Any samples taken including methodology and analytical results.
Containment and due diligence actions undertaken by the Contractor, Environmental Monitor and relevant regulatory agencies.
Features of the environment which were of concern.
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Ashlu Creek Construction Environmental Management Plan g) h) i) j) l) 7. Chain of communication or notification.
Rev. J 08 Nov 06
Environmental Monitor actions and communications. Contractor(s) staff actions and communications. Agencies notified and their actions taken.
k)
Refer to the Emergency Report Summary attached.
Detailed colour photographic record of during emergency and after cleanup.
Remedial actions for clean-up of the emergency and the site.
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Rev. J 08 Nov 06
Schedule A2
List of Contacts
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Owners Representative .............................................................................. Scott Lyons Senior VP, Ashlu Creek Investments Limited Partnership 604-699-2836 Kelly Boychuk Project Manager, Ashlu Creek Investments Limited Partnership 604-699-2859
LIST OF CONTACTS
Environmental Monitor............................................................................... Tom Cleugh TRC Biological Consulting Ltd. 604-464-5045 Independent Engineer ......................................................................True North Energy George Steeves 416-452-4715
Civil Contractor.................................................................................. Shane Yamamoto Site Superintendent, Ledcor CMI Ltd. 604-898-5746 (site office) Site Safety Program .......................................................................... Shane Yamamoto Site Superintendent, Ledcor CMI Ltd. 604-898-5746 (site office) Tunnelling Contractor ...........................................Frontier Kemper Constructors Inc. Dave Rogstad 206-766-8106 Squamish First Nation...................................................................................Dale Harry Councillor 604-892-4140
Project Engineer ...................................................................................... Dan Campbell Klohn Crippen Berger Ltd. 604-251-8463
Northwest Squamish Logging Partnership .................................... Chief Bill Williams President 604-980-4553 REGULATORY AGENCIES
Fisheries and Oceans Canada (DFO) ........................................................ Vince Busto Fisheries Officer, Lower Fraser River Branch 604-666-8281 Murray Gilchrist Field Supervisor, Conservation and Protection, Squamish Office 604-892-3230
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Rev. J 08 Nov 06
Ministry of Environment........................................................................ Steve Rochetta Habitat Protection Officer, Lower Mainland Region 604-898-3678 Bob Herath Acting Section Head, Water Stewardship - Lower Mainland 604-582-5218
Matt Foy Senior Biologist, Habitat Management Branch 604-666-3678
Ministry of Forests .............................................................................. Mick McKechnie Engineering Officer, Squamish Forest District 604-898-2139
Canadian Wildlife Service ................................................................ Andrew Robinson Environmental Assessment Officer 604-940-4685 Transport Canada ............................................................................. Jim Schellenberg Navigable Waters Protection Officer 604-775-8896 Ministry of Tourism and Culture......................................................... Steven Acheson Project Officer, Archaeological Branch 604-356-4439
Stuart McDonald Compliance & Enforcement Technician, Squamish Forest District 604-898-2103
Integrated Land Management Bureau...................................................David Ingleson Land Officer 604-586-4453
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Schedule A3
Daily Environmental Inspection Report
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Daily Environmental Inspection Report

Date: _____________________ Weather: __________________ Time Project: Ashlu Creek Green Power Project Monitor: _____________________
Activities, Discussions, Recommendations
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Schedule A4
Emergency Report
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Emergency Report
(See Section 5.2)
Date of Incident: ____________________________________________ ____________________________________________ ____________________________________________ ____________________________________________ ____________________________________________
Time of Incident:
Location of Incident: Weather Conditions: Monitor:
Incident Description/Cause:
Affected Environmental Features:
Remedial Actions:
Notifications:
Personal Involved:
Samples Taken: Yes / No (If Yes, then provide details, analysis)
Photographs Taken: Yes / No
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Rev. J 08 Nov 06
Schedule A5
Halted Work Report
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Rev. J 08 Nov 06
Halted Work Report

(see Section 5.2)
Date of Incident: ____________________________________________ ____________________________________________ ____________________________________________ ____________________________________________ ____________________________________________
Time of Incident:
Location of Incident: Weather Conditions: Monitor:
Events Leading to Order:
Non-compliance with:
Environmental Features at Risk/Damaged:
Notifications:
Personal Involved:
Resolution:
Photographs Taken: Yes / No (if Yes, list photos with description on separate page)
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Schedule A6
Emergency Response Diagram
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Rev. J 08 Nov 06
EMERGENCY RESPONSE DIAGRAM Ensure Safety
Stop the flow
Secure the area
Contain the spill
Notify Environmental Monitor
Notify PEP 1-800-663-3456
Clean up
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Schedule A7
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Emergency Vandalism, serious accidents Serious Injury Hazardous Discharge Hazardous Discharge into Stream or Wildlife Kills Hazardous Chemical Oil Spills Erosion, Sediment Release Forest Fire Agency RCMP, Squamish (air lift/hospital) Squamish Hospital Fisheries and Oceans Canada Ministry of Environment Environment Canada Provincial Emergency Program (PEP) Squamish Fire Department Number 604-892-6100 Sergeant Cheryl Armstrong 911 604-892-5211 1-800-465-4336 1-800-663-9453 1-604-666-6100 1-800-663-3456 604-898-9666
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From: Sent: To: Cc: Subject: Attachments: Robert Kulka [RKulka@innergex.com] Monday, October 18, 2010 11:02 AM Bennett, Timothy A ENV:EX Busto, Vince; Knight, Francesca; Stoddard, Erin M ENV:EX; Babakaiff, Scott C ENV:EX FW: May 8 Ashlu stranding report FINAL (Water file 2001264) Ashlu Fish Stranding Incident Report - May 8 2010 - FINAL.pdf; image002.jpg; image001.jpg
HelloTim, AttachedisEcofishsreportregardingtheMay8thstrandingincidentasdiscussedintheSeptember21stmeeting Regards, Robert
________________________________________
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
From: Adam Lewis [mailto:fjalewis@ecofishresearch.com] Sent: Friday, October 15, 2010 2:31 PM To: Robert Kulka Cc: 'Heather Gall' Subject: FW: May 8 Ashlu stranding report FINAL
HelloRobert: AttachedpleasefindtherevisedAshlustrandingincidentreportfordistributiontotheagencies. Regards,Adam

FJ Adam Lewis, M.Sc. R.P.Bio. Principal, Senior Biologist Ecofish Research Ltd.
fjalewis@ecofishresearch.com www.ecofishresearch.com F-450 8th Street, Courtenay, BC, V9N 1N5 Cell: 250 218-4180; Voice: 250 334-3042; Fax: 250 897-1742 Suite 1000 355 Burrard Street, Vancouver, BC, V6C 2G8 Cell: 250 218-4180; Voice: 604 608-6180; Fax: 604 608-6163
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This email contains confidential information that is proprietary to Ecofish Research Ltd.. This information is intended only for the person(s) named in the destination address. Unauthorized distribution, copying or disclosure is strictly prohibited. If you receive this e-mail in error please delete it immediately.
Page 461 FNR-2011-00265/ Part 1
Russell, Ve onica A ENV:EX

From: Sent: To: Subject: Babakaiff, Scott C ENV:EX Wednesday, April 14, 2010 9:44 AM 'Knight, Francesca'; 'Busto, Vince' FW: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management Plan, Revision C
Sorry, I shouldve ccd yall on this yesterday...

From: Babakaiff, Scott C ENV:EX Sent: Tuesday, April 13, 2010 2:06 AM To: Bennett, Timothy A ENV:EX Cc: Stoddard, Erin M ENV:EX; Barrett, Scott ENV:EX Subject: FW: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management Plan, Revision C Hi Tim, Per your request (and in anticipation of our meeting on Tuesday afternoon), I've competed a more detailed review of the latest OEMP iteration (Revision C) for the Ashlu IPP. You may recall that I sent a short email a few weeks ago indicating that the latest iteration did not address the deficiencies I'd previously identified in Revision B back in December 2009. So, here's a point-by-point review of Revision C in comparision to my December 2009 comments on Revision B (review comments on Revision B shown in italics): "Ive reviewed Revision B of the Operations Environmental Management Plan for the Ashlu Creek project (dated November 2009) as submitted by Innergex. The document is hereafter referenced simply as the OEMP since there is no authorship or bibliographic detail included. The absence of any explicit authorship is notable: there is little evidence that the OEMP has been composed by a licensed professional (e.g. RP Bio) with experience in the development or implementation of a monitoring program intending to fulfill agency needs. In short, the OEMP is typical for a preliminary draft, but it is troubling that completion of project construction & commissioning is imminent." Revision C has been composed by Focus Environmental Ltd. , but no individual author is named. Given the corporate structure of Focus Environmental, it seems safe to assume that the author is Bill Johnson (a RP Bio.) but this detail should have been provided. "Regardless, I have several primary concerns with the OEMP: 1. Few commitments to follow commonly-accepted guidelines for data collection & analysis, despite a proposal that monitoring details meet the requirements of DFO and MOE (p. 6 of the OEMP). I suggest many details proposed in the OEMP are seemingly arbitrary and do not reference any guidelines or standards typically referenced by Provincial or Federal agencies.
Revision C certainly includes more details than Revision B: a simple glance at the Table of Contents would allow this conclusion. Whether much of this detail is required is certainly questionable, but leaving that aside, I appreciate that Revision C similarly includes more commitments to follow commonly-accepted guidelines for data collection & analysis (e.g. text in Section 5). However, the details of data collection & analysis tabulated in the respective sub-sections of Section 5 are often inconsistent with the details of the respective guidelines (e.g. hydrometric guidance in Section 5.1). I'll suggest that this represents a lack of due dilligence rather than any intentional deceit. However, it is interesting that Section 5.0 (p.15) of Revision C includes the retrospective explanation that "baseline studies were carried out from 2001 to 2006 by Sigma and TRC Biological Ltd (TRC, 2005) according to B.C. Resource Inventory Standards Committee (RISC) standards, but prior to the Provincial guidelines compiled by Hatfield et al (2007)". This is a very generalized statement, and the author of Revision C does not provide any detail or supporting evidence for the claim of 'RISC standards' being met (ie. which RISC standards and for which components?). Nor does the author indicate how these RISC standards may or may not apply to the collection & analysis of data at this particular site. For example, RISC standards in 2006 did not include detailed guidance determination of stage-discharge rating curves, nor did they include guidance regarding recommended protocol for the collection of fish abundance data at sites such as Ashlu (ie. cold, deep, silty, low-conductivity streams) where standard methods (ie. electro-shocking) may be inappropriate.
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For instance: 1. Stage-discharge rating curves- the OEMP commits to collecting a minimum of three discharge measurements and warns that ...it is unlikely that flows will be able to be measured above 20% of mean annual discharge. There are clear and well-established guidelines for developing stage-discharge rating curves (e.g. LWBC Hydrometric Guidelines; B.C. Provincial Hydrometric Standards (see http://www.env.gov.bc.ca/fia/documents/Manual%20of%20British%20Columbia%20Hydrometri c%20Standards%20V1.0,%20March%2012,%202009.pdf) that the proponent is recommended to meet. Section 5.1.2 includes reference to appropriate guidance (RISC, 2009 & LWBC, 2005) for development of stage-discharge rating curves at the three proposed hydrometric stations, but explicit work to be undertaken to develop rating curves (e.g. 'three measurements' per Table 2 in Section 5.1.2) is inadequate and not consistent with provincial guidance. In fact, Section 5.1.2.1 of Revision C indicates that two of the three gauges have yet to be installed (so the rating curves have not yet been established), and Revision C indicates that 'calibration' of the gauge proposed for verifying compliance with IFR & ramping rates (WQ1) has already been completed by Northwest Hydraulic Consultants Ltd.(December 9 2009 report) but I do not believe this work has been reviewed & accepted by MOE. Text includes within Section 2.8 of Revision C suggests that the proponent may have a different understanding of IFR gauge calibration than the standard expected by MOE for streamflow measurement (" The sensor was tied into a benchmark in November 2009 following calibration of the 2.42 m/s IFR required under the DFO Authorization. The benchmark serves as a visual reference to calibrate the level probe") . The absence of an agency-approved rating curve and data collection protocol calls into question the reliability of streamflow data provided to date, including verification of compliance with IFR provision, so I recommend that the work be completed & submitted for MOE review ASAP, with no provision of final leaves to commence operation until the rating curves have been reviewed and accepted by MOE. Rating curve development for all three proposed gauges must be completed by a licensed Professional with appropriate training and experience in the collection & analysis of stream discharge data. The OEMP (and OPP) should also include a commitment to complete ongoing discharge measurements at each station to allow verification of the rating curve (or re-development of a rating curve, if need be) per the latest (2009) RISC standards. I can provide more detail to the consultants if need be. 2. Reporting of stream flow data: the OEMP commits to collect to collect flow data on a continuous basis, typically in 15-minute intervals and promises that data will be recorded...and can be provided to onsite DFO and/or MOE staff...for compliance purposes...flow data will be reported quarterly. I suggest there is no need to submit data to review agencies more frequently than once per year, but agencies must be informed within 24 hours of any non-compliance (e.g. IFR provision, ramping rates), and the proponent must resolve the issue of non-compliance immediately. In terms of data collection&logging, I note that the BC Provincial Hydrometric Standards (Section 3.2.2.3) recommends a stage reading every 15 minutes, but advises that "this is a minimum requirement...site specific flow regimes may necessitate a shorter frequency...". For purposes of verifying compliance with flow ramping requirements in fish-bearing waters, particularly those with the diversity of fish values in the Ashlu diversion reach, I would recommend a much shorter stage sampling frequency (say, 10-second), with a 2-minute average for storage in the data logger (and submission to agencies). I would also recommend that data be downloaded from the logger on a frequency no less than once per month, to ensure that any equipment malfunctions (e.g. battery loss, equipment damage) do not result in lengthy data gaps. For purposes of graphical presentation in monitoring reports, it may be helpful to apply an hourly average to the 2-minute stage data.
Section 5.1.3 of Revision C includes more detail than previous iterations, but still does not address the deficiencies identified in Revision Revision B (see above). Of greatest concern is the absence of a commitment to inform MOE within 24 hours of any non-compliance with water license conditions (ie, IFR provision, ramping rates) and immediately address any issues of non-compliance. Instead, Revision C simply commits to having the data available for agency review, if need be, along with annual submission: this is obviously inadequate. Also, Table 2 does not include any explicit commitments to the sample averaging intervals to be applied, despite my previous comments requesting such detail. I'm left with the impression that the author of Revision C has either not been provided with my previous review comments, or has wilfully ignored them. 3. Development of ramping rates: Section 12.2 of the OEMP proposes that the ramping rates shall not exceed 29.0 cms per 90 minutes. This rate will be established during the commissioning
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process of the plant, and may be subject to different flow conditions in the creek. This rate was based on the natural ramping rates that have been historically observed in Ashlu Creek over several years since 1991.... The OEMP provides some detail regarding proposed methods for establishing ramping rates during commissioning, but I would suggest that such protocol (and such interim rates like 29 cms per 90 minutes) should be established and scientifically-justified by an experienced professional, with reference to established agency criteria (e.g. DFOs default hourly ramping rates of 2.5 cm & 5.0 cm for fry & juveniles) or recommended guidelines. Finally, I suggest that the commitment within Section 14 of the OEMP to submit the ramping rate report six months after commissioning represents an inappropriate risk to fish & fish habitat given the rapid interim ramping rate proposed and the fish values present in the diversion reach. Ramping rate monitoring is proposed in Section 5.1 of Revision C, but again, the streamflow gauges proposed for monitoring of the ramping rates have either not yet been installed (WQ2, WQ3) or lack agency-approved rating curves (WQ1, WQ2, WQ3). Text within Section 5.1 of Revision C also suggests that the proponent is aiming to simply "track ramping rates during shut down" and may not fully understand that they will be obligated to verify compliance with ramping rates that will not harmfully alter or disrupt fish & fish habitat. It is also my understanding in the ongoing absence of a detailed ramping rate assessment, the proponent will be obligated to follow the DFO default standards (2.5 cm/hour when fry are present, 5.0 cm/hour otherwise) but there is no reference in Revision C to this standard. 4. Fish Abundance (Section 7) & Invertebrate Density (Section 8): no methodological guidelines for data collection or analysis are proposed, despite the bibliographic reference in Section 16 of the OEMP to Hatfield & Lewis (2007). The MOE-ESD information checklist provided in the Provincial IPP Guidebook also provides supplemental guidance for OEMP development. It is my understanding that the baseline biological data collected in recent years did not follow any particular protocol, but was undertaken by several different biologists in different locations, using different methods. As such, it is imperative that all baseline data be collated and assessed by a professional biologist with experience in the relevant specialization (ie. fisheries biology, macroinvertebrate biology), and compiled for assessment regarding its adequacy as a baseline to assess future changes that may be attributable to operation of the IPP facility.
Revision C includes an update on biological data collection undertaken since provision of the Water License & DFO Authorization (July 2006) : none. It includes some qualitative summaries of the baseline fish abundance & macroinvertebrate data collected in 2001-2004, but very little quantitative summarization. Section 5.3.1 of Revision C provides qualitative summaries of baseline fish habitat work (Section 5.3.1), and concludes that "Sampling and reporting standards and protocols for the inventory and analysis of fish habitat were available at the time Sigma conducted baseline programs, such as Fish Habitat Assessment Procedures (FHAP) outlined in Johnston and Slaney (1996) and the Reconnaissance1:20,000 Fish and Fish Habitat Inventory: Standards and Procedures (RIC, 1999a, 1999b, and RISC, 2001). Sigma (2002) did not refer to these documents,although we suspect, given the type of discussion in Sigma (2002 and 2004a) that they were aware ofthem, but simply omitted to reference them". Of course, an alternative explanation is that no specific set of guidelines were followed by the consultants in completion of the baseline studies, which I recall was the conclusion generated in MOE's review of the baseline studies back in 2004. It is proposed in Section 5.3.2 of Revision C that such qualitative fish habitat summaries persist as a component of operational monitoring. Similarly, Section 5.4.1 includes a summary of baseline fish sampling efforts, which seems to represents a total baseline effort in the diversion reach of approximately seven site visits over 14 days in 2001, and some follow-up work in 2002 (effort unquantified). It is subsequently concluded in Section 5.4.1 of Revision C that "Sigma conducted salmon spawning surveys in Reach 1 in 2003 (see Sigma2004a). It appears no further fish sampling was conducted by either Sigma or TRC". Section 5.4.2 includes several pages of proposed future (post-diversion) fish monitoring efforts, but given the negligible baseline data collection efforts conducted to date, I question the utility of such information to "determine the nature of any impacts of the project on fish" (per the water license). However, I'll leave any detailed consideration of proposed fish and macroinvertebrate baseline sampling effort to agency biologists in ESD (Erin Stoddard, Scott Barrett) or DFO (Francesca Knight). Finally, I suggest that any reference to informing DFO of any fish mortalities related to project operations (ie. Section 5.4.3) should also include a commitment to inform MOE. 2. No baseline data or power analysis: the adequacy of the monitoring details proposed in the
OEMP (e.g. duration and frequency of sampling, expected natural variability, sample sizes, methods of analysis, a priori agreement on ecologically-acceptable thresholds of dependent variables,
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corrective/compensatory measures to be adopted upon threshold exceedance, monitoring program budgets, etc. ) cannot be objectively considered without preliminary analysis of baseline data, including statistical power analysis. In the absence of such analyses, particularly for the biological data described in Sections 6&7 of the OEMP, I have little confidence in the adequacy of prediversion baseline data described in the OEMP to assess any diversion-induced changes in these biological response variables.
Revision C does not include any quantitative analysis of baseline data or power analysis on fish abundance. This is not surprising, given the baseline dataset described in Section 5.4.1 of Revision C. I suggest that it is either naive or misleading to justify the absence of a power analysis on "low fish capture numbers during baseline sampling in the Project area" and to subsequently suggest that "there may be insufficient baseline information to apply the BACI approach with any statistical reliability...since fish capture numbers were low during baseline sampling". It seems more likely that it was it is inadequate sampling effort, not necessarily low fish numbers, that have resulted in the inability to apply the BACI approach or to complete a power analysis on fish abundance data. Rather than proposing that "only trends in fish community metrics can be used for comparison with baseline", I suggest that an appropriate level of dilligence would include proposal of a detailed fish data collection program prior to diversion that would address this deficiency in baseline data. The proposal in Section 5.4.2.2 of Revision C that "Quantitative multivariate analysis of the data with power analysis to assess the biological change will be performed if possible" doesn't meet agency needs to assess the likelihood that the proposed monitoring program will be adequate to allow statistical resolution of project-related impacts to fish. 3. Details of monitoring commitments tabulated in the Appendix of the OEMP do not seem congruent with text in the body of the OEMP. For instance, page 3 of the OEMP clearly states: In the case of the Ashlu Project, baseline studies were carried out from 2001 to 2006, a period of five (5) years and were done prior to the new Provincial guidelines (Hatfield and Lewis, 2007); therefore, not all of the criteria outlined in the guidelines for control sites have been implemented during these previous studies. However, monitoring proposed for some components (e.g. biological components from Tables 3-5 of the OEMP) have been copied verbatim from the guidelines (which, incidentally, are not referenced correctly) and subsequent case study (Trout Creek), so it is unclear what aspects of the monitoring criteria will or will not be undertaken per the OEMP. Monitoring commitments tabulated in Revision C are relatively congruent with the associated text, but (as described above) there are many instances where these commitments refer to consistency with Provincial Guidelines, when such consistency may not be achieved by tabulated protocol (ie. sampling, analysis). 4. Pre-diversion activities which may require several months to complete have yet to have been initiated. For instance: 1. installation of the four pressure transducers (per Section 4.2.1 of the OEMP) and development of associated rating curves for water flow (Section 4) and instream flow (Section 11) monitoring; As described above, gauge installation & rating curve establishment has still has not yet been completed. 2. Collection of stream channel morphology data (per Section 10 of the OEMP). This component of the OEMP is particularly ill-defined: there are no explicit guidelines or standards referenced, and I also question the proposed benefits of completing repeat surveys at a few transects to assess whether the IFR is affect any of the fish habitat as was originally predicted. Assessment of changes in channel morphology related to project operations (e.g. flow diversion, changes in sediment and LWD transport rates and volumes, etc.) is crucial, but should be considered more holistically using low-level air photos and longitudinal survey profiles. Again, it is recommended that an professional experienced with development of channel monitoring programs (ie. a fluvial geomorphologist or river engineer) be tasked with developing the study design and undertaking the work prior to final commissioning;
Section 5.6.1 of Revision C clearly states what baseline data has been collected: "Geomorphology studies designed specifically to establish bed load transport and deposition characteristics through the Project area were not conducted as baseline prior to construction of the Project". This certainly doesn't preclude collection of such 'baseline' data prior to initiation of operations. However, the data collection program proposed in Section 5.6.2.2 of Revision C will not meet agency goals of resolving whether changes to sediment & LWD transport associated with project operations have impacts fish & fish habitat in reaches downstream (and potentially upstream) of the project. I strongly suggest that a more careful consideration of the proposed channel morphology data collection & analysis program be undertaken by a professional experienced in fluvial geomorphology, with reference to the baseline
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data collection program recommended in my review of Revision B (ie. site surveys and aerial methods such as low-level photography or LIDAR). Again, as per my review of Revision B, I suggest that the examples I've provided regarding deficiencies in Revision C do not represent the full suite of deficiencies; they were simply the most obvious shortfalls within my area of expertise. A more complete suite of review comments may be available through consultation with other ESD staff (ie. Erin Stoddard & Scott Barrett), WSD staff (e.g. Jim Davies) or our Federal counterparts (e.g. Vince Busto & Francesca Knight). Revision C is certainly an improvement on Revision B, but it is unfortunate so many deficiencies in the OEMP persist. It is also unfortunate that it has become apparent that no baseline fish&fish habitat data has been collected in the last eight years. I remain unconvinced that the monitoring program as proposed in Revision C adequately addresses Conditions i(2) of the Water Licence which "Requires a monitoring program suitable to determine the nature of any impacts of the project on fish and wildlife" and i(3) which requires a monitoring program to evaluate the effect of the regulation of works as ordered in number 1 above. Scott
From: Robert Kulka [mailto:RKulka@innergex.com] Sent: Thu 18/03/2010 4:40 PM To: Bennett, Timothy A ENV:EX Cc: Babakaiff, Scott C ENV:EX; gsteeves@ameresco.com; Richard Blanchet; Kelly Boychuk; Bill Johnson Subject: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management Plan, Revision C
HelloTim, AttachedisRevisionCoftheOEMP.AlsoattachedisacoverletteroutliningthehistoryoftheOEMP,ourre applicationforLTCOperation,andcurrentstatusoftheproject(shutdownfortunnelrepairs).Asealedandsigned copyoftheOEMPwillbesentpermailtoyouearlynextweek. Pleasecontactmeifyouhaveanyquestions.Regards, Robert
________________________________________
http://www.innergex.com/logo.jpg
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
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March 18, 2010 Tim Bennett, P.Eng. Section Head - Water Allocation Ministry of Environment 10470 152nd Street, 2nd Floor Surrey, BC, V3R 0Y3 Tel: (604) 582-5235 Email: timothy.Bennett@gov.bc.ca Re: Ashlu Creek Green Power Hydroelectric Project Operations Environmental Monitoring Plan, Revision C, Application for Leave to Commence Operations and Project Status
Dear Tim; Pursuant to the requirements of Conditional Water Licence #102203 (file #2001264) Ashlu Creek Investments LP (ACILP) hereby submits the Aquatic Life Operating Environmental Monitoring Plan, Revision C for the Ashlu Creek Project (the OEMP). The OEMP in a previous form was submitted to DFO on May 19, 2009 under the title Five Year, Post-Construction Aquatic Monitoring Program, Revision A. A follow up letter describing the method to confirm ramping rates during commissioning has been sent to DFO on October 14, 2009. We have yet not received comments from DFO to Revision A or the follow up letter. Revision B was issued to your office with copy to DFO on November 27, 2009. In an email dated December 18, 2009 you expressed various concerns with regards to Revision B, one of them the unknown authorship. ACILP has retained Bill Johnson, R.P.Bio who authored the new revision of the OEMP. Please note that the Operating Parameters and Procedures Report for the Ashlu Creek Project (the OPPR) as submitted to your office on November 24, 2009 has some minor inconsistencies with the new revision of the OEMP, mainly with respect to water temperature, water level and flow monitoring stations. We plan to revise the OPPR to implement those changes once the OEMP has been accepted by your office. We understand that the OEMP was the last remaining document required to issue a Leave to Commence Operation and ACILP hereby reapplies for the LTC Operation. ACILP and its Consultant Bill Johnson remain available to meet with MOE staff to discuss the OEMP or OPPR for the Ashlu Creek project. As per my voicemail to you on March 9, 2010 the plant is not diverting water since February 28, 2010 due to increased number of rocks that went through the turbines which caused us to perform a tunnel inspection. The inspection revealed that some localized areas in the tunnel require repairs which commenced in early March and are expected to be completed by March 29. Commissioning activities have been interrupted by the current shut down and the final index testing of the turbines has been consequently delayed. We further intend to extend the commissioning activities to the repaired tunnel with a two week monitoring program for rock break in the turbines and tail race in order to confirm that the initial tunnel works and current
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From: Sent: To: Subject: Attachments: Babakaiff, Scott C ENV:EX Friday, March 19, 2010 8:24 AM Bennett, Timothy A ENV:EX; Stoddard, Erin M ENV:EX FW: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management Plan, Revision C Ashlu OEMP Rev C 18-March-2010.pdf; 2010-03-18 Ashlu ltr RK to TB OEMP RevC.pdf
Hi Tim, I've had a quick look at this revision (Rev. C), and it doesn't address the OEMP deficiencies identified in my previous reviews (most recently in January 2010), nor deficincies identified in reviews completed by other agency staff (e.g. Francesca Knight of DFO from Jan 15 2010). I'll re-forward these most recent reviews to you, but I suspect you've got a reasonable understanding of our concerns. As you know, given my present schedule, it is likely that I will not have the opportunity to complete a detailed review of Rev. C until mid-April, and it seems likely that the proponent will be seeking WSD (ie. you) for their LTC Operation before then, without a reasonable OEMP. We'll soon be reaching that difficult moment we've been predicting for the last few years...so now what? , but I can be reached on my cell phon like to chat. Enjoy the sunshine this weekend, amigo. Scott
S. 22 S. 22
if you'd
From: Robert Kulka [mailto:RKulka@innergex.com] Sent: Thu 18/03/2010 4:40 PM To: Bennett, Timothy A ENV:EX Cc: Babakaiff, Scott C ENV:EX; gsteeves@ameresco.com; Richard Blanchet; Kelly Boychuk; Bill Johnson Subject: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management Plan, Revision C
HelloTim, AttachedisRevisionCoftheOEMP.AlsoattachedisacoverletteroutliningthehistoryoftheOEMP,ourre applicationforLTCOperation,andcurrentstatusoftheproject(shutdownfortunnelrepairs).Asealedandsigned copyoftheOEMPwillbesentpermailtoyouearlynextweek. Pleasecontactmeifyouhaveanyquestions.Regards, Robert
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http://www.innergex.com/logo.jpg
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434

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From: Sent: To: Cc: Subject: Attachments: Adam Lewis [fjalewis@ecofishresearch.com] Friday, June 25, 2010 8:58 PM Babakaiff, Scott C ENV:EX; Bennett, Timothy A ENV:EX; 'Knight, Francesca'; gsteeves@ameresco.com; Stoddard, Erin M ENV:EX; 'Busto, Vince' 'Richard Blanchet'; 'Robert Kulka' RE: Ashlu Creek Hydro Project (Water file 2001264): Revision of OEMP Ashlu Creek Hydro Project - OEMP DRAFT for Agency Review V1.pdf; image001.jpg
Helloall: AttachedpleasefindanOEMPpreparedbyEcofishResearchonbehalfoftheACILPfortheAshluCreekPower Project. Pleasecontactmeifyouhaveanyquestions.

FJ Adam Lewis, M.Sc. R.P.Bio. Principal, Senior Biologist Ecofish Research Ltd.
fjalewis@ecofishresearch.com www.ecofishresearch.com F-450 8th Street, Courtenay, BC, V9N 1N5 Cell: 250 218-4180; Voice: 250 334-3042; Fax: 250 897-1742 1031 355 Burrard Street, Vancouver, BC, V6C 2G8 Cell: 250 218-4180; Voice: 604 608-6180; Fax: 604 608-6163 This email contains confidential information that is proprietary to Ecofish Research Ltd.. This information is intended only for the person(s) named in the destination address. Unauthorized distribution, copying or disclosure is strictly prohibited. If you receive this e-mail in error please delete it immediately.
From: Robert Kulka [mailto:RKulka@innergex.com] Sent: Tuesday, June 22, 2010 6:54 AM To: Bennett, Timothy A ENV:EX Cc: Babakaiff, Scott C ENV:EX; Knight, Francesca; Busto, Vince; Stoddard, Erin M ENV:EX; gsteeves@ameresco.com; Adam Lewis; Richard Blanchet Subject: Ashlu Creek Hydro Project (Water file 2001264): Revision of OEMP
HiTim, IprovidethefollowingupdatewithregardstotheOEMPandotherdocuments:Weexpecttosubmittherevised OEMPonFriday,June25thandtwodocumentssummarizingthebaselinedatareviewandanoverviewoftherecent baselinedatacollectedthroughEcofishbyMonday,June28th,2010. Pleasecontactmeifyouhaveanyquestionsorcomments. Regards, Robert
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Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
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Birchard, Leona ENV:EX

From: Sent: To: Cc: Subject: Attachments: Bennett, Timothy A ENV:EX Friday, January 8, 2010 10:06 AM 'Knight, Francesca'; Babakaiff, Scott C ENV:EX Stoddard, Erin M ENV:EX; 'Busto, Vince' RE: Ashlu long-term monitoirng RE: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management Plan
Hiall, IhadparaphrasedScottsoriginalreviewcomments(tome)andprovidedthemtoInnergexonDec18,2009(see attachedemail). Ihaventyetreceivedaresponse;andwillsendareminder(alongwithOPPcomments)inthenearfuture. Onthatnote,haveyou(Vince,Francesca)seentheOPP?Wereceivedahardcopy,andcouldeitherscanitandsend itoryoucouldaskInnergextoprovideadigitalcopy. ItmightbeworthwhilehavingabriefchattocollateallofourcommentsontheOEMP(andthefactthattherewasa previousversionsubmittedtoDFO)andOPP,andprovidetheminonego? Cheers,

TimothyBennett,M.Sc.,P.Eng. SectionHead,WaterAllocation WaterStewardshipDivision MinistryofEnvironment
From: Knight, Francesca [mailto:Francesca.Knight@dfo-mpo.gc.ca] Sent: Friday, January 8, 2010 9:19 AM To: Babakaiff, Scott C ENV:EX; Bennett, Timothy A ENV:EX Cc: Stoddard, Erin M ENV:EX; Busto, Vince Subject: RE: Ashlu long-term monitoirng
may I just say, in the parlance of today's youth... OMG! thanks for the clarification, C
From: Babakaiff, Scott C ENV:EX [mailto:Scott.Babakaiff@gov.bc.ca] Sent: Fri 1/8/2010 8:28 AM To: Knight, Francesca; Bennett, Timothy A ENV:EX Cc: Stoddard, Erin M ENV:EX; Busto, Vince Subject: RE: Ashlu long-term monitoirng
Yall, There seems to be two different versions of the Ashlu IPP long-term monitoring Plan floating around the review agencies at the moment. In the process of reviewing the OPP (v.4 dated November 24 2009), I discovered (in Appendix E of the OPP) a long-term monitoring plan developed by Cascade Environmental (dated May 2009, submitted by Kelly Boychuk to Vince Busto). This plan was never submitted to MOE, and I didnt even know it existed until yesterday. This (again) illustrates the value in our regular & ongoing meetings & communications regarding IPP review issues.
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For the record, Chessy: I agree with your conclusions. The May 2009 plan developed by Cascade Environmental is lacking many critical elements of an appropriate monitoring Plan, including a power analysis which (I suspect) would confirm that the baseline work completed to date is far from adequate. The Ashlu IPP long-term monitoring Plan which was submitted by Robert Kulka to MOE in November 2009, and subsequently reviewed by MOE (see attached email from Tim Bennett, which was sent to the proponent a few weeks ago), was very different than the Plan submitted to DFO in May. It seems that this is not a matter of one version superceding another, but rather that the proponent has submitted different plans to DFO and MOE. I dont know whether the proponent has done this intentionally, believing that one Plan would meet the needs of DFOs Authorization, and the other Plan would address Water License requirements. Or perhaps the different reps for the Proponent (Kelly Boychuk & Robert Kulka) arent even aware that the two different plans exist. Regardless, it seems that action is required from MOE & DFO to ensure that the proponent is made aware that: 1. a single long-term monitoring Plan should be developed to meet the needs of both DFO & MOE, and, 2. the Plan(s) in their present form are far from adequate. Scott
From: Knight, Francesca [mailto:Francesca.Knight@dfo-mpo.gc.ca] Sent: Thursday, January 7, 2010 6:54 PM To: Babakaiff, Scott C ENV:EX; Bennett, Timothy A ENV:EX Cc: Stoddard, Erin M ENV:EX; Busto, Vince Subject: Ashlu long-term monitoirng
Hi guys,
I'd been meaning to take a look at the Ashlu's long-term monitoring plan. Does anyone know who wrote the plan? After seening the Fitz creek plan, the Ashlu one leaves me wanting a bit. I believe the approach for most of the indicators is too "qualitative", in other words, it is not set up to allow the investigators to draw meaningful conclusions regarding any potential biological responses to the alterted flow regime. I'll give you a couple of examples:
1. The report claims that fish population density will be evaluated, but in fact, there is no method included for establishing a population estimate in the diversion reach. What will actually be measured is prsence/absence, which is useful if you just care about whether any fish are in the diversion reach at all post-diversion, but otherwise useless for telling us whether the diversion has influenced the fish population. In addition, there is no method for counting adult fish... just gee traps for the little guys.
2. The bug data will not be analyzed in any way that enables us to make before-and-after diversion comparisons; abundance will be presented for each sampling event, but no quantitative evaluation of change over time. There are some other short-comings related to methods, but the limited analysis is the biggie. In addition, there is of course nothing proposed for evaluating changes to community structure, but you all know that is my main concern with how invertebrates are used as indicators in the IPP-world.
3. The methods proposed for evaluating physical habitat change (transects) are again, too qualitative. I don't think we would be able to draw any meaningful conclusions about how the altered flow regime affected available habitat types.

4. The monitoring for the compensatory fish habitat is entirely qualitative: "Periodic observations will be made to check on fish utilization in the channel and pools." No mention of even setting gee-traps!
In summary, I think the program is set up to collect some data, but not to offer any useful interpretation or determine any flow/biological response relationships. C
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Ashlu Creek Hydroelectric Power Project Operations Environmental Management Plan
Revision B
November 2009
Ashlu Creek Investments Limited Partnership 303-38 Fell Avenue North Vancouver, BC V7P 3S2
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Abstract
In July 2006, the Ministry of Environment (MOE) issued Ashlu Creek Investments Limited Partnership Conditional Water License #102203 on Ashlu Creek near Squamish B.C. Conditions of the water license included a maximum diverted flow of 29.0 m3/s and the completion of an Operational Environmental Monitoring Plan (OEMP) to evaluate the effect of the regulation of works. In July 2006, the Department of Fisheries and Oceans (DFO) issued authorization #04-HPCAPA2-000-000530. Conditions of this authorization include a year round Instream Flow Requirement (IFR) of 2.42 m3/s. A draft (Revision A) of the Five Year, Post-Construction Aquatic Monitoring Program Revision A was submitted to DFO in May 2009. A follow-up letter was sent to DFO in October 2009 with description of the specific plan to confirm ramping rates. As of November 27, 2009, comments have not been received from DFO. In addition, Approval #8200-T-10595.2 issued by Transport Canadas Navigable Waters Protection Division (NWPD) requires the IFR to range between 16 m3/s and 32 m3/s during twelve (12) weekends between May and September. The OEMP outlines the biotic and physical monitoring parameters to be monitored during both pre and post construction of the Ashlu Creek Hydroelectric Project. The purpose of the OEMP is to provide early warning of impending change in key variables and provide an opportunity to mitigate any change through alterations of operating procedures. The goal of the OEMP is to ensure resource values potentially affected by power production are not adversely compromised over the life of the facility.
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Table of Contents Abstract........................................................................................................................... i Table of Contents ...........................................................................................................ii List of Figures ...............................................................................................................iv List of Tables .................................................................................................................iv 1.0 2.0 3.0 3.1 3.2 3.3 3.4 3.5 3.6 3.7 3.8 3.9 Introduction......................................................................................................... 1 Study Area........................................................................................................... 1 Monitoring Components .................................................................................... 2 Headpond ............................................................................................................. 3 Intake/Weir ........................................................................................................... 3 Mile 25 Bridge....................................................................................................... 4 Gravel Bar in Ashlu Canyon ................................................................................. 4 Gustafson (Bend) Creek ....................................................................................... 4 Powerhouse/Tailrace/Switchyard ......................................................................... 4 Double Bridges ..................................................................................................... 4 Fish Compensatory Habitat .................................................................................. 4 Transmission Line ................................................................................................ 6
4.0 Water Flow .......................................................................................................... 6 4.1 Monitoring Locations ............................................................................................ 6 4.2 Monitoring Approach and Analysis ....................................................................... 6 4.2.1 Electronic Pressure Transducers............................................................... 6 4.2.2 Visual Staff Gauges ................................................................................... 7 4.3 Reporting .............................................................................................................. 7 5.0 5.1 5.2 5.3 6.0 6.1 6.2 6.3 7.0 7.1 7.2 7.3 8.0 8.1 8.2 8.3 Water Quality ...................................................................................................... 7 Monitoring Locations ............................................................................................ 8 Monitoring Approach and Analysis ....................................................................... 8 Reporting .............................................................................................................. 8 Water Temperature............................................................................................. 9 Monitoring Locations ............................................................................................ 9 Monitoring Approach and Analysis ....................................................................... 9 Reporting .............................................................................................................. 9 Fish Abundance and Biomass Density (Fish Community)........................ 10 Monitoring Locations .......................................................................................... 10 Monitoring Approach and Analysis ..................................................................... 10 Reporting ............................................................................................................ 11 Invertebrate Abundance and Biomass Density ............................................. 12 Monitoring Locations .......................................................................................... 12 Monitoring Approach and Analysis ..................................................................... 12 Reporting ............................................................................................................ 13
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9.0 Compensatory Fish Habitat Efficacy .............................................................. 13 9.1 Monitoring Locations .......................................................................................... 13 9.2 Monitoring Approach and Analysis ..................................................................... 13 9.2.1 Fish Ladder.............................................................................................. 13 9.2.2 Rearing Fish Compensation .................................................................... 13 9.3 Reporting ............................................................................................................ 14 10.0 Stream Channel Morphology........................................................................... 14 10.1 Monitoring Locations .......................................................................................... 15 10.2 Monitoring Approach and Analysis ..................................................................... 15 10.3 Reporting ............................................................................................................ 15 11.0 Instream Flow Requirement............................................................................. 15 11.1 Monitoring Locations .......................................................................................... 15 11.2 Monitoring Approach and Analysis ..................................................................... 16 11.2.1 Requirements under DFO........................................................................ 16 11.2.2 Requirements under TC / NWPD............................................................. 16 11.3 Reporting ............................................................................................................ 17 12.0 Ramping ............................................................................................................ 17 12.1 Monitoring Locations .......................................................................................... 17 12.2 Monitoring Approach and Analysis ..................................................................... 17 12.3 Reporting ............................................................................................................ 18 13.0 Footprint Impact Verification........................................................................... 19 13.1 Monitoring Locations .......................................................................................... 19 13.2 Monitoring Approach and Analysis ..................................................................... 19 13.3 Reporting ............................................................................................................ 19 14.0 15.0 Reporting........................................................................................................... 19 Exclusions......................................................................................................... 20
16.0 References ........................................................................................................ 20 16.1 General References ........................................................................................... 20 16.2 Project-Specific References ............................................................................... 20
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List of Figures
Figure 1 Post-Construction Aquatic Monitoring Program Monitoring Station Locations ........... 5
List of Tables
Table 1 Table 2 Table 3 Table 4 Table 5 Table 6 Table 7 Table 8 Table 9 Table 10 Water Flow ............................................................................................................... 23 Water Quality............................................................................................................ 23 Water Temperature .................................................................................................. 24 Fish Abundance and Biomass Density..................................................................... 24 Invertebrate Abundance and Biomass Density ........................................................ 25 Compensation Fish Habitat Efficacy......................................................................... 25 Stream Channel Morphology.................................................................................... 26 Instream Flow Requirement ..................................................................................... 26 Flow Ramping .......................................................................................................... 27 Footprint Impact Verification..................................................................................... 27
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1.0
Introduction
The post-construction and operational impacts of the Ashlu Creek Hydroelectric Power Project (the Project) on the aquatic environment of Ashlu Creek will be monitored to ensure compliance with the environmental standards and agreements made with MOE and DFO during the permitting process for the Project. This Five Year, Post-Construction Monitoring Program (the Program) proposes the technical methods that will be used for data collection and presentation to DFO under the Projects Fisheries Authorization (04-HPAC-PA2-000-000530) dated July 31, 2006. The post-construction monitoring period, as described in the Fisheries Authorization, is five (5) years from the date of commercial operation of the Project, which is the date when construction is substantially completed and the Project begins to generate electricity for sale to BC Hydro, which based on an expected Commercial Operation Date (COD) of December 2009, is anticipated to be the period from January 2010 to December 2014.
2.0
Study Area
Ashlu Creek rises in the Tantalus Range of the Coast Mountains and flows in a south-easterly direction to its confluence with the Squamish River, approximately 20 km north of the Town of Squamish, B.C. It is a fifth order stream with a length of approximately 34 km and a drainage area of 324 km2. The catchment area of Ashlu Creek at the proposed intake location is 295 km2. The mean annual flow in Ashlu Creek at the intake site is estimated to be 27.1 m3/s (per Knight Pisolds February 2004 report). Ashlu Creek has been gauged intermittently since 1991 and consequently longer term flow records were synthesized from data obtained from a nearby Water Survey of Canada gauging station on the Elaho River. The lowest mean monthly discharges of 3 m3/s to 5 m3/s occur in winter (December to March), while the highest mean monthly discharges of 60 m3/s to 65 m3/s occur in the summer (June and July). The Ashlu Creek Aquatic Environmental Assessment Report (September 2002) and the Aquatic Environmental Addendum (April 2004) by Sigma Engineering described the fish and fish habitat in detail. It is summarized following in the context of the six distinct reaches of the creek. Reach 1 begins at Ashlu Creeks confluence with the Squamish River and extends up 2.8 km upstream to the upstream end of the double bridge island. This reach has a low gradient, highly productive side channels, and comprises primarily riffle habitat. Chinook, coho, chum, pink, and sockeye salmon, winter run steelhead, coastal cutthroat and rainbow trout, and Dolly Varden char were found in this reach. Reach 2 is the cascade section of the creek, with gradients ranging from 4 to 8%, several small falls, and riffle-chute habitat. It extends 2.7 km from the top end of the double bridge island up
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to the natural island in the middle of the Ashlu Canyon. This reach provides little to no spawning or rearing habitat due to the high velocity and minimal in-stream cover. An adult steelhead was found at the start of the reach at low flows in November 2001, and several smaller migratory fish were found at the top end of the reach at low flows in April 2002. A natural fish barrier is located in Reach 2 at approximately 0.8 km upstream of the double bridges; anadromous fish migration ends at the canyon. Reach 3 is located entirely within a vertical walled canyon from the natural island to a 6 m high waterfall. The habitat is continual rapid-chute with many waterfalls up to 2 m in height. Instream cover is minimal and banks are steep, providing little overstream cover. No fish were located in this reach. Reach 4 has low gradient and good fish habitat, with a mixture of riffles, glides and pools, and abundant in-stream cover. It extends 6.5 km upstream from the 6 m high water fall, past the proposed project intake, up to near the confluence with Pykett Creek. Within the creek there are several islands, creating side and back channels, and the substrate is primarily gravels and boulders. Numerous rainbow trout were caught on all sampling dates. Reach 5 extends from near Pykett Creek to 3.5 km upstream of the confluence of Tatlow Creek. It has similar habitat to Reach 4, with low gradient, abundant cover, a mixture of riffles, glides and pools, and several side channels. Fish were caught throughout the lower reach. Reach 6 is characterized by high velocities and steep slopes in a narrow, confined channel. It extends from Reach 5 up to the headwaters of Ashlu Creek. There is minimal cover in the reach, the flows are cascades and riffles, and the substrate is mainly bedrock and boulder. No fish were located in this reach. Steelhead fry were stocked in the upper reaches (Reaches 4, 5 and 6) of Ashlu Creek by the Fisheries Branch of Ministry of Environment, Lands and Parks (MoELP) from 1978 to 1997, and residual populations of these steelhead/rainbow trout inhabit the reaches above the Ashlu Canyon.
3.0
Monitoring Components
The Program comprises two types of monitoring: compliance monitoring and biotic response monitoring. Compliance monitoring measures water use to ensure that Ashlu Creek Investments Limited Partnership (the Proponent) is complying with the conditions of MOEs Conditional Water License, including water quantity, quality and temperature, and DFO/MOEs habitat compensation works to ensure that they are physically stable and performing adequately. Biotic response monitoring addresses the complexity of the biological response to flow conditions, and the monitoring program will measure the effect of flow releases on target ecological resources (i.e. fish populations, fish habitat, and invertebrate abundance).
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To reduce the natural variation in Ashlu Creek, time of year and flow range at the time of sampling will be standardized to the extent possible. Field studies will be planned to target a specific flow within a practical calendar period rather than aiming solely for a particular calendar date each year. The approached developed by Hatfield and Lewis (2007) for Independent Power Projects (IPPs) in British Columbia follows a quantitative, site effectiveness monitoring with a beforeafter control-impact (BACI) approach. Under this approach, control sites (i.e. portions of Ashlu Creek or reaches without water withdrawal) are monitored simultaneously with impact sites (i.e. reaches with water withdraw) for a predetermined period both before and after project implementation. Typically, the control sites are upstream of the Project area, and impact sites are within the diversion reach of the Project. In the case of the Ashlu Project, baseline studies were carried out from 2001 to 2006, a period of five (5) years and were done prior to the new Provincial guidelines (Hatfield and Lewis, 2007); therefore, not all of the criteria outlined in the guidelines for control sites have been implemented during these previous studies. The Program consists of monitoring the following aquatic components: 1. 2. 3. 4. 5. 6. 7. 8. 9. Water flow; Water quality; Water temperature; Fish abundance and biomass density; Invertebrate abundance and biomass density; Compensation fish habitat efficacy; Stream channel morphology; Instream Flow Requirement; Flow ramping; and
10. Footprint impact verification. The key areas where these monitoring components will be performed are described below and are shown on Figure 1. All locations are referenced to the distance along the Ashlu Forest Service Road (Ashlu FSR) originating from the Squamish River Bridge. 3.1 Headpond The headpond is located approximately 9 km along the Ashlu FSR and is directly upstream of the intake and weir. When the headpond is filled to its normal operating elevation of 276.0 metres, it will extend approximately 400 metres upstream of the intake and weir. 3.2 Intake/Weir The intake and weir are located approximately 9 km along the Ashlu FSR and are directly downstream of the headpond. The intake comprises a fixed concrete structure and earthfill dam
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with sluice and intake gates; the weir comprises a fixed concrete sill and an inflatable, rubber, Obermeyer weir. The fish ladder is located within the intake/weir structures. 3.3 Mile 25 Bridge The Mile 25 Bridge is located approximately 7 km along the Ashlu FSR and crosses Ashlu Creek just upstream of the Ashlu Canyon. The bridge was built by previous logging companies who worked within Tree Farm License 38 area where Ashlu Creek is located. There is a fork in the Ashlu FSR just 100 metres prior to reaching the Mile 25 Bridge, and this fork leads to the intake, weir and headpond areas. 3.4 Gravel Bar in Ashlu Canyon The gravel bar in the Ashlu Canyon is located approximately 5.5km along the Ashlu FSR and is not accessible from the road. The area is defined at a widening of the Ashlu Canyon where the flow energy of the stream decreases and forms a large gravel bar. Both upstream and downstream of this location are narrow, bedrock canyons. 3.5 Gustafson (Bend) Creek Gustafson (or Bend) Creek is located approximately 4.4km along the Ashlu FSR and is an intermittent stream. In the winter and early spring, Gustafson Creek typically acts as a conduit for avalanches that cross the Ashlu FSR. Immediately downhill of Gustafson Creek is a steep section of the Ashlu FSR. 3.6 Powerhouse/Tailrace/Switchyard The powerhouse and tailrace are located approximately 2.8km along the Ashlu FSR. The powerhouse comprises a fixed concrete building with turbines and generators within, and the tailrace comprises a fixed concrete pool and overflow sill into Ashlu Creek. The powerhouse and tailrace are located immediately downstream of the mouth of the narrow Ashlu Canyon. Adjacent to both structures is the electrical switchyard, and slightly uphill is the tunnel portal and adjoining penstock (buried beneath the Ashlu FSR). 3.7 Double Bridges The double bridges are located approximately 2.5km along the Ashlu FSR and cross Ashlu Creek in two places. Like the Mile 25 Bridge, these bridges were built by previous logging companies who worked within the Tree Farm License 38 area. The double bridges mark the area where Ashlu Creek changes to a wide, low energy, meandering stream. This location is generally known to be the upstream limit for salmon spawning in Ashlu Creek. 3.8 Fish Compensatory Habitat The fish compensatory habitat is located approximately 1.5 to 2km along the Ashlu FSR and covers the area to the north and south of the FSR, including along the transmission line right-ofway. This area also connects DFOs small intake and fish habitat ponds and channels that were
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established in the late 1990s. The fish compensatory habitat comprises a network of narrow, low energy streams and pools that criss-cross the transmission line right-of-way and enter into the forested area on the Ashlu Creek delta.
Figure 1 Post-Construction Aquatic Monitoring Program Monitoring Station Locations
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3.9 Transmission Line The transmission line begins at the electrical switchyard and extends for approximately 3km to the BC Hydro switch beside the Squamish River Bridge. The transmission line parallels the Ashlu Forest Service Road and crosses over Ashlu Creek at the double bridges.
4.0
Water Flow
The primary objective of water flow monitoring is to provide accurate, real time instantaneous flow data in the most practical manner that meets the requirements of DFO and MOE. Monitoring flows will allow verification of the instream flow release (IFR) in the stream at these critical locations for compliance with DFOs Fisheries Authorization provision for minimum flow release. 4.1 Monitoring Locations A total of four (4) hydrometric stations will be installed at the intake (two), Mile 25 Bridge, and at the powerhouse/tailrace. At each station, an electronic pressure transducer will be utilized, and will measure the water level in the headpond and the water level in Ashlu Creek downstream of the intake, within the diversion reach, and downstream of the tailrace. A total of four (4) visual staff gauges will be installed alongside the electronic pressure transducers to provide visual references of the water levels. The staff gauges will allow regulatory agency personnel to evaluate instream flow conditions independent of project operations at any time. 4.2 4.2.1 Monitoring Approach and Analysis Electronic Pressure Transducers At the headpond, a pressure transducer will be installed to continually measure the elevation of the water upstream of the rockfill weir and concrete structures. A second pressure transducer will be installed at a suitable location downstream of the rockfill weir and concrete structures to measure the total IFR, which includes flows from the IFR pipe, fish ladder, sluiceway, emergency spillway, seepage under the structures and overflow from the Obermeyer weir. At the Mile 25 Bridge, located approximately 2 km downstream of the headpond, an existing pressure transducer will continue to measure the elevation of the water within the diversion reach. This station has a proven flow discharge curve which was established during the development phase of the project and has been maintained on a regular basis. It is envisioned that this information will be converted from water depth to flow and be posted onto a publicly accessible web site for recreation users to observe. At the Mile 25 Bridge location, the water level in the diversion reach will be a combination of the IFR plus inflows from tributaries downstream of the weir, seepage from underneath the
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various structures, and any flow releases from the fish ladder, sluiceway and emergency spillway. The hydrometric stations will be installed according to RISC protocols (1998). 4.2.2 Visual Staff Gauges The visual staff gauges will be located near the electronic pressure transducers so that the water level readings from the transducers correlate to the staff gauges. The staff gauges will typically be aluminium strips with calibrated markings (in centimetres) on them, and will be mounted to a stationary object (i.e. rock outcrop, bridge abutment).
A minimum of three (3) discharge measurements, well distributed over the range of discharge flows, will be manually measured to establish the initial rating curves for Ashlu Creek in the diversion and downstream reaches. Due to the significant amount of natural flow in Ashlu Creek, it is unlikely that flows will be able to be measured above 20% of Mean Annual Discharge (MAD) of the full stream flow (27 m3/s) in Ashlu Creek. Once the flow rating curve is established, the water level data collected from the electronic pressure transducers can be converted to flow values. 4.3 Reporting The flow data will be collected on a continuous basis, typically in 15 minute reading intervals, and will be converted to flows for reporting purposes. The data will be recorded and available to the plant operator on a real time basis. The Proponents plant operator can provide on-site DFO and/or MOE staff with the instantaneous water level and flow data for compliance purposes. The headpond data will also be collected on a continuous basis but at a higher frequency as this information is transmitted to the powerhouse for the overall flow control from the intake. The flow passing through the turbines in the powerhouse can be accurately measured through a turbine efficiency test that will be completed during commissioning of the Project. This tests will provide measured data on turbine flow output that can be correlated with tunnel/penstock pressures and then used to develop a program that can convert real time energy and pressure measurements into flows. Flow data will be reported quarterly. summarized in Table 1. Details of the water flow monitoring program are
5.0
Water Quality
The primary objective of water quality monitoring is to monitor for potential impacts of the Project on the stream by collecting and comparing water quality samples taken upstream of the intake and headpond areas of influence (the Control Samples), and within the diversion reach and downstream of the tailrace (Impact Samples).
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5.1 Monitoring Locations Water quality samples will be collected from four (4) locations; i) upstream of the headpond (upstream by 100 to 200 metres and downstream of Pokosha Creek), ii) upstream of the powerhouse/tailrace in the mouth of Ashlu canyon, iii) directly from within the tail race weir, and iv) at or near the double bridges on the Ashlu delta. The double bridge location will likely correspond with one of the pre-project water quality data collection locations; the other two locations will be new locations. 5.2 Monitoring Approach and Analysis Samples taken upstream of the headpond will provide baseline water quality prior to any water reaching, and being influenced by, the intake structure. Samples taken upstream of the powerhouse will represent the most changed water conditions as the water will have flown entirely down the diversion reach at this point. Samples taken from within the tail race weir will reflect any changes to the water quality due to its passage through the water conveyance system, and in particular the tunnel. Samples taken at the double bridge site will reflect the mixed water quality of the diversion reach and discharged water back into the stream from the tunnel/penstock. Water quality samples at all sample locations will be collected semi-annually, which is coincident with low flow events at the beginning and end of the fish growing season, which occurs in April and October, when there is the greatest potential for there to be impacts from the Project on water quality. Water quality samples at the tail race will be collected quarterly to more frequently monitor Acid Drain Rock and metals leaching from the tunnel rock. Water quality parameters most likely to be affected by the project operations include total suspended solids (TSS) and total gas pressure (TGP). Samples will be collected and sent to a certified laboratory for analysis; dissolved oxygen and TGP data will be collected in-situ with portable meters. Dissolved oxygen, turbidity, total suspended solids (TSS), specific conductance, total alkalinity, pH, total phosphorus, ortho-phosphorus, ammonia, nitrite, nitrate and metals will also be analysed. 5.3 Reporting TSS and TGP values will be compared from the three sampling locations to compare and contrast any changes between the values of the Control and Impact Samples. Also, the baseline study values will also be presented to compare and contrast with sample results from the double bridge sample location. Dissolved oxygen, turbidity, TSS, specific conductance, total alkalinity, pH, total phosphorus, ortho-phosphorus, ammonia, nitrite, nitrate, and metals will also be compared. TGP is expected to decrease in the diversion and downstream reaches following project operation, based on the fact that flow reductions in the diversion reach will decrease the entrainment of air in pools and the potential for increases in dissolved gas. This prediction will
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be confirmed by comparing the results of the Year 1 study with the baseline data; should the predictions be confirmed, then TGP sampling will be terminated after Year 1. Water quality results will be reported annually. Details of the water quality monitoring program are summarized in Table 2.
6.0
Water Temperature
The primary objective of water temperature monitoring is to observe any potential significant changes in water temperature and the effect of water diversion during operations on water temperatures in the diversion reach and the Ashlu delta. The secondary objective is to observe the water temperatures in the new fish compensatory habitat areas, which are somewhat independent of the ambient water temperature of Ashlu Creek due to the change in stream characteristics for creek into the habitat areas.(i.e. high vs. low energy streams). 6.1 Monitoring Locations Water temperature will be monitored at five (5) stream locations: within the headpond, in the diversion reach at the Mile 25 Bridge, at the powerhouse/ tailrace discharge area, and near the double bridges. A fifth location, which is not on Ashlu Creek, will be in the new fish compensatory habitat on the Ashlu delta. 6.2 Monitoring Approach and Analysis Water temperature data will be collected using stand-alone water temperature sensors or with water level data collection from electronic pressure transducers (as per Section 1). The sensor in the headpond and will be combined with the headpond water level sensor, and will measure the water temperature of the inflowing water from the non-impacted reaches upstream of the Project. The existing water temperature sensor at the Mile 25 Bridge will continue to measure the water temperature within the diversion reach. The sensor installed within the tailrace will measure the temperature of the diverted water from the intake as its passed through the tunnel/penstock and discharged from the powerhouse. The sensor near the double bridges will measure the water temperature of the mixed water from the powerhouse discharge and the flows in the diversion reach. The sensor in the new fish compensatory habitat will monitor the overall temperatures of the slow moving water as it passes through the shallow channels and pools (see Section 6 for details). Water temperature data will be collected in 15 minute intervals (when the sensor is combined with an electronic pressure transducer for measuring water levels) or in two hour intervals (for stand-alone sensors) and will be downloaded quarterly (for the electronic pressure transducers) and semi-annually (for the stand-alone temperature transducers). 6.3 Reporting
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Water temperature data will be reviewed to determine if any temperature issues are present (i.e. biologically significant differences between baseline and operating temperature regimes). The measured temperatures will be compared to the temperature database from the environmental baseline study to observe whether the diverted flow has any affect on the streams overall water temperature. The new measurements may be used to potentially predict and calculate extreme conditions to provide more accurate estimates of temperatures during extreme conditions, which may not be observed in the first few years of monitoring. The frequency of temperature monitoring may be reduced or terminated after five (5) years from the project commissioning should the measurements show that temperature changes are insignificant under the Projects operations and the predicted future conditions. Water temperature results will be reported annually. monitoring program are summarized in Table 3. Details of the water temperature
7.0
Fish Abundance and Biomass Density (Fish Community)
The primary objective of fish abundance and biomass density (also known as fish community) monitoring is to determine whether the fish populations decrease in the diversion reach during Project operations. The target species for monitoring of fish abundance and biomass will be rainbow trout, which were encountered in the upper end of the diversion reach; the secondary target species will be coho salmon, encountered at the lower end of the diversion reach. Rainbow trout were primarily observed upstream of the Mile 25 Bridge, although some were found in the Ashlu Canyon as they were washed down each year, and were survivors of a stocking program carried out by the Ministry of Environment in the 1980s in the upper reaches of Ashlu Creek. Coho salmon were observed in the lower end of the diversion reach (approximately 300 metres upstream of the powerhouse and tailrace location).While this short length of stream was used primarily for rearing and not spawning, it will be included in the monitoring program. The area downstream of the double bridges is known salmon spawning habitat. 7.1 Monitoring Locations The fish community will be monitored in four (4) reaches: one (1) "control" reach located upstream of the headpond on an undisturbed section of Ashlu Creek and three (3) impact reaches within the diversion reach. The control reach location will be upstream the upper limit of the headpond and downstream of the confluence of Pokosha Creek. The impact reaches will be at or near the Mile 25 bridge, in Ashlu Canyon along the gravel bar/side channel, and upstream of the powerhouse/tailrace area at the mouth of the Ashlu canyon. 7.2 Monitoring Approach and Analysis To observe the potential affects of the Project on fish, the following fish characteristics will be
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monitored and measured: Presence/absence; Distribution; Population density; Condition (health); and Age structure.
Rainbow trout abundance and density will be monitored at the upper monitoring locations (i.e. headpond, Mile 25 bridge, gravel bar) whereas coho salmon abundance and density will be monitored at the lower location (i.e. powerhouse/tailrace) only as coho salmon are limited to this reach due to the cascade at approximately 500 metres further upstream of the powerhouse/tailrace location. Within this lower reach, rainbow trout may also be encountered as they may be seasonally washed down through the Ashlu canyon to this location. Due to the low conductivity of Ashlu Creek, electrofishing has not typically been the most effective method for fish sampling, and therefore fish sampling will be primarily performed using Gee Traps. The Gee Traps will comprise fine mesh nets capable of barring rainbow trout fry and coho salmon. A minimum of five (5) replicate sample sites will be established in each of the control and impact reaches. Impacts of the headpond, caused by backwatering of the stream channel upstream of the water intake and weir, will also be monitored. Fish abundance sampling will be performed during project operations and the results comparing the observed densities in the baseline study to determine if the headpond has encouraged or displaced fish. Due to the greater depth of the headpond than the pre-project creek, angling will be used as the primary method of fish detection. During the fish abundance sampling, abundance in fish habitats approximately 100 m upstream and downstream of the intake (i.e. within the headpond and downstream of the IFR and fish ladder flow releases) will be evaluated by snorkelling and/or Gee Traps (or electrofishing, if possible) to determine fish quantity, species type and size class. Captured fish will be identified (type and species), body weight and fork length measured, and scale samples of adult taken for age identification prior to being returned to the stream. In addition, notes of the sampling area, its usability as habitat, and the water temperature and conductivity on the day of sampling will also be collected. 7.3 Reporting Based on the fish captured using the various methods, the presence/absence, distribution, population density, condition (health) and age structure of the fish will be reported. The same sampling sites will be used each year to allow paired comparisons of the fish capture in statistical tests and thereby increase statistical reliability as the program is performed over the five year period. The sampling sites will be georeferenced, photographed, and marked in the
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field to allow the same location to be used repeatedly each year. Sampling will take place during September or October when the flow in Ashlu Creek is low and also during the rainbow trout growing season. The headpond/IFR data will be used to evaluate the relative use of the headpond and habitat downstream of the intake structures by rainbow trout, and will provide evidence of any blockage to upstream movement. Fish abundance and biomass density results will be reported annually. Details of the fish abundance and biomass density monitoring program are summarized in Table 4.
8.0
Invertebrate Abundance and Biomass Density
The primary objective of invertebrate abundance and biomass density monitoring is to test whether invertebrates decrease in the diversion reach during Project operations. 8.1 Monitoring Locations Invertebrate abundance and biomass density will be monitored in three (3) locations: two (2) "control" reach located upstream and downstream of the Project, and one (1) impact reach within the diversion reach. The upper control reach location will be upstream the upper limit of the headpond and downstream of the confluence of Pokosha Creek; the lower control reach will be at or near the double bridges. The impact reach will be within the proposed diversion reach at or near the gravel bar in the Ashlu canyon. In addition, the sampling sites will be located in representative habitat in the downstream half of a riffle section, and to the extent possible, nets will be set in areas with water velocities of 0.2 to 0.4 m/sec. 8.2 Monitoring Approach and Analysis Abundance and distribution of macroinvertebrates in the drift will be characterized through the use of drift samplers, which are vertically fixed nets that are suspended in the water column. The samplers will be installed with rebar, set in the current and left to "fish" for a period. Drift samplers will be fixed plankton-type drift nets (30 x 30 cm mouth) with 250 m mesh to retain invertebrates of most importance to fish. Drift will be sampled in the daytime to reflect prey abundances available to fish and will be deployed for a sufficient period to gather an adequate drift sample (typically two hours, but may be shorter, depending on drift conditions. Two (2) replicate samples will be collected at each site on each sampling day according to the methods for collection and analysis of invertebrate drift as presented in Hatfield and Lewis (2007). Sites will be sampled at least once during the main growing season, usually May through September when the fish abundance surveys are being performed and during low to moderate flows. If additional samples are collected, the sampling dates will be separated by at least one (1) month. One (1) sample should be taken during base flow conditions; the other
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sample should be taken within the growing season prior to the period of lowest flows. Captured macroinvertebrates will be identified by type and species, as well as abundance (quantity). In addition, the sampling area and the water temperature on the day of sampling will also be noted.
8.3 Reporting Based on the macroinvertebrates captured, the presence/absence, type and species, quantity and population density will be reported. The same sampling sites will be used each year to allow paired comparisons of the macroinvertebrates capture in statistical tests and thereby increase statistical reliability as the program is performed over the required period. The sampling sites will be georeferenced, photographed, and marked in the field to allow the same location to be used repeatedly each year. Sampling will take place during September or October when the flow in Ashlu Creek is low and also during the rainbow trout growing season. The monitoring of invertebrate drift organism abundance and biomass density will be measured up to twice per year. Details of the invertebrate abundance and biomass density monitoring program are summarized in Table 5.
9.0
Compensatory Fish Habitat Efficacy
The primary objective of compensatory fish habitat efficacy monitoring is to monitor the performance of project mitigation and compensation habitats, which will be evaluated following project commissioning after one (1) and five (5) years of operation. 9.1 Monitoring Locations Compensatory fish habitat efficacy will be monitored at two (2) locations: the fish ladder, at the intake and weir area, and the new fish compensation habitat on the Ashlu delta. 9.2 9.2.1 Monitoring Approach and Analysis Fish Ladder The efficacy of rainbow trout passage past the water intake will be evaluated qualitatively by an inspection of the fish ladder each year during the period of rainbow trout movement (typically in April/May). The fish ladder will be examined, and measurements of depths and velocities at key locations within the ladder will be taken to provide information on the flow conditions and on the discharge through the ladder. Periodic observations will be made to check on fish passage either in the ladder or at the staging area below the ladder. 9.2.2 Rearing Fish Compensation Mitigation and compensation habitat for the Project was created on the Ashlu delta
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primarily for coho salmon, with secondary works for rainbow trout/steelhead, as directed by DFO and MOE. The compensatory fish habitat for coho salmon comprises a series of new channels, pools and the interconnection of existing, intermittent channels along the Ashlu flood plain into the existing DFO developed pools and channels created in the late 1990s. Construction of the new habitat was supervised by an on-site DFO representative in June 2007 and May 2008, with overview by the Environmental Monitor and Proponent to assist in the channel and pool layouts. Once the compensatory habitat was built in 2007, occasional visits were made to review the conformance with the design specifications, and to ensure post-construction inspection to ensure adherence to the original compensation plan for the Project. In 2008, some modifications were performed to optimize flows, and additional channels and pools were independently added on by DFO to interconnect to Buck Creek, located further north on the Ashlu delta. The compensatory fish habitat for rainbow trout/steelhead comprised several triangulated debris jams (i.e. root wad and log structures) that were installed in 2007 by MOEs representative in and around the original DFO habitat as well as along the north bank of Ashlu Creek. Additional work was carried out in 2008 to fine-tune this habitat work, and was carried out under supervision of DFOs representative. The fish compensatory habitat will be examined, and measurements of depths and velocities at key locations within the streams and pools will be taken to provide information on the flow conditions and discharge through the system. Periodic observations will be made to check on fish utilization in the channels and pools. Utilization of the fish ladder and compensatory habitat will be through observations and photographs. 9.3 Reporting Coho salmon presence/absence, and the physical integrity, stability and erosion of the new habitat channels will be noted for the compensatory habitat, whereas rainbow trout presence/absence only will be noted for the fish ladder. Temperature will be monitored in the fish compensation habitat using a single continuous recorder, as described in Section 3. This sensor will be located in the large pool or in the adjacent large culvert located on the north side of the existing Forest Service Road and at the base of Buck Mountain. Details of the compensatory fish habitat efficacy monitoring program are summarized in Table 6.
10.0 Stream Channel Morphology

The primary objective of compensatory fish habitat efficacy monitoring is to assess any potential impacts that the Project has on channel stability and sediment conditions during operations.
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10.1 Monitoring Locations Stream channel morphology will be monitored at three (3) locations: in the headpond, the diversion reach at the gravel bar in the Ashlu canyon, and at or near the double bridges (downstream of the powerhouse/tailrace). 10.2 Monitoring Approach and Analysis To determine whether there are any changes in the stream channel morphology during Project operations, data will be collected prior to project completion to provide a baseline data set, and either (a) after a large flood event (the first 1 in 10-year event or greater event as determined by hydrology at the point of diversion) or (b) at the end of five (5) years of post-construction monitoring, whichever comes first. During operations, periodic observations will be made to identify any changes to the habitat in the diversion reach over time in the designated areas. Transects will be carried out to measure the quantity of change of the stream channel shape and size. These transects will allow for a comparison of the changing stream channel and will aid in assessing whether the IFR is affecting any of the fish habitat as was originally predicted. For the headpond, transects will likely not be achievable due to the depth of the headpond; as an alternative, bathometry may be used to map the profile of the headpond. At the headpond, the change in the bathometry profile of the base of the headpond will allow the rate of sediment infilling to be determined. In the diversion reach, the transect measurements will show how often the gravel bar side channel is wetted and used by rainbow trout. At the double bridges, the transect measurements will show if the channel profiles are changing on gradual basis during operations or if the channel profiles change only after large flood events as is currently the pre-Project case. 10.3 Reporting Transect cross sections and headpond bathometry profiles will be presented, as well as a description of any changes to these sections and their apparent affect on fish habitat. The sampling sites will be georeferenced, photographed, and marked in the field to allow the same location to be used repeatedly each year. The stream channel morphology results will be reported annually. Details of the stream channel morphology monitoring program are summarized in Table 7.
11.0 Instream Flow Requirement

The primary objective of monitoring water flows is to ensure the instream flow requirements (IFRs) are met. 11.1 Monitoring Locations
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The primary gauge for IFR measurement is at the first suitable location downstream of the intake which is the transition from a relatively flat gravel and boulder field into a bedrock canyon, approximately 250 m downstream of the intake. A pressure transducer level probe is installed in this location and connected to the intake control building by a teck cable suitable for direct burial. The water level is measured on a continuous basis and relayed to the powerhouse control system in real time. A water level benchmark corresponding with the 2.42 m/s IFR required under the DFO Authorization has been established in March 2009 and will serve as a visual reference to calibrate the level probe. A secondary gauge for backup and calibration purposes is installed in the diversion reach at the Mile 25 Bridge location. Approximately 10% of the flows measured at this location are attributed to a small tributary between intake and this location. Therefore, the IFR immediately downstream of the intake is approximately 90% of the flow measured at this location. The secondary station is powered by a solar panel with battery backup and direct radio link to the powerhouse. The station also provides data required under the DFO Authorization and houses a kayaker warning system as required by NWPD. 11.2 Monitoring Approach and Analysis IFRs for this project are defined in the Authorization issued by DFO and the Approval issued by NWPD. It is noted that when the two documents call for different minimum flows at the same time, the higher flow will be released. 11.2.1 Requirements under DFO DFO Authorization 04-HPAC-PA2-000-000530 sets the minimum IFR at 2.42 m/s year around with no seasonal adjustments required. This flow is primary provided through a 30 inch bypass pipe has been installed as part of the sluiceway structure. The center inlet elevation of the pipe is 272.0 meters, while the normal operating water level is 276.0. The inlet is protected by a coarse trash rack and the inflow can be controlled by a manually actuated knife valve. The IFR valve will be calibrated to the required minimum flow during the commissioning of the plant. Because the water level in the head pond will remain nearly unchanged during normal operation, it is not expected that the valve requires adjustments during the operational phase of the project. The sluiceway flap gate acts as a backup system to meet the IFR in case the 30 inch pipe is not providing the required flows or is shut down for maintenance and repair works. The capacity of the flap gate is approximately 3 m/s at normal head pond operating water level. 11.2.2 Requirements under Transport Canada / Navigable Waters Protection Division Approval #8200-T-10595.2 issued by NWPD calls for instream flow releases to accommodate recreational use of the creek through kayakers during specific days and times as follows if pre-booked by kayakers:
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Four weekends (Saturdays and Sundays) in May and eight weekends (Saturday and Sundays) in August and September for a total of 24 days and on each of those days between 9am and 6pm Flow release to range between 16 m/s and 32 m/s. Amounts of actual release to be coordinated between ACILP and the kayakers.
An online booking system is being developed to meet the spring 2010 kayaking season. The system will allow kayakers to book flow release days within the windows described above and select their preferred release rate within the required range. Flows for kayaking purposes will be primarily released and controlled through the sluiceway. 11.3 Reporting All data, raw and analyzed will be made available to the regulatory agencies throughout the season. Monitoring of stream flows will be maintained throughout the life of the project and may be used with other effectiveness and compliance monitoring programs. Details of the IFR monitoring program are summarized in Table 8.
12.0 Ramping
The primary objective is to assess the efficacy of Proponents proposed ramping rate. 12.1 Monitoring Locations Ramping will be monitored at three (3) locations: in the diversion reach immediately downstream of the water intake and weir and at the gravel bar within Ashlu canyon, and downstream of the diversion reach at the double bridges. 12.2 Monitoring Approach and Analysis During commissioning, normal operation, start ups, normal shut downs and emergency shut downs, the ramping rates shall not exceed 29.0 m3/sec per 90 minutes. This rate will be confirmed during the commissioning process of the plant and may be subject to different flow conditions in the creek. This rate was based on the natural ramping rates that have been historically observed in Ashlu Creek over several years since 1991 when a dedicated hydrometric station was first established on the stream. Ramping rates will be monitored during commissioning of the Project to measure water level change rates and their resulting changes to fish habitat (i.e. dewatering of side channels and the potential stranding of fish). During project commissioning, the efficacy of this rate will be tested by ramping down at the specified rate and measuring the resulting water level change in the sensitive habitats in the diversion reach and further downstream where all of the diverted and IFR flows converge. The ramping rate test will occur when fry and juvenile rainbow trout are present. If the Project is
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commissioned when fry and juveniles are not present (i.e. January to May), an additional test will be made when flows are below design flow levels and when fry and juveniles are present. Once determined, the ramping rate will be used throughout the operation of the Project. To monitor the effect of ramping during Project commissioning, temporary (or permanent) water level gauges will be installed at the key sites, and will consist of a manual gauge plate (approximately 60 cm in height) fixed to the bank, large boulder, large woody debris or hammered in the stream bed. In addition, the water level data measured by the electronic transducers at the hydrometric stations (installed as per Section 1) will also be collected. The habitat and water levels at the monitoring locations will be observed and measured by a biologist, who will be stationed at each monitoring station during the ramping test, to document any incidences of fish stranding. The biologist will collect the baseline habitat data and visually observe for any fish presence/absence. Habitat data will include dominant stream cover types, substrate composition and a general description, including GPS coordinates. A photo monitoring station will be established at each site, and photos will be collected (and repeated) at each of the cross-sections measured. Drawings of each site showing the location of photo monitoring stations and gauge locations will be prepared. The sites will be monitored at the beginning and end of each ramping commissioning test to document the extent of flooding and collected habitat measurements. At each site, the wetted widths and wetted lengths of any isolated pools will be measured along with measurements of water level changes from the staff gauges. Temporary cross-sectional pins will be set in the ground to identify the locations where wetted widths and lengths are to be collected pre-and post-ramping. Where wetted areas become dry post-ramp, substrate will be excavated by hand and overturned to confirm fish presence/absence. Any fish found will be captured, enumerated by species and age class, and their reason for stranding will be recorded (i.e. fish isolated in a pool or habitat was dewatered). Following project commissioning, the water level sensors hydrometric stations (as installed in Section 1) will record water level changes annually for one (1) to five (5) years in the diversion reach. 12.3 Reporting Photos of each key monitoring site at specific flows will be provided for each of the monitoring stations. Cross-sections of each monitoring site will be prepared and will show the stream profiles, water level changes and gauge locations from the transect measurements. In addition, a description of the dominant stream cover types and substrate composition will accompany the cross-sections. The ramping results will be reported within six months after Project commissioning is completed. Details of the ramping monitoring program are summarized in Table 9.
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13.0 Footprint Impact Verification

The primary objective of footprint impact verification is to assess and quantify whether the asbuilt Project footprint impacts aquatic and riparian habitats. 13.1 Monitoring Locations Footprint impact verification will be measured at the intake and weir, powerhouse, tailrace, switchyard, portions of the access roads (leading down to the intake, powerhouse, switchyard) and portions of the transmission line, as these areas are located instream and/or within the riparian zone of Ashlu Creek. 13.2 Monitoring Approach and Analysis Impacts on aquatic and riparian habitat will be verified through direct on-site measurements. The physical dimensions of each right-of-way or clearing that impacts a riparian zone or an aquatic habitat will be measured in the field and documented with photographs. For aquatic habitat, the bed material will be described in the impact zones (i.e. concrete, rip-rap), while for riparian habitat, the condition of the reseeding/replanting will be documented. The monitoring of the effectiveness of re-vegetation will take place for one (1) year following the completion of construction and late in the growing season, when a full season of growth will be evident. Successful replanting will be evidenced by a survival rate of 80% of the stock; if more than 20% of the planted stock dies over one year, replanting will be required. Replanting of lost vegetation should occur within eight months of disturbance, with stock planted during the fall and spring to ensure the greatest likelihood of survival. Once planted, brushing around seedlings may be required to remove competing vegetation and additional erosion control may be required to stabilize vegetation on steep, erodible soils and ensure long-term vegetation success. 13.3 Reporting The effectiveness of the re-vegetation and any replanting requirements will be documented so that they can be planned and completed the following year during the growing season. The footprint impact verification results will be reported annually. Details of the footprint impact verification monitoring program are summarized in Table 10.
14.0 Reporting
The objectives, methods, results and recommendations for changes to and/or additional monitoring will be provided in annual or more frequent reports, depending on the component of interest. The timing of reporting for the monitoring programs will vary by component, however annual reports will be prepared for all, except those components that only require a one-time study (documented in a single report) or those that require more frequent monitoring.
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All baseline monitoring data will be compiled in a report for agency review by March 31, 2010 following the year in which project construction is complete. In each year following this, an annual report will be submitted to DFO and MOE that documents the findings of the previous year's study. After five (5) years of post-project monitoring, a summary report will be completed that evaluates the need for additional monitoring. Section 8 (ramping) will be reported on within six (6) months of the completion of commissioning tests during which the ramping rate will be tested and refined. Section 9 (footprint impact verification) will be reported on by March 31, 2011 of the year following the completion of construction or earlier if the mitigation of disturbed areas has been completed. Annual reporting of project components will be standard for each component. All reports will be certified by an appropriately qualified professional registered biologist as required.
15.0 Exclusions
Post-construction monitoring of Harlequin Ducks and Grizzly Bears will be carried out and reports issued to Environment Canada and the MOE, respectively, as per their regulatory permitting requirements. Therefore, these species have not been included in the Program.
16.0 References
16.1 General References
Hatfield, T. and A.F. Lewis. 2007 (draft). Guidelines for the collection and analysis of data on fish and fish habitat in small steep streams. Prepared by Ecological Research Ltd. and Ecofish Research Ltd. for the BC Ministry of Environment, Surrey BC. Lewis, A., T. Hatfield, B. Chilibeck, and C. Roberts. 2004. Assessment methods of aquatic habitat and instream flow characteristics in support of application to dam, divert, or extract water from streams in BC. Ministry of Water, Land, and Air Protection, and the Ministry of Sustainable Resource Management, Victoria, BC. 101 pp. LWBC 2004. Hydrological Guidelines for Waterpower Projects, October 2004. Completed by the Surrey Regional Office, Land and Water Management Division, Suite 200-10428 153rd Street, Surrey, BC V3R 1E1. 20 pp. RISC. 1998a. Manual of Standard Operating Procedures for Hydrometric Surveys in British Columbia. Prepared for the Resource Inventory Standards Committee. Roper, B.B., J.L. Kershner, E. Archer, R. Henderson, and N. Bouwes. 2002. An evaluation of physical stream habitat attributes used to monitor streams. J. Am. Water Resource Assoc. 38: 1637 1646. 16.2 Project-Specific References
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Ashlu Creek Green Power Project Fish Ladder Design Modifications. Prepared by Ashlu Creek Investments Limited Partnership. March 3, 2008. Ashlu Creek Green Power Project Construction Environmental Management Plan Revision J. Prepared by Sigma Engineering Ltd. and modified by Ledcor Power Inc. November 8, 2006 (updated from original May 2004). Authorization for Works or Undertakings Causing the Harmful Alteration, Disruption or Destruction of Fish Habitat and Destruction of Fish (Authorization No. 04-HPAC-PA2000-000530). Prepared by Fisheries and Oceans Canada. July 31, 2006. 2005 Environmental Assessment Addendum for the Ashlu Creek Hydroelectric Project. Prepared by TRC Biological Ltd. September 1, 2005. Ashlu Creek Project South Side Channel Short-Term Compensation. Prepared by Ledcor Power Inc. February 28, 2005. Ashlu Creek Project Denil Fishway Design Proposal. February 3, 2005. Prepared by Ledcor Power Inc.
Ashlu Creek IPP Compensation for Steelhead Trout. Ministry of Water, Land and Air Protection to Fisheries and Oceans Canada. November 25, 2004. CEAA Screening Report Ledcor Power Inc.s Proposed Run-of-River Hydro Project on Ashlu Creek, BC. Prepared by Department of Fisheries and Oceans, Habitat and Enhancement Branch, Major Projects Review Unit (Vancouver, B.C.). October 18, 2004. Ashlu Creek Project Species at Risk Summary letter. Sigma Engineering Ltd. October 8, 2004. Ashlu Creek Project - Response to Environment Canada September 10, 2004 Letter. Prepared by Ledcor Power Inc. October 7, 2004. Ashlu Creek Hydroelectric Project Habitat Balance. Prepared by Sigma Engineering. September 2004 (updated from March 2004). Ashlu Creek Project Flow Ramping Rate Amendment. Prepared by Ledcor Power Inc. May 28, 2004. Ashlu Creek Run-of-River Power Project. Prepared by Fisheries and Oceans Canada. April 21, 2004. Ashlu Creek Power Project Species at Risk. Prepared by Sigma Engineering. June 7, 2004. 2003 Environmental Assessment Addendum for the Ashlu Creek Hydroelectric Project. Prepared by Sigma Engineering Ltd. April 13, 2004. Ashlu Creek Hydroelectric Project Habitat Balance. Prepared by Sigma Engineering Ltd. March 18, 2004. Ashlu Creek Water Power Project Wildlife Addendum to the Ashlu Creek Development Plan. Prepared by Sigma Engineering Ltd. January 9, 2004. 2003 Environmental Assessment Addendum for the Ashlu Creek Hydroelectric Project. Prepared by Sigma Engineering. April 13, 2004. Ashlu Creek Project Flow Ramping Rate Recommendation. Prepared by Ledcor Power Inc.
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March 29, 2004. Ashlu Creek Updated Hydrology Report. Prepared by Knight Pisold Consulting. February 25, 2004. Ashlu Creek Power Project - Wildlife Addendum to the Development Plan. Prepared by Sigma Engineering. November 28, 2003 Ashlu Creek Project Minimum Flow Recommendation. Prepared by Ledcor Power Inc. November 21, 2003. Ashlu Creek Hydroelectric Hydrology Report. Prepared by Sigma Engineering Ltd. October, 2002.
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Table 1. Objective Description Criteria Location Duration
Methods Sample area Units Sensitivity/accuracy Sample no.
Frequency Timing Measure constraints Analytical test
Water flow To ensure compliance with flow releases. Water level pressure sensors and manual flow discharge measurements. Flow discharge measurements over a range of flows (between 10% and 200% MAD). In the headpond; downstream of the intake structures; at the Mile 25 Bridge; downstream of powerhouse/tailrace. Headpond stage monitoring for the life of the project. Discharge measurements may be terminated when biotic response monitoring is complete five (5) years after project commencement provided that headpond stage has been shown to accurately measure channel flow in the diversion reach. Continuous pressure transducers; calibrated with manual velocity meters. Headpond; in stream channel downstream of intake, Mile 25 Bridge, downstream of powerhouse/tailrace. 3 Water level in mm and flow in m /s. +/- 2 mm for pressure transducers. To calibrate pressure sensors, minimum of three (3) discharge measurements (20+ vertical stream measurement slices) per transect; for headpond sensors, three (3) measurements. 15 second scan and two (2) minute log for headpond sensor; 15 minute scan and one (1) hour log for stream flow sensors. Continuous. For pressure transducers, select location on stream with adequate protection from debris for the standpipe; avoid placing transducer downstream of major local inflow, and avoid sites that dewater in low flow. n/a (compliance monitoring).
Water quality To test whether water quality changes in the diversion reach during operations. Dissolved oxygen, total gas pressure (TGP), turbidity, total suspended solids (TSS) , specific conductance, total alkalinity, pH, total phosphorus, ortho-phosphorus, ammonia, nitrite, and nitrate Pre-construction (2 years) Upstream of headpond (control reach), in diversion reach (impact reach), and downstream of diversion reach. Two (2) year baseline and five (5) year post-construction mean. In-situ data collection (water quality meters) and sample collections for laboratory analysis. Spot locations in upstream reach above influence of headpond; in stream channel in diversion reach upstream and above influence of tailrace; at double bridges and downstream of tailrace return water. Varies by parameter. Varies by parameter. One (1) site in each sample area, three (3) per sampling event. Semi-annually Pre-construction: during typical flows of each season; post-construction: low flow periods near the beginning and end of the growing season Select sites avoiding sites immediately downstream of significant local inflow BACI: normalize data and use or use bootstrapping tests of difference between groups (rotating comparisons) if data normalization tests
Criteria Location Duration Methods Sample area
Units Sensitivity/accuracy Sample no. Frequency Timing Measure constraints Analytical test
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Water temperature To assess whether water temperature changes in the diversion reach due to the diversion of water during operations. Temperature. Pre-construction (2 years) maximum, minimum and mean in critical periods. Headpond, diversion reach, at powerhouse/tailrace, double bridges (downstream of tailrace), new fish compensatory habitat areas. Two (2) year pre-construction baseline and five (5) year post-construction. Continuous temperature recorders (may be incorporated with water level sensors) Fixed locations in headpond, diversion reach, powerhouse/tailrace, double bridges (downstream of tailrace), in new fish compensatory habitat areas. Degrees Celsius. +/- 0.1 deg. C One (1) sensor in each location. Hourly. Continuous (15 minutes with incorporated water level sensor; 2 hours for standalone sensor). Select site away from temperature edge effects; avoid sites that dewater in low flow. BACI: express in appropriate format for issues. For fish rearing: degree days in growing season, days >18, >20, <1.
Fish abundance and biomass density To test whether fish abundance decreases in the diversion reach during operations. Number of fish by species and life stage per unit area; body weight and fork length of all fish captured; scale samples of adult fish; area of sampling; usability of habitat; temperature and conductivity. Pre-construction (2 years) mean. Upstream of headpond (control); headpond, diversion reach at Mile 25 Bridge, diversion reach in Ashlu Canyon, diversion reach below cascade in Ashlu Canyon (impact). Two (2) year pre-construction baseline and five (5) year post-construction mean. (a) Gee Traps; (b) angling; (c) snorkelling; (d) electrofishing; (e) on-site measurement of fork length and weight; (f) scale collection; (g) lab analysis of age; photo documentation of site; measure depth, velocity and substrate in enclosure to quantify usability (see Hatfield and Lewis 2007). 2 2 Minimum 100 m per site: greater area required if fish density <0.1 fish/m . no. fish/m2; g/m2 +/- 0.1 g 10 total; five (5) in control reach; five (5) in each section of impact reach. Annually. Late growing season (August to October). Conduct when flows are between 10 and 20% MAD; water clarity >30 cm; and water temperature >= 7 deg. C; release all fish unharmed; standardize effort by area and intensity; measure habitat usability to standardize areal unit measure. BACI: normalize data and use ANOVA or use bootstrapping tests of difference between groups (rotating comparisons) if data fail normalization tests.
Criteria Location
Duration Methods
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Invertebrate abundance and biomass density To test whether invertebrates decrease in the diversion reach during operations. Number and biomass of invertebrates by per unit flow; diversity. Pre-construction (minimum 1 year) mean. Upstream of headpond (control); diversion reach at gravel bar in Ashlu canyon and at double bridges (impact). Minimum one (1) year pre-construction baseline and one (1) year post-construction. (a) drift net samples fish for hours; (b) taxamonic id to genera or family; (c) photo documentation of site; (d) measure depth and velocity and discharge to quantify flow (see Hatfield and Lewis 2007). Drift net sampler (30 cm x 30 cm mouth, 100 cm length); 250 m mesh. No. and biomass of invertebrates per # of taxamonic. +/- 1 Three (3) in total; two (2) in control reach and one (1) in impact reach At least once per year in the growing season (May to September); twice preferred, if practical, and separated by one month. Under base flow conditions in the rainbow trout growing season. Conduct when flows are between 10 and 20% MAD; water m3/s; and water temperature traps placed in downstream half of riffles. BACI: normalize data and use or use bootstrapping tests of difference between groups (rotating comparisons) if data fail normalization tests. Compensation fish habitat efficacy To evaluate the performance of compensation habitats in compensating for lost habitat, and the effectiveness of migration. Measurement of habitat dimensions, evaluation of habitat quality through physical parameter measurements (stability, erosion), and monitoring of water level and temperature. Confirmation of fish use of compensation habitats through juvenile and adult fish observations. Examine fish ladder annually and comment on condition and apparent efficacy using fish abundance data for inference. Should habitat characteristics change such that habitat suitability is reduced, the compensation habitats will be restored as necessary. Intake (fish ladder) and compensation habitat on Ashlu delta. Up to five (5) years post-construction. Evaluation will be done by observation of fish presence/absence. Water temperature and level measurements will generally follow the guidance in Tables 1 and 3. Fish ladder and compensation habitat.
2 2 2 no. fish/ m ; g/m , deg. C, m , water level in mm
Criteria Location Duration Methods Sample area Units Sensitivity/accuracy Sample no. Frequency Timing
+/- 0.1 g; +/- 0.1 deg. C, +/- 2 mm (water level) Two (2) samples of fish abundance in compensation habitat; single survey of fish ladder use. Fish abundance and density annually; physical characteristics when the compensation habitat is completed, after one (1) and five (5) years of operation Year round for temperature and level for compensatory habitat only; fish observations in late growing season for coho salmon (August to October) for compensatory habitat; fish observations in rainbow trout migration season (April/May). Conduct when flows are between 10 and 20%, water clarity >30 cm; and water temperature release all fish unharmed; standardize effort by area and intensity; measure habitat usability to standardize areal unit measure. BACI design or variant: integrate with impact and control measures taken in other areas.
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Table 7. Objective
Description Criteria Location Duration Methods Sample area Units Sensitivity/accuracy Sample no. Frequency Timing Measure constraints Analytical test
Stream channel morphology To assess project impacts on channel stability and sediment conditions during operations in the headpond area, the diversion reach, and downstream of the powerhouse/tailrace Substrate surveys through transect surveys; photo transect survey points. Pre-construction and post-construction, following 1:10 year flood event or for five (5) years, whichever comes first. Headpond; in the diversion reach at the gravel bar in Ashlu canyon; at the double bridges. Pre-operational and after 1:10 year flood event or after five years, whichever comes first. Transect surveys in diversion and downstream reaches; bathometry topographical survey in the headpond. n/a n/a n/a Detailed transect survey: one (1) transect in diversion reach and one (1) at double bridges; bathymetry survey at headpond. Once pre-project, once after 1:10 year flood event or after 5 years, whichever comes first. Post-freshet: transects after large flood event (1:10 year flood). n/a n/a
Instream Flow Requirement To ensure compliance with the specified instream flow requirement. Water level pressure sensors and manual flow discharge measurements. 2.42 m3/s year round or 16 m3/s to 32 m3/s if pre-booked during 4 weekends in May and 8 weekends in August and September. Approximately 250m downstream of the intake structure Life of the project. Continuous pressure transducer n/a cm staff gauges; m3/s - discharge +/- 2 mm for pressure transducers. To calibrate pressure sensors, minimum of three (3) discharge measurements (20+ vertical stream measurement slices) per transect; for headpond sensors. 15 minute scan and one (1) hour log for stream flow sensors. Continuous. For pressure transducers, select location on stream with adequate protection from debris for the standpipe; avoid placing transducer downstream of major local inflow, and avoid sites that dewater in low flow. n/a
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Flow Ramping Assess the efficacy of prescribed ramping rates. Monitor ramping rates, survey for fish stranding. 15 m3/s per hour proposed rate when fry and juvenile fish are present. In diversion reach: immediately downstream of the intake/weir; the gravel bar and side channel in Ashlu canyon; downstream of diversion reach at double bridges. During project commencement to establish ramping rates. Ramp down and measure the resulting water level change in sensitive habitats in diversion reach and below diversion reach; observe sensitive habitats for fish stranding. Spot locations in sensitive habitats in diversion reach and below diversion reach. m3/s per hour (or equivalent cm/hr); number of stranded fish. +/- 2 mm Variable. During project commissioning. When fry and juvenile fish are present; if a project is commissioned when fry and juveniles are not present (January to May), an additional test will be made when flows are below design flow levels and when fry and juveniles are present (worst case conditions). n/a n/a
Sample area Units Sensitivity/accuracy Sample no. Frequency Timing
Footprint impact verification Quantify as-built footprint impact areas and characteristics. Measure extent and magnitude of impact of project structures on instream and within riparian zones. Ground measures and characteristics laid out in impact assessment reports. Intake, weir, powerhouse, tailrace, switchyard, access roads, transmission line. One time measurement following project construction. Measurements on the ground and/or from aerial photos based of the overlap of project structures and work areas: evaluation of magnitude of effect based on impact assessment criteria. Document instream bed characteristics and riparian condition. Document success of re-vegetation and replant areas. Ground measurement of impacted riparian or instream areas, supported with length and width measurements of individual sites. m2 +/- 10% n/a One time measurement. One year after construction, when mitigation of disturbed areas has been completed. n/a n/a
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Birchard, Leona ENV:EX

From: Sent: To: Cc: Subject: Attachments: Bennett, Timothy A ENV:EX Friday, December 18, 2009 3:12 PM 'Robert Kulka' Babakaiff, Scott C ENV:EX; XT:Busto, Vince DFO EAO:IN; 'gsteeves@ameresco.com'; 'Richard Blanchet'; 'Kelly Boychuk' RE: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management Plan Ashlu OEMP - Rev B.PDF; image001.jpg
HiRobert, ThankyouforprovidingyourdraftOEMPforourreview. Staffhaverevieweditandprovidedthefollowingpreliminarycomments: 1. ReportAuthorshipunknown:Thereportshouldbepreparedandsignedbyappropriatelyqualifiedlicensed professional(s)(e.g.,RPBio). 2. Fewcommitmentstofollowcommonlyacceptedguidelinesfordatacollection&analysis,despitea proposalthatmonitoringdetailsmeettherequirementsofDFOandMOE(p.6oftheOEMP).Many detailsproposedintheOEMPareseeminglyarbitraryanddonotreferenceanyguidelinesorstandards typicallyreferencedbyProvincialorFederalagencies.Forinstance: 1. StagedischargeratingcurvestheOEMPcommitstocollectingaminimumofthreedischarge measurementsandwarnsthat...itisunlikelythatflowswillbeabletobemeasuredabove20%of meanannualdischarge.Thereareclearandwellestablishedguidelinesfordevelopingstage dischargeratingcurves(e.g.LWBCHydrometricGuidelines;B.C.ProvincialHydrometricStandards (see http://www.env.gov.bc.ca/fia/documents/Manual%20of%20British%20Columbia%20Hydrometric% 20Standards%20V1.0,%20March%2012,%202009.pdf)thattheproponentisrecommendedtomeet. 2. Reportingofstreamflowdata:theOEMPcommitstocollecttocollectflowdataonacontinuous basis,typicallyin15minuteintervalsandpromisesthatdatawillberecorded...andcanbe providedtoonsiteDFOand/orMOEstaff...forcompliancepurposes...flowdatawillbereported quarterly.Isuggestthereisnoneedtosubmitdatatoreviewagenciesmorefrequentlythanonce peryear,butagenciesmustbeinformedwithin24hoursofanynoncompliance(e.g.IFRprovision, rampingrates),andtheproponentmustresolvetheissueofnoncomplianceimmediately.Interms ofdatacollection&logging,InotethattheBCProvincialHydrometricStandards(Section3.2.2.3) recommendsastagereadingevery15minutes,butadvisesthat"thisisaminimum requirement...sitespecificflowregimesmaynecessitateashorterfrequency...".Forpurposesof verifyingcompliancewithflowrampingrequirementsinfishbearingwaters,particularlythosewith thediversityoffishvaluesintheAshludiversionreach,Iwouldrecommendamuchshorterstage samplingfrequency(say,10second),witha2minuteaverageforstorageinthedatalogger(and submissiontoagencies).Iwouldalsorecommendthatdatabedownloadedfromtheloggerona frequencynolessthanoncepermonth,toensurethatanyequipmentmalfunctions(e.g.battery loss,equipmentdamage)donotresultinlengthydatagaps.Forpurposesofgraphicalpresentation inmonitoringreports,itmaybehelpfultoapplyanhourlyaveragetothe2minutestagedata. 3. Developmentoframpingrates:Section12.2oftheOEMPproposesthattherampingratesshall notexceed29.0cmsper90minutes.Thisratewillbeestablishedduringthecommissioningprocess oftheplant,andmaybesubjecttodifferentflowconditionsinthecreek.Thisratewasbasedon thenaturalrampingratesthathavebeenhistoricallyobservedinAshluCreekoverseveralyears since1991....TheOEMPprovidessomedetailregardingproposedmethodsforestablishing rampingratesduringcommissioning,butIwouldsuggestthatsuchprotocol(andsuchinterimrates like29cmsper90minutes)shouldbeestablishedandscientificallyjustifiedbyanexperienced professional,withreferencetoestablishedagencycriteria(e.g.DFOsdefaulthourlyrampingrates of2.5cm&5.0cmforfry&juveniles)orrecommendedguidelines.Finally,Isuggestthatthe commitmentwithinSection14oftheOEMPtosubmittherampingratereportsixmonthsafter
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commissioningrepresentsaninappropriaterisktofish&fishhabitatgiventherapidinterim rampingrateproposedandthefishvaluespresentinthediversionreach. 4. FishAbundance(Section7)&InvertebrateDensity(Section8):nomethodologicalguidelinesfor datacollectionoranalysisareproposed,despitethebibliographicreferenceinSection16ofthe OEMPtoHatfield&Lewis(2007).TheMOEESDinformationchecklistprovidedintheProvincialIPP GuidebookalsoprovidessupplementalguidanceforOEMPdevelopment.Itismyunderstanding thatthebaselinebiologicaldatacollectedinrecentyearsdidnotfollowanyparticularprotocol,but wasundertakenbyseveraldifferentbiologistsindifferentlocations,usingdifferentmethods.As such,itisimperativethatallbaselinedatabecollatedandassessedbyaprofessionalbiologistwith experienceintherelevantspecialization(ie.fisheriesbiology,macroinvertebratebiology),and compiledforassessmentregardingitsadequacyasabaselinetoassessfuturechangesthatmaybe attributabletooperationoftheIPPfacility.Onthisnote...
3. Nobaselinedataorpoweranalysis:theadequacyofthemonitoringdetailsproposedintheOEMP(e.g.
durationandfrequencyofsampling,expectednaturalvariability,samplesizes,methodsofanalysis,apriori agreementonecologicallyacceptablethresholdsofdependentvariables,corrective/compensatory measurestobeadopteduponthresholdexceedance,monitoringprogrambudgets,etc.)cannotbe objectivelyconsideredwithoutpreliminaryanalysisofbaselinedata,includingstatisticalpoweranalysis.In theabsenceofsuchanalyses,particularlyforthebiologicaldatadescribedinSections6&7oftheOEMP,I havelittleconfidenceintheadequacyofprediversionbaselinedatadescribedintheOEMPtoassessany diversioninducedchangesinthesebiologicalresponsevariables. 4. DetailsofmonitoringcommitmentstabulatedintheAppendixoftheOEMPdonotseemcongruentwith textinthebodyoftheOEMP.Forinstance,page3oftheOEMPclearlystates:InthecaseoftheAshlu Project,baselinestudieswerecarriedoutfrom2001to2006,aperiodoffive(5)yearsandweredoneprior tothenewProvincialguidelines(HatfieldandLewis,2007);therefore,notallofthecriteriaoutlinedinthe guidelinesforcontrolsiteshavebeenimplementedduringthesepreviousstudies.However,monitoring proposedforsomecomponents(e.g.biologicalcomponentsfromTables35oftheOEMP)havebeencopied verbatimfromtheguidelines(which,incidentally,arenotreferencedcorrectly)andsubsequentcasestudy (TroutCreek),soitisunclearwhataspectsofthemonitoringcriteriawillorwillnotbeundertakenperthe OEMP. 5. Prediversionactivitieswhichmayrequireseveralmonthstocompletehaveyettohavebeeninitiated. Forinstance: 1. installationofthefourpressuretransducers(perSection4.2.1oftheOEMP)anddevelopmentof associatedratingcurvesforwaterflow(Section4)andinstreamflow(Section11)monitoring; 2. Collectionofstreamchannelmorphologydata(perSection10oftheOEMP).Thiscomponentofthe OEMPisparticularlyilldefined:therearenoexplicitguidelinesorstandardsreferenced,andIalso questiontheproposedbenefitsofcompletingrepeatsurveysatafewtransectstoassesswhether theIFRisaffectanyofthefishhabitataswasoriginallypredicted.Assessmentofchangesin channelmorphologyrelatedtoprojectoperations(e.g.flowdiversion,changesinsedimentand LWDtransportratesandvolumes,etc.)iscrucial,butshouldbeconsideredmoreholisticallyusing lowlevelairphotosandlongitudinalsurveyprofiles.Again,itisrecommendedthatanprofessional experiencedwithdevelopmentofchannelmonitoringprograms(ie.afluvialgeomorphologistor riverengineer)betaskedwithdevelopingthestudydesignandundertakingtheworkpriortofinal commissioning; IalsonotethatitappearsthisdraftOEMPwasprovidedtoDFOinMay2009;wereearliercopiessubmittedtoMoE? Ifyouhaveanyquestionsinthisregard,pleasedonothesitatetocontactmeorScottBabakaiff. Regards,
TimothyBennett,M.Sc.,P.Eng. SectionHead,WaterAllocation WaterStewardshipDivision
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MinistryofEnvironment
From: Robert Kulka [mailto:RKulka@innergex.com] Sent: Friday, November 27, 2009 3:04 PM To: Bennett, Timothy A ENV:EX Cc: Babakaiff, Scott C ENV:EX; XT:Busto, Vince DFO EAO:IN; gsteeves@ameresco.com; Richard Blanchet; Kelly Boychuk Subject: Ashlu Creek Hydro Project (Water Stewardship Division file number: 2001264): Operations Environmental Management Plan Hello Tim, Attached are the following files: Revision B of the Operations Environmental Management Plan for the Ashlu Creek project. Jpeg file of the monitoring map shown as Figure 1 in the OEMP. Cover letter regarding submission of the OEMP. Hard copies are in the mail to you, to Scott Babakaiff, and to Vince Busto. Please contact me if you have any questions. Regards, Robert
________________________________________
Phone : 604 984.8600 Fax : 604 984.8699 Cell.: 778 227.0434
Page 507 FNR-2011-00265/ Part 1
MEMORANDUM TO: FROM: DATE: FILE: Matt Henderson Elyse MacDonald January 13, 2011 1112-05
RE: Ashlu Creek Hydroelectric Project Ramping Rate Compliance Specifications During the 11 January agency meeting, a request for a table confirming ramping rates and compliance points was requested of Ecofish Research Ltd. by Ministry of Environment (MOE) and Ministry of Natural Resource Operations (MoNRO) staff. Below, please find this table (Table 1) and a site figure (Figure 1) showing locations of permanent gauges and sensitive sites. Figure 2 shows the response plan in flow chart form. Table 1.
Operation
Ashlu Creek Ramping Rate Compliance Specifications

Reach Sensitive site locations Flow range (cms) Maximum operational rate (cms/h) Maximum gauge stage change rate (cm/h) Compliance point Average sensitive site stage change rate (cm/h) Data review results from Compliance Point (cm/h) <4.0 Action to be taken Agency Notification Reporting type / Deadline
Start-up
Diversion
ASU-DVSD01 ASU-DVSD02 ASU-DVSD03
0 - 17.6
1.5
4.0
IFR Gauge
4.12
None
N/A
N/A
>4.0 >17.6 (60% MAD) Shutdown Downstream ASU-DSSD04 ASU-DSSD05 ASU-DSSD07 0 - 19.4 TBD 1.5 4.0 IFR Gauge ASU-DSLG01 1.95 <4.0
Mobilize crews to sensitive Notify agency of Submission of impact report sites. If fish are found event within 24 and data within 2 weeks. conduct a salvage. hours
None
N/A
N/A
>4.0
Mobilize crews to sensitive Notify agency of Submission of impact report sites. If fish are found event within 24 and data within 2 weeks. conduct a salvage. hours
>19.4 (60% MAD)
TBD
ASU-DSLG01
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Figure 1. Ashlu Creek Monitoring Sites
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Figure 2.
Flow Chart of Response

Ashlu Ramping Rate Compliance Specs
Data Review: Review both IFR gauge and ASUDSLG01 and determine ramping rate during event (cm/h)
Possible facility-induced noncompliance ramping event occurs
Action Required:
1) Notify Elyse MacDonald ERL 2) Notify Agencies within 24 hrs No Action Required If calculated rates for both gauges are less than4.0 cm/h no incident has occurred
< 4.0 cm / hr
If calculated rates for either gauge exceeds 4.0 cm/h, an incident has occurred
> 4.0 cm / hr
3) Notify Robert Kulka* ACILP 4) Immediately mobilize crews to sensitive sites
1) Mobilize crews to: ASU-DVSD02 ASU-DVSD03 2)Search for stranded fish
Start Up
1) Mobilize crews to: ASU-DSSD04 ASU-DSSD05 2) Search for stranded fish
Shut Down
Stranded fish are found
Conduct Fish Salvage
Stranded fish are found
No stranded fish found
No stranded fish found
Notify Robert Kulka* of results within 24 hours
Report for DFO / MOE submitted within 2 weeks. Report must include: A) One minute data for intake flows, diversion flows & operational monitoring points, over the full period of non-compliance B) A description of the mitigative steps taken to reduce the likelihood of (1) such non-compliance from occurring in the future, and (2) environmental impacts (e.g. fish salvage) associated with the noncompliance
* May be replaced with Matt Henderson in further revision of OPPR
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30 Gostick Place | N. Vancouver, B.C. V7M 3G3 | 604.980.6011 | www.nhcweb.com
December 9, 2009 ASHLU CREEK INVESTMENTS LIMITED PARTNERSHIP Suite 303 38 Fell Avenue North Vancouver, BC V7P 3S2
Attention: Via Email: Subject:
Mr. Robert Kulka, P.Eng. RKulka@innergex.com Ashlu Creek IFR Flow Measurement Revision B
Northwest Hydraulic Consultants (NHC) is pleased to submit the following results from our November 26, 2009 survey at the Ashlu Creek Intake Site. The purpose of the survey was to measure flow through the downstream end of a steel pipe installed within the abutment of the sluiceway designed to provide instream flow release (IFR) for the project.
Background (from email provided by Ashlu Creek Investments)

For the Ashlu Creek Project the Department of Fisheries and Oceans (DFO) Authorization calls for a minimum IFR of 2.42 m3/s. In order to provide a reliable means for the IFR a 30-inch steel pipe was installed within the abutment wall of the sluiceway. The pipe inlet can be controlled with a hand operated knife gate valve located downstream of a coarse trash rack. The pipe was designed to provide the IFR at the lowest head pond operating level (the elevation of the pipe CL is 272.0m and the head pond operating level is between 275.5 to 276.5m net head of the pipe inlet is between 3.5 to 4.5m). Flow calculations were provided to the DFO. The objective of these measurements was to confirm the release.
Field Measurements
On November 26, 2009 NHC met on-site, Photograph 1, to measure IFR flows at the downstream end of the 30-inch pipe using a Pitot tube. Velocities were measured from above through the centerline of the pipe. It was assumed that flow at the end of the pipe was fully developed and any blockage effect generated by the Pitot tube and support structure was insignificant. Results from the survey indicated that both assumtions are reasonable. Photographs on the following page illustrate the site, flow conditions, and measurement approach. Flow measurements were recorded along the centerline of the pipe for two conditions. The first set of measured velocities were recorded with debris located in the vicinity of the entrance to the pipe. The velocities indicated that the discharge was approximately 15% below the minimum IFR of 2.42 m3/s. The initial results prompted the operators to sluice the approach channel. The velocity measurements
water resource specialists
Page 795 FNR-2011-00265/ Part 1
ASHLU CREEK INVESTMENTS LIMITED PARTNERSHIP December 9, 2009 Revision B Page 2
were then repeated and the discharge through the pipe exceeded the required IFR by approximately 20%. Both sets of measurements were compared to theoretical velocity distributions and presented in Figure 1 and Figure 2 on page 3. Headpond elevations were recorded through the day and varied between El. 276.03 m and El. 276.08 m.
IFR Pipe Outlet
Photograph 1 Overall view of the project site (Photogragh provided by Innergex)
Photograph 2 View of the IFR from downstream of the 30 inch pipe.
Photograph 3 View of the IFR from above
Photograph 4 Measurements were recorded using a Pitot tube.
Page 796 FNR-2011-00265/ Part 1
Figure 1 Measured and theoretical velocity distribution. Discharge = 2.05 m3/s
Figure 2 Measured and theoretical velocity distribution. Discharge = 2.90 m3/s
Velocity measurements are considered accurate to within 3% and the locations are accurate to within 5mm. Water levels were also recorded downstream of the inlet structure. During the first series of velocity measurements the water level downstream of the inlet gate was at El. 274.40 m while the head pond was at El. 276.08m, a loss of 1.68m (discharge of 2.05 m3/s). Following sluicing of the debris, the water level downstream of the trash rack was El. 275.76 m while the head pond dropped slightly to El. 276.06 m, a loss of 0.30 m (discharge of 2.90 m3/s). Figure 3 Based on the measurement recorded on November 26, 2009, the water level downstream of the inlet gate must be at El. 275.00 m to drive 2.42 m3/s through the IFR pipe
Page 797 FNR-2011-00265/ Part 1
IFR Inlet Gate Operation

At water levels above 275.3 m the well maintained IFR system will discharge flows greater than 2.42 m3/s. To reduce losses the IFR inlet gate could be operated to manage the release. Due to the interaction between the trashrach, inlet gate, and pipe entrance it is difficult to calculate precise operation of the gate. However, assuming a loss gate coefficient of 0.61 an estimated (losses could vary by about 10% to 20%) gate operation scenario is presented in the following table.
WaterSurfaceElevation(m) Forebay 275.1 275.2 275.3 275.4 275.5 275.6 275.7 275.8 275.9 276.0 276.1 276.2 276.3 276.4 276.5 276.6 276.8 277.0 HeadLoss GateOpening Downstream Attributedtothe (%) ofTrashRack IFRInletGate(m) 274.8 fullyopen 100% 274.9 fullyopen 100% 275.0 fullyopen 100% 275.1 0.1 79% 275.2 0.2 75% 275.3 0.3 71% 275.4 0.4 68% 275.5 0.5 65% 275.6 0.6 63% 275.7 0.7 61% 275.8 0.8 59% 275.9 0.9 57% 276.0 1.0 56% 276.1 1.1 54% 276.2 1.2 53% 276.3 1.3 51% 276.5 1.5 49% 276.7 1.7 47%
As s umedthehea dl os s throughthetra s hra cki s a cons ta nt0.3m IFRInl etGa teopeni ngi s effecti vel y1.2mhighby1.0mwi de As s umedIFRInl etGa tel os s coeffi ci enti s 0.61
OperatingRange
We appreciated this opportunity and look forward to the opportunity of working with Ashlu Creek Investments and their partners in the future. Please do not hesitate to contact me directly in NHCs Vancouver office at (604) 980-6011 or via email at KChristison@nhc-van.com if you have any questions. Sincerely,
northwest hydraulic consultants

original signed
Kenneth J. Christison, P.Eng. Principal
Page 798 FNR-2011-00265/ Part 1
30 Gostick Place | N. Vancouver, B.C. V7M 3G3 | 604.980.6011 | www.nhcweb.com
May 3, 2010 ASHLU CREEK INVESTMENTS LIMITED PARTNERSHIP Suite 303 38 Fell Avenue North Vancouver, BC V7P 3S2
Attention: Via Email: Subject:
Mr. Robert Kulka, P.Eng. RKulka@innergex.com Ashlu Creek IFR Flow Measurement April 28, 2010
Northwest Hydraulic Consultants (NHC) is pleased to submit the following results from our April 28, 2010 survey at the Ashlu Creek Intake Site. The purpose of the survey was to develop a discharge rating curve for the instream flow release (IFR) system over a range of operating conditions. This report is an addendum to NHCs December 9, 2009 letter describing a similar survey at the Ashlu Creek Intake Site on November 26, 2009.
Background (from emails provided by Ashlu Creek Investments)

For the Ashlu Creek Project, the Department of Fisheries and Oceans (DFO) Authorization requires a minimum IFR release flow of 2.42 m3/s. In order to provide a reliable hydraulic release structure for the IFR, a 30-inch diameter steel pipe was installed within the abutment wall of the sluiceway. This pipe discharges water from the headpond to the tailrace below the weir. The pipe inlet is controlled with a hand-operated knife gate valve located downstream of a coarse trash rack. The pipe was designed to provide the IFR at the lowest head pond operating level (the elevation of the pipe CL is 272.0 m and the head pond operating level is between 275.5 to 276.5 m net head of the pipe inlet is between 3.5 to 4.5 m).
Field Measurements
On April 28, 2010 NHC met on-site, to measure IFR flows over a variety of operating conditions at the downstream end of the IFR pipe using a calibrated Swoffer propeller-type current meter. Discharge information was collected in two stages. Stage 1 involved opening the sluice gate in 0.1 m increments ranging from closed to fully open and measuring IFR flows using a coarse array of five velocity measurements, see Figure 1a. Stage 2 provided additional, more detailed, flow measurements at gate openings associated with releases of 1.5 m3/s and 2.5 m3/s. A finer array of eleven velocity measurements, Figure 1b, was adopted in Stage 2. Time, reservoir pool elevations, and the head loss through the IFR trash rack were recorded between each set of velocity measurements. Velocity measurements are considered accurate to within 10%, locations and reservoir pool elevations are accurate to within 0.005 m, and head losses through the IFR trash rack are accurate to 0.025 m.
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Page 799 FNR-2011-00265/ Part 1
ASHLU CREEK INVESTMENTS LIMITED PARTNERSHIP May 3, 2010 Draft Report Page 2
Figure 1a Stage 1 Measurement Locations.
Figure 1b Stage 2 Measurement locations
IFR Inlet Gate Operation

Stage 1 testing concluded that for the observed IFR gate openings, the outlet flows ranged from 0.65 m3/s to 2.97 m3/s. Head losses across the IFR trash rack were measured between 0.03 m and 0.25 m, see Table 1 and attached Figure 2, & 3. Outlet flows where calculated based off the average velocities of the IFR release. Downstream of the trash rack and knife gate flow likely approaches fully developed conditions near the downstream end of the approximately 33 m length of straight pipe. However, the pipe turns 30 approximately 6 m upstream of the outlet. At the outlet the flow is not fully developed. Stage 2 data was integrated over the measured flow area and a weighted average flow was produced, see Table 2. Measured flows are accurate to within 10%. From field measurements, the developed IFR rating curve presented in Figure 2 indicates a gate opening of 29.5% and 55.5% will produce IFR flow flows of 1.5 m3/s and 2.50 m3/s, respectively. The relationship between discharge and losses past a clean trash rack re presented in Figure 3.
Page 800 FNR-2011-00265/ Part 1
ASHLU CREEK INVESTMENTS LIMITED PARTNERSHIP May 3, 2010 Draft Report Page 3
Table 1 Stage 1 Measurement Data

Reservoir Elevation(m) 275.75 275.83 275.83 275.82 275.79 275.77 275.78 275.80 275.83 275.85 275.86 275.85
n/r=notrecorded
Table 2 Stage 2 Measurement Data

Reservoir Elevation(m) 275.81 275.85 275.87 275.81 275.82 275.80 GateOpening IFRTrashRack (%) Headloss(m) 25.0 0.055 29.2 0.05 33.3 0.065 50.0 0.125 54.2 0.13 58.3 0.14 Flow (m3/s) 1.29 1.47 1.68 2.36 2.47 2.55
GateOpening IFRTrashRack (%) Headloss(m) 8.3 n/r 16.7 0.03 25.0 0.05 33.3 0.06 41.7 0.12 50.0 0.12 58.3 0.14 66.7 0.17 75.0 0.18 83.3 0.25 91.7 0.25 100.0 0.25
Flow (m3/s) 0.65 1.15 1.05 1.83 2.21 2.43 2.72 2.68 2.81 2.97 2.90 2.89
We appreciated this opportunity and look forward to the opportunity of working with Ashlu Creek Investments and their partners in the future. Please do not hesitate to contact me directly in NHCs Vancouver office at (604) 980-6011 or via email at KChristison@nhc-van.com if you have any questions. Sincerely,

Original signed by
W.D. Clohan, E.I.T. Project Engineer
Reviewed by: K. J. Christison, P.Eng. Principal Attach.
Page 801 FNR-2011-00265/ Part 1
100.0 Stage1Measurements 90.0 Stage2Measurements
80.0
70.0
OpenChannelFlowDownstreamOutlet IFRGateOpening(%)
60.0
Transtition Zone
PipeFullFlowDownstreamOutlet
50.0
40.0
30.0
20.0
10.0
0.0 0.00 0.50 1.00 1.50 Flow(m3s) 2.00 2.50 3.00
Ashlu Creek Investments

ASHLU CREEK IFR FLOW MEASUREMENT FIELD STUDY
NOTES:
1. UNLESS OTHERWISE STATED, PROVIDED UNITS ARE METRIC 2. DATA COLLECTED WITH SWOFFER METER 35317-002
IFR GATE OPENING RATING CURVE

DRN. BY: WDC MAY-3-2010
FIGURE 2 Page 802 FNR-2011-00265/ Part 1
0.3 Stage1Measurements Stage2Measurements 0.25
HeadlossThroughCleanTrashRack(m)
0.2
OpenChannelFlowDownstreamOutlet
Transtition Zone
PipeFullFlowDownstreamOutlet
0.15
0.1
0.05
0 0.00 0.50 1.00 1.50 Flow(m3s) 2.00 2.50 3.00
Ashlu Creek Investments

ASHLU CREEK IFR FLOW MEASUREMENT FIELD STUDY
NOTES:
1. UNLESS OTHERWISE STATED, PROVIDED UNITS ARE METRIC 2. DATA COLLECTED WITH SWOFFER METER
IFR TRASH RACK HEAD LOSS RATING CURVE

35317-002 DRN. BY: WDC MAY-3-2010
FIGURE 3 Page 803 FNR-2011-00265/ Part 1
Flow Rate (cms) Ashlu Creek with Obermeyer Gate System

800 700 600 500 Flow Rate (cms) 400 300 200 100 0 271.00
272.00
273.00
274.00 Upstream Water Elevation (m) Top of Gate Elevation:
275.00
276.00
277.00
271.50
272.00
272.50
273.00
273.50
274.00
274.50
275.00
275.50
276.00
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Discharge Capacity at the Sluiceway Gate Fully Open not submerged condition
277 Bottom elevation of the Sluiceway gate at its maximum opening = 276,51 m
276
Upstream Water Level in the reservoir
275 Q = 20.05 (H-271)^1.2495 Water Level (m) 274
Water Level at the Sluiceway gate

273 Q = 19.95 (H-270)^1.515 272
271
270 0 50 100 150 200 250 300 350 Discharge (m/s)
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Discharge Capacity at the Sluiceway Different Gates Openings not submerged condition 278
277.00
278.00
276.00
275.50
276.50
277.50
277
Upstream Water level (m)
Bottom elevation of the Sluiceway gate at its maximum opening = 276,51 m 276 Different Gate Elevation (m)
275
274
273 Q = C D L (2gH)^0.5 Where, C = IF(D/H) <1.1, C = 0.1545*(D/H)^2-0.3393*D/H+0.7014 IF (D/H) 1.1, C = 0.515 D = gate opening (m) L = width (m) g = 9.81 m/s H = head to the center of the gate opening Crest elevation of the sluiceway = 270,00 m 270 0 50 100 Discharge (m/s) 150 200 250
272
271
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278.50
279.00
ENVIRONMENTAL INCIDENT REPORT

INCIDENT TYPE: FISH STRANDING Date of Report: Date/Time of Incident: Project Name: Project Owner: Report Prepared By: (name, position and company): Witness to Event (name, position and company): Name of company responsible for incident: Owner/Operator Telephone No.: Owner/Operator Contact Name: Ecofish Research Ltd. (ERL)
ERL Staff: Project Staff:
INCIDENT PROFILE Incident Type: Fish stranding and mortality Observed number of fish (Number of fish by species, and life stage observed stranded) impacted : Observed wildlife species impacted: Weather:
Page 807 FNR-2011-00265/ Part 1
Intent of work:
(What the operator was doing at the time, for example plant start-up or shut-down, for what purposes, modify points below as needed) (If ERL staff were onsite at the time, describe why and where they were working i.e. conducting ramping monitoring, fish community monitoring, etc.)
Cause of incident: What immediate environmental impacts occurred as a result of the incident: Photos
(Briefly, what happened and why)
(Fish Kill in violation of the Fisheries Act Section 32; violation of recommended ramping rates,etc.) Attached
IMMEDIATE ACTION TAKEN A chronologic sequence of events, including responses and actions taken is provided below, with a more comprehensive discussion following: Time (24hr) Description of Events/Actions
IMPACT DISCUSSION (How many fish were salvaged: how many released alive, how many dead, by species and age class. Preferably, info on fish size (FL or mass). Areas surveyed and methods for doing so, estimate of area of habitat impacted. Final estimate of total number of fish killed or dewatered. Data logger information, if available, for actual stage change; operational ramping rates used (cms/hr) and confirm if these were the intended operational rates; was the operational rate consistent with that intended, but naturally decreasing water levels
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compounded start up i.e. the plant operated at xx cms/hr but with the natural decrease in flow the actual decrease was more like xx cms/hr.
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Figure 1.
Map of assessment sites and reconnaissance sites.
Table 1.
Summary of site information and number and density of stranded and dewatered fry/fish observed at assessment sites located in the area of impact.
FOLLOW UP ACTIONS TO PREVENT RE-OCCURRENCE Responsible Party (Client) (Client) ERL Detailed Impact Assessment Report (to come) Action Due Date
Page 810 FNR-2011-00265/ Part 1
NOTIFICATION:
Reported to Owner Representative or Operator DFO MOE Name/Position of Person Reported to Name of Person Who Made Report Date, Time and Method Reported (ex: May 8, 2010; 8:00am, over radio or phone) (date, time, method) (date, time, method) (date, time, method) (Client)
Other:
REPORT SIGN OFF:
Print Name Ecofish Research Ltd. Representative: Print Name
Position and Company
Signature
Date
Position
Signature
Date
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PHOTOS
Page 812 FNR-2011-00265/ Part 1
ENVIRONMENTAL INCIDENT REPORT

INCIDENT TYPE: FISH STRANDING Date of Report: Date/Time of Incident: Project Name: Project Owner: Report Prepared By: (name, position and company): Witness to Event (name, position and company): Name of company responsible for incident: Owner/Operator Telephone No.: Owner/Operator Contact Name:
INCIDENT PROFILE Incident Type: Observed number of fish impacted : Observed wildlife species impacted: Weather:
Page 813 FNR-2011-00265/ Part 1
Intent of work: Cause of incident: What immediate environmental impacts occurred as a result of the incident: Photos Attached
IMMEDIATE ACTION TAKEN A chronologic sequence of events, including responses and actions taken is provided below, with a more comprehensive discussion following: Time (24hr) Description of Events/Actions
IMPACT DISCUSSION
Page 814 FNR-2011-00265/ Part 1
Figure 1.
Map of assessment sites and reconnaissance sites.
Table 1.
Summary of results.
FOLLOW UP ACTIONS TO PREVENT RE-OCCURRENCE Responsible Party Action Due Date
Page 815 FNR-2011-00265/ Part 1
NOTIFICATION:
Reported to Owner Representative or Operator DFO MOE Name/Position of Person Reported to Name of Person Who Made Report Date, Time and Method Reported (ex: May 8, 2010; 8:00am, over radio or phone) (date, time, method) (date, time, method) (date, time, method) (Client)
Other:
REPORT SIGN OFF:
Print Name Ecofish Research Ltd. Representative: Print Name
Position and Company
Signature
Date
Position
Signature
Date
Page 816 FNR-2011-00265/ Part 1
PHOTOS
Page 817 FNR-2011-00265/ Part 1

Response Records Part 1

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Page 1 FNR-2011-00265/ Part 1

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ASHLU CREEK INVESTMENTS LIMITED PARTNERSHIP

Ashlu Creek Green Power Project 2009 Environmental Monitor

Cascade was pre act as interim EM

Page 7 FNR-2011-00265/ Part 1

Richard Blanchet Vice President

Page 8 FNR-2011-00265/ Part 1

Construction of the Ashlu Creek Waterpower Project

Page 9 FNR-2011-00265/ Part 1

Regulation of the Construction of Works

Information and Reports

the requirements of the EMP, the potential environmental impacts, and

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Delegation of Duties of Environmental Monitor

Testing the Operation

Authority to Stop Construction Activities

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Name: ______________________________________ Environmental Monitor, supervisor Mike Nelson, R.P. Bio.

Date: April 22, 2009

Date: : April 22, 2009

Date: : April 22, 2009

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Appendix A - Contact List

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T: +1 (604) 514-3322 F: +1 (604) 514-3323 E: Surrey@exova.com W: www.exova.com

Report Transmission Cover Page

413-01-01 Ashlu IPP Ashlu IPP

Oct 27, 2009 Oct 29, 2009 1267258

Contact & Affiliation Lesley Nelson Cascade Environmental Resource

Christine Becker Cascade Environmental Resource

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T: +1 (604) 514-3322 F: +1 (604) 514-3323 E: Surrey@exova.com W: www.exova.com

413-01-01 Ashlu IPP Ashlu IPP