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High marks for Toba Montrose from FPB

July 27, 2011

What’s that big fiery object in the sky?

With so much cold, crappy weather here in B.C. over the past few months — coupled with the apparent cancellation of anything remotely resembling summer — we recently decided to unchain the boys in the BCCGE mailroom from their desks every once in a while so they can go outside and experience a few of the rare days of sunshine that have managed to materialize.

And once we explained to our beleaguered, overworked boys that the big fiery object in the sky was not something hurled at them with malevolent intent by the staff at COPE 378 headquarters, they seemed to calm down and even appeared to enjoy themselves

Who says we’re not benevolent taskmasters filled with generosity of spirit?

But as everyone in the BCCGE mailroom knows well, all good things must come to an end, and sunny weather or not it’s back to the mailroom they go; once again chained to their desks and grinding through the minutiae and finer details of the latest renewable energy news.

So, what have the boys in the BCCGE mailroom been working on?

I bet you’re curious to know what the boys in the BCCGE mailroom have been working on over the past several weeks.

Well, most of their attention has been focused on a recent report by B.C.’s independent Forest Practices Board.

The report by the Forest Practices Board is the result of a thorough investigation into the purported impact of the Toba Montrose project on forest resources, and it was occasioned by a complaint from the Friends of Bute Inlet and the Sierra Club of B.C.

For those not completely up to speed, the Forest Practices Board is the “independent watchdog for sound forest and range practices in British Columbia.”  As the board’s website states, the board has “an arms-length relationship from government, and a mandate to hold both government and the forest industry publicly accountable for forestry practices.”

But if the Friends of Bute Inlet and the Sierra Club were hoping for some sort of scathing condemnation of the Toba Montrose project by the Forest Practices Board they certainly didn’t get one.  Not by a long stretch; the report, in fact, found that the Toba Montrose project’s harvesting and road building followed requirements to protect the environment.

And, as the boys in the BCCGE mailroom have been telling us ever since they first skimmed the Board’s report, anyone reading the report would be hard pressed to see it as anything other than favourable and positive toward the Toba Montrose project’s forest practices.

For those interested in reading the Board’s complete 47-page report for themselves, the report is entitled “Forest Resources and the Toba Montrose Creek Hydroelectric Project” (Complaint Investigation 090928 — FPB/IRC/175), and it can be found by clicking here.

So, what did the Forest Practices Board actually find through their investigation?

Most people are probably aware that the Toba Montrose run-of-river project is located north of Powell River.  They probably also know that it began supplying clean, renewable energy to BC Hydro’s grid nearly a year ago in August 2010.

And, as the Forest Practices Board notes in its report, the Toba Montrose project underwent a full environmental assessment and was approved by both the provincial and federal governments in 2007.

As for the complaint itself: The Board was asked to assess a whole laundry list of things by the complainants, some of which were beyond the Board’s mandate and were therefore not addressed.

What the Forest Practices Board focused their  investigation on (in accordance with their mandate) was how logging, road building and related planning for the Toba Montrose project impacted forest resources.

And where they were requested to do so by the complainants, the board also directly compared forest practices for the Toba Montrose project to those commonly employed by the forest industry.

Yes, but what did the Board actually say?

So, what did the Forest Practices Board actually have to say about the Toba Montrose project in their report, you ask?

Having thoroughly studied the Forest Practices Board report, we can say with great confidence that any reasonably minded, unbiased person who takes the time to read the entire report would find the overall thrust of the report, and its conclusions, to be very positive toward the Toba Montrose project’s forest practices.

For starters, the Board’s findings clearly state that the Toba Montrose project’s timber harvesting and road work generally complied with the legislated and contractual requirements for the project and that they also met the commitments set out in the project’s environmental assessment certificate.

The Board also determined that the work was done to a standard comparable to that of the forest industry.

As for the project’s environmental monitoring and enforcement actions: The board found that these had many characteristics of an effective program, particularly the extent of monitoring for compliance through an independent monitor who appeared sufficiently objective and independent.

The board also found that the project’s cumulative effects assessment was consistent with the limited legal requirements that currently exist and that project-level consultation was extensive and exceeded common practice in the forest industry.

In terms of the Toba Montrose proponent’s decision to not hold a public meeting in a larger regional centre (presumably where major media outlets might be more likely to broadcast the grandstanding antics of protesters bussed in by groups like the Wilderness Committee and COPE 378); the Board considered the decision to be “reasonable” and that public involvement in, and disclosure of, the location of the transmission line was adequate.

Taken as a whole, the Forest Practices Board’s “report card” on the Toba Montrose project represents a collection of A’s, B’s, and high C-pluses.  These are high marks by anyone’s standards, and any parent whose child brought home a report card with similarly good grades would be suitably pleased with their child’s progress.

Putting an even finer point on it: The Board’s findings in this matter are nowhere close to being a scathing indictment of the Toba Montrose project (and presumably, by extension, all independent run-of-river projects) that the Sierra Club and Friends of Bute Inlet were probably hoping for when they filed their complaint.

Drilling down deeper into the Forest Practices Board report

So, let’s drill down deeper into the Forest Practices Board’s report and take a detailed look at the specific questions the board was asked and what the Board’s independent investigation revealed:

Question #1: “Were harvesting and road building practices consistent with requirements, and comparable to those for forest major licensees”

The answer is “yes,” the proponent’s harvesting and road building practices were consistent with requirements and were comparable to those for a major forest licensee.

Detailed discussion of Question #1

The Forest Practices Board found that the Toba Montrose project’s harvesting and road building practices were generally consistent with legal and contractual requirements to protect the environment.  These requirements were similar to those required of forestry operations and, in some cases, were more stringent.

The Board found existing roads and bridges (which were maintained under permit and agreements) generally had functional drainage systems, adequate visibility and stable road prisms.

The work was done to a standard comparable to that of the forest industry, except for some deactivated spur roads where natural drainage patterns had not yet been restored at the time of the Board’s field review (some of which, as the report notes, have since been deactivated or reseeded).

Of the hundreds of stream crossings examined by the Board, there were only three observed instances of damage whereby stream banks were disturbed over a small area or where natural stream channels were rerouted for short lengths due to clearing.  Otherwise, work around streams complied with legislated and contractual requirements a) to not obstruct fish passage, b) to protect stream crossings, c) to prevent materials from entering watercourses and d) to minimize the number of crossings.

As well, when constructing overhead lines, the Forest Practices Board found that the proponent’s work was consistent with the Department of Fisheries and Ocean’s prescribed measures to protect fish and fish habitat.  The Board found that work around streams was comparable to that typically observed by the Board during audits of major forest licensees (other than the clearing of vegetation next to fish streams needed to provide clearance for the transmission line).

And although clearing of vegetation next to streams was contrary to the contractual requirement to leave trees less than five-metres tall along 32 streams where the clearing width was wider than the normal 40 metres, the proponent did so to ensure crew safety and provide clearance for the transmission wires.

In terms of the visual impacts of transmission line clearing, the board found that visual impacts were consistent with the visual quality objectives.  The observed soil disturbance within the right-of-way was also found to be negligible.

On the steeper sections of the transmission line that were not accessible to ground-yarding equipment, the report states that felled timber was left on the ground in a few places and, for the most part, not bucked and limbed as per the minimum standards described in the proponent’s debris management plan.

However, as the report also states, the proponent had a qualified professional assess the transmission line and the professional was satisfied that the clearing and debris management standards of the project had been met and, moreover, that they met or exceeded the standards of the coastal forest industry.

The professional involved also deemed the fire risk to be within the acceptable range because the areas with debris accumulation noted by the Board were generally at higher elevations with lots of snow, limited access and natural fire breaks.

These higher elevation areas also tended to have five-metre, debris-free zones around any road access.  The Board therefore accepted the opinion of the professional regarding debris management and stated so clearly in their report.

Question #2: “Did the proponent meet requirements and commitments to manage spatially-defined conservation areas?”

The answer is “yes,” the proponent met the requirements and commitments for managing spatially-defined conservation areas.

Detailed discussion of Question #2

In their complaint to the Forest Practices Board, the Sierra Club and the Friends of Bute Inlet raised concerns about the project’s impacts on spatially defined conservation areas—such as Old Growth Management Areas (OGMAs), ungulate winter ranges (UWRs), and wildlife habitat areas (WHAs).

However, the Forest Practices Board discovered that there were no established wildlife habitat areas (WHAs) within the area of the Toba Montrose project and nor were there any ungulate winter ranges (UWRs).

And although the project reduced Old Growth Management Areas (OGMAs) by 35 hectares, the report states that the project proponent met its commitments to mitigate the project’s impacts on these.  In fact, the Board found that the location of the transmission line within the approved right-of-way generally avoided Old Growth Management Areas or usually crossed them in narrow sections.

Question #3: “Did the proponent adequately assess and manage for archaeological features?”

“Yes,” the proponent adequately assessed and managed for archaeological features.

Detailed discussion of Question #3

In their complainant to the Forest Practices Board, the Sierra Club and Friends of Bute Inlet questioned whether the proponent’s assessments for archaeological features and unstable terrain were of a calibre comparable to the forest industry.

The Board reviewed the proponent’s archaeological and terrain hazard assessments and compared them to common practice for major forest licensees.

The Board found that the Toba Montrose proponent adequately managed for archaeological features and that archaeological and cultural heritage assessments were similar to assessments often undertaken by major forest licensees.  These assessments, the report states, met the legislated requirements as well as the conditions of the project’s environmental assessment certificate.

As was also noted in the Board’s report, run-of river projects and major forest licensees are both subject to the Heritage Conservation Act, which provides protection for heritage objects, burial sites, and rock carvings or paintings.

The proponent also committed to mitigating the potential effects on archaeological resources including the outlining of procedures for dealing with any archaeological features that might be encountered and having an archaeologist and a representative from the Klahoose, Sliammon or Shishalh First Nation present during construction activities in sensitive areas which had been identified by the archaeological impact assessment.

Question #4: “Did the proponent adequately assess terrain?”

“Yes,” the proponent adequately assessed terrain.

Detailed discussion of Question #4

The Forest Practices Board found that the proponent’s terrain assessments were consistent with its commitments and that they were comparable to assessments sometimes done by major forest licensees.

The proponent had a qualified professional complete detailed terrain assessments for the transmission line alignment, including site and project description, methodology, follow-up field work, terrain maps, findings, recommendations and conclusions.

Project terrain maps were produced according to Resources Inventory Committee standards, and recommendations were made to relocate towers and mitigate the risk from terrain hazards.

The proponent also had a qualified professional assess the landslide risk of reactivating the road in the Toba Valley.  This qualified professional found a low to moderate landslide probability associated with the roads, and a low risk to downslope resources as a result of reactivation of these roads.

Question #5: “Did the proponent adequately consider and manage for access?”

The answer, again, is “yes” the proponent adequately considered and managed for access.

Detailed discussion of Question #5

In their complaint, the Sierra Club and Friends of Bute Inlet expressed a concern that the transmission line network created vehicle access into previously inaccessible areas, thereby impacting wildlife through unmonitored hunting.

Although the Forest Practices Board did not assess whether the proponent’s measures were effective at managing hunting pressure, they did find that the proponent made legally binding commitments to address access issues identified during the environmental assessment process and that these commitments had been met by the proponent.

For example, as the Board’s report states, the southern, or “Powell River,” section of the Toba Montrose project is accessed by existing forestry roads.  And because this southern area is already open to hunting and other recreational uses, the Board found that any additional impact on resources from increased access is likely to be low and was therefore not investigated further by the Board.

To access the East Toba power station, however, the proponent reopened and upgraded 40 kilometres of existing deactivated logging roads — roads that are only accessible by barge.  As such, gates were not installed during construction which was a commitment the project proponent had made.

Instead, the proponent implemented “safety call-in procedures” for its contractor which very effectively prevented any unauthorized use of these roads.

And as the Forest Practices Board report also states, gates were subsequently installed in October 2010 in accordance with the proponent’s access management plan.

Although this approach was seen by the Board as falling somewhat short of the proponent’s original commitment, the Board nevertheless accepted that the proponent’s approach likely met the spirit and intent of the proponent’s commitment to manage access.

Question #6: “Did the proponent adequately consider and manage for invasive plants?”

The answer is “yes,” the proponent adequately managed for invasive plants.

Detailed discussion of Question #6

In their complaint, the Sierra Club and Friends of Bute Inlet expressed a concern that the transmission line and roads for the Toba Montrose project could provide a potential foothold for invasive plants such as scotch broom (note: you could say that about practically any road, couldn’t you?).

As the Board states in its report, they did not confirm the presence or absence of any invasive plants during their time on the Toba Montrose site.  Instead, the Board assessed how the proponent managed for invasive plants by comparing and contrasting those practices with the best management practices of the forest industry.

The Board found that the proponent’s approach to managing invasive plants met or exceeded common practice in the forest industry.

The Board also noted that although there are no specific requirements in legislation for run-of-river projects or forest licensees to manage for invasive plants, the Toba Montrose proponent nevertheless committed to numerous measures intended to control invasive plants.

For example, all construction vehicles were thoroughly washed, either before or immediately upon their arrival by barge at the Toba area.  Special attention was paid to wheel wells, tire treads and tracks where mud and seeds could be lodged, and disturbed areas were reseeded with native species or in accordance with generally accepted forestry and resource road practices.

As the report states, the Toba Montrose proponent’s practices were consistent with some of the recommended methods for preventing the establishment of invasive plants and could only be further improved by prompt re-vegetation of disturbed areas and through ongoing monitoring.

Question #7: “Was wood utilization consistent with requirements and policy?”

Again, the answer is “yes,” wood utilization was consistent with requirements and policy.

Detailed discussion of Question #7

In their complaint, the Sierra Club and Friends of Bute Inlet expressed a concern about timber being wasted during transmission line logging.

The Board therefore examined the wood waste question relative to requirements and policy and found that merchantable wood left dispersed under the transmission line was consistent with the province’s take or pay policy, even though it was contrary to the project’s licensing requirement to deck timber at roadside.

However, as the Board states in its report, the proponent was billed $150,000 for this residual wood waste in accordance with procedures outlined in the Coast Appraisal Manual.

As the report also states, the proponent found that it was more economical to pay the waste fee—particularly for areas not accessible to ground yarding—than it was to incur the cost of yarding the timber and decking it at roadside.

Question #8: “Was monitoring and enforcement effective in promoting compliance with requirements and commitments to manage forest resources?”

You guessed it… The answer is once again “yes,” the proponent’s monitoring and enforcement actions had many characteristics of an effective program, particularly the extent of monitoring for compliance through the independent monitor.

Detailed discussion of Question #8

In their complaint, the Sierra Club and the Friends of Bute Inlet questioned whether the project’s approach to monitoring and enforcement was adequate for ensuring the adherence to requirements for managing forest resources.

They also asked the Forest Practices Board to determine whether self-monitoring by the proponent was sufficiently independent and objective.

As with most of their other findings, the Forest Practices Board found that the monitoring and enforcement actions of the project had many characteristics of an effective program, particularly the extent of monitoring for compliance through the independent monitor which, they note, appeared to be sufficiently objective and independent.

As the Board’s report states, one of the conditions of the project’s certification was the requirement for the proponent to appoint an independent environmental monitor (IEM) who was acceptable to, and would report to, the Ministry of the Environment. The role of this independent monitor was to check on the implementation of the proponent’s commitments and obligations and to monitor environmental compliance by periodically inspecting the environmental management of the project.

As the report also states: “Not surprisingly for a project of this size, in challenging coastal conditions, the IEM identified non-compliances with requirements.”  Among these, fuel spills were cited as the most commonly identified issue in the project’s challenging coastal environment.   In the nearly three-year period between September 2007 and June 2010,  the Board noted a bit over 100 spills ranging from several litres up to 900 litres.

As the report also notes, all of these spills were promptly dealt with using spill kits as well as the removal of contaminated materials.  And no residual problems were identified in the independent environmental monitor’s reports.

Another issue cited by the independent monitor was sediment delivery into streams.  Over 20 reports by the independent monitor made note of sediment delivery during the same three-year period noted above between September 2007 and June 2010, including instances of work not proceeding in accordance with plans which resulted in sedimentation of fish streams.

However, as the report states, the independent environmental monitor issued immediate stop-work orders, and in two cases, the incidents resulted in brief suspensions to the foreman and superintendent and to the retraining of crews.

As the Board’s report also notes, the project proponent immediately modified their procedures in response to the sedimentation issue by hiring an environmental inspector who worked with the independent environmental monitor and required the project’s contractor to vet activities through the independent monitor before starting work.

Most importantly, however, was the fact (noted by the Board) that the proponent mitigated most issues quickly and the Board concluded that the high frequency of independent environmental monitor inspections was sufficient and appropriate for the level of risk to forest resources.

Overall, the Forest Practices Board concluded that the measures in place, and the actions taken by the proponent, were characteristic of an effective monitoring and enforcement program.

The one thing the Forest Practices Board did specifically note as a concern, however, was the coordination of government oversight.  The Board was of the opinion that government oversight was not “well coordinated” and that, as a result, “potential non-compliances were not assessed for possible enforcement actions.”

As noted by the Board, bureaucrats in government agencies sometimes did not receive weekly reports until several weeks after they were prepared, and often after issues noted in reports had already been addressed.

These delays in reporting, and the limited nature of the notification, could, the Board felt, have made it more difficult for the Ministry of the Environment to plan a program of inspections and also potentially precluded agencies from timely follow-up on specific issues.  For that reason the Board felt the enforcement framework was not fully effective.

However, to our way of thinking it seems that having an independent environmental monitor on site and watching over a project is probably a more effective way to protect the environment and ensure compliance than relying on government officials sitting in far away offices wielding punishments after the fact.

Question #9: “Was the cumulative effects assessment consistent with legislation and guidance?”

The answer is “yes,” but with room for discussion due to vagueness surrounding the whole question of what constitutes a cumulative effect.

Detailed discussion of Question #9

In their complaint to the Forest Practices Board, the Sierra Club and the Friends of Bute Inlet claimed that the cumulative environmental effects of the project were not well-considered in the environmental assessment process.

Unfortunately for the Sierra Club and the Friends of Bute Inlet, the Board’s findings do no support that view.

As the Board’s report clearly states, the project proponent did undertake ”a cumulative impacts assessment and specified the scope and methodology in its application for an Environmental Assessment Certificate.”

Moreover, the proponent’s cumulative impacts assessment was accepted by the Environmental Assessment Office and by the federal government and was found by the Board to be consistent with the limited legal requirements that were in existence.

Cumulative effects are generally considered to be those effects likely to result from any disturbance caused by a project in combination with disturbances from other projects or activities that have been, or will be, carried out in the same geographical area.

However, it is important to note that cumulative effects assessment is an area where there does not yet seem to be a clear consensus.

And, as the Forest Practices Board points out in their report, cumulative effects assessments are not even required for road building or timber harvesting activities under a forest major licence.

Moreover, at the time the Toba Montrose project went through the assessment process, the Environmental Assessment Office “had no explicit policy for assessing the cumulative environmental effects of reviewable projects.”

In fact, as the Board states in their report, neither the federal nor the provincial statutes governing run-of-river projects spell out what a cumulative effects assessment should entail even though they require that one be carried out.

As a point of background, run-of river projects such as the Toba Montrose project are reviewable under the Canadian Environmental Assessment Act (CEAA) and consideration of cumulative environmental effects is required.

Likewise, under the provincial Environmental Assessment Act (EAA), project proponents for projects such as the Toba Montrose project must specify the scope and methodology of their cumulative effects assessment at the pre-application phase of the assessment process in their terms of reference.

And as noted by the Forest Practices Board in their report, the Toba Montrose proponent complied with these requirements, and in the case of the federal environmental assessment process was “guided” by an operational government policy statement in the form of the “Cumulative Effects Practitioners Guide.”

However, the Board felt the proponent’s assessment methods diverged somewhat from the guide-book even though the proponent themselves felt their cumulative effects assessment and methodology was entirely consistent with the Practitioners Guide.

The difference between the two views relates to the consideration of past human activities.

For the purposes of the Toba Montrose project, the proponent defined cumulative effects as: “changes to the environment that are caused by a residual impact of the Project in combination with other present and future human actions.”

The federal guide-book, however, defines cumulative effects as: “changes to the environment that are caused by an action in combination with other past, present and future human actions.”

The operative difference here really is kind of subtle, in our opinion, because in the case of the Toba Montrose project most of the past human action relevant to the project would presumably be logging operations rather than the kind of heavy industrial activities one might see in brownfield sites in Ontario, Quebec and the Maritimes.

Although we haven’t studied the “Cumulative Effects Practitioners Guide” in any great detail, as a federal government document one can assume that (as with most things federal) it is probably tailored more toward situations found in Eastern Canada rather than to those more commonly encountered here in B.C.

As the Operational Policy Statement which underpins the Practitioners Guide states, the guide “is intended to be broadly applicable across Canadian jurisdictions and to projects of varying size and complexity in different industrial and development sectors.”

Likewise, the disclaimer at the head of the Practitioners Guide states that “it is to be used as guidance material only” and that “users of the Guide should consult with the appropriate decision-making authority for which the environmental assessment is undertaken for further information on assessment requirements specific to applicable statutory requirements and expected best practice.”

Moreover, the Guide states clearly that the document is an “evolving product” and not the “final word” on cumulative effects assessment and will be updated and revised as the practice of [cumulative effects assessment] evolves.”

In short, as the Guidebook also states, the Guide is meant to be “generic to any legislated assessment process” and therefore not specific to any particular project or the unique context that it may represent.

Nevertheless, the concern expressed by the Forest Practices Board is that, if each assessment begins with the current condition as the baseline, and evaluates impacts against that baseline, the assessment process might tend to cause the baseline to be continuously eroded.

As the Board states, this erosion effect is often referred to as “baseline creep” and, in the Practitioners Guide, as “nibbling loss.”

However, the fact remains that, for the Toba Montrose project, past human activity would mostly have been logging activities, and the current conditions (e.g., old logging roads and a legacy of second and third growth forests) would reflect that past use of the land.

In other words, the Toba Montrose project was not dealing with a brownfield site where past industrial uses would have seriously, and irrevocably, impacted the environment.

Question #10: “How did consultation differ from what forest licensees must do?”

To quote the Forest Practices Board report directly: “For the Toba Montrose project, project-level consultation was extensive and exceeded common practice in the forest industry.”

Detailed discussion of Question #10

In their complaint to the Forest Practices Board, the Sierra Club and the Friends of Bute Inlet claimed that the Toba Montrose project did not involve the public in the same way that traditional forestry operations do and then questioned whether public involvement in, and public disclosure of, the routing of the transmission line was adequate.

They also expressed a belief that the project proponent should have held public meetings in a center larger than Powell River, perhaps in Campbell River.

The Forest Practices Board, however, did not agree with their assertions and the Board states very clearly, and very prominently, that “for the Toba Montrose project, project-level consultation was extensive and exceeded common practice in the forest industry.”

As the Board’s report states, the proponent held a public open house in Powell River in November 2004 during the pre-application phase of the project.  Subsequent open houses were then held in Powell River and other nearby communities during the application review stage from January to March 2006.

In all, as the Board notes in their report, seven open houses were held, along with informal meetings in Powell River with various community members and site tours for interest groups.

In fact, as the Board notes in their report findings, “some of the most effective approaches to consultation occur outside of the legal framework.”

Question #11: “Should the proponent have held a public meeting in a larger centre?”

The answer is “no,” there was no indication that a public meeting at a larger centre was warranted or that it would have attracted any additional interested parties.  The decision to not hold a meeting in a larger centre was reasonable.

Detailed discussion of Question #11

As the Forest Practices Board states in its report: “The proponent held seven open houses in nearby communities of Power River, Cortes Island and Sechelt. The proponent was not required to hold a meeting in a larger centre and the EAO policy did not provide guidance on the issue.”

Moreover, as is also stated in the Board’s report, “members of the public did not request such a meeting, despite a high level of awareness about the project.”

The Environmental Assessment Office found that there was “limited public interest in the project at the time, and stated that there was no indication that a public meeting at a larger centre was warranted, or would have attracted any additional interested parties.”

The Board therefore considered the decision to not hold a meeting in a larger centre to be a reasonable one.

Question #12: “Was there adequate public involvement in and disclosure of the routing of the transmission line?”

The answer is “yes,” public involvement in and disclosure of the transmission line route was adequate.

Detailed discussion of Question #12

As the Board states in its report, the proponent made the location of the transmission line known to the public through open houses and during discussions with various interest groups, including the Powell River Regional District, Powell River Regional Economic Development Society, Eldred Climbers Society and Stillwater Community Advisory Group.

The location of the proposed transmission line was also made publicly available in the proponent’s application which was posted on the Environmental Assessment Office’s website, and was also made available through public libraries in nearby communities.

The Powell River Alpine Club (PRAC) did express concern about the impact on a campground and on hiking trails, but other than that the Environmental Assessment Office received “limited comment from the public about the location of the transmission line” during the review period.  In response to the Powell River Alpine Club’s concerns, the proponent committed to locating transmission poles so as to minimize impacts.

All in all, the Forest Practices Board found that public involvement in and disclosure of the location of the transmission line was adequate.

Concluding comments (i.e., “Smashing, Basil!… But what does it all mean?”)

If you’ve stayed with us this far, you’re not only a bone fide green energy trooper, you’re probably also hoping we’re going to wrap this thing up soon and provide you with a pithy summarization.

Well, you’re in luck.  This is the concluding section of what has turned out to be an epic posting; and it will be suitably pithy.

Perhaps the best way to sum up the Forest Practices Board’s findings in this matter is to quote directly from the Board’s June 9, 2011 News Release in which they announced that their investigation into the Toba Montrose project’s forest practices had been concluded.  The lead sentence from that news release states:

“An investigation into a complaint about a run-of-river power project in Toba Inlet, north of Powell River, found that harvesting and road building followed requirements to protect the environment, according to a Forest Practices Board report released today.”

And as the Chair of the Forest Practices Board, Al Gorley, went on to state in that June 9th News Release:

“The requirements for this project were similar to those required of forestry operations and, in some cases, were more stringent…. For example, they hired an independent monitor to oversee the construction work, and public involvement and consultation exceeded what is required for forestry operations.”

So there you have it.  High marks for the Toba Montrose project from the “independent watchdog for sound forest and range practices in British Columbia.”

Very clearly the proponent followed not only the letter and the spirit of the environmental protection rules and regulations, in some cases they actually exceeded what was required and put measures in place that were more stringent than those commonly seen in the forest industry.

And as we noted at the beginning of this posting, if the Friends of Bute Inlet and the Sierra Club were hoping for some sort of scathing condemnation of the Toba Montrose project by the Forest Practices Board they definitely didn’t get one.  On the contrary: the Board’s findings were very positive.

That’s not to say human error and/or accidents will never occur, or that these can somehow be systematically factored out of the equation wherever human beings are involved (including energy projects).  That would be highly unrealistic and a bar that no person or project could ever measure up to.

But in the case of the Toba Montrose project, the proponent clearly took prompt and appropriate steps the rectify human errors and accidents, wherever and whenever they occurred, and demonstrated a commendable and conscientious respect for the environment.

Epilogue: One final comment, if we may

One final comment seems appropriate in summing up our analysis of the Forest Practices Board’s findings.

As per the Board’s mandate, their investigation focused on how logging, road building and related planning for the Toba Montrose project impacted forest resources.

In this respect, the Board’s investigation was very concrete and did not venture into questions that fell outside the Board’s stated mandate, such as whether independent energy projects are in the public interest.

But our group’s mandate (if you can call it that) does not preclude us from commenting on such a question and we can say, without any reservation whatsoever, that independent green energy projects are very definitely in the public interest.

Not only do independent green energy projects help us tap into renewable energy resources that are clean and non-emitting, they also provide excellent value for BC Hydro ratepayers because they can typically provide us with new sources of energy at a lower cost than new BC Hydro projects, such as the proposed Site C dam, or at a cost comparable to refurbished BC Hydro dams.

Our generation seems to have forgotten that the mega dams we inherited from previous generations weren’t built for free.  Our parents and grandparents paid dearly for those dams, and in so doing they provided our generation with a valuable legacy of inexpensive, clean, renewable energy.

We owe that same legacy to the generations that follow us.

Unfortunately, as we’ve pointed out numerous times before, BC Hydro has been a net importer of electricity throughout most of the past decade because the province’s mega dams can no longer produce as much electricity as B.C.’s growing population consumes.

And more recently, the province as a whole has also become a net importer, with a “declining trade balance in electricity,” as Professor George Hoberg from UBC’s Department of Forest Resources Management found through his research on the subject.

Is this the legacy we want to pass on to our children and grandchildren?  A declining trade balance in electricity!

B.C.’s population is growing and so is our need for clean electricity.  Nothing can therefore serve the public interest better than making sure future generations have access to the same clean, affordable energy we’ve enjoyed through the courtesy of our predecessors.

And although some of the more sentimental occupants of the BCCGE mailroom are weeping openly at this point, the issue is a very serious one indeed and deserves intelligent, well-informed discussion.

There will undoubtedly be those who will try to distort and misrepresent the findings of the Forest Practices Board in the coming days, adding to the toxic load of misinformation that already surrounds the green energy issue in this province.

But the boys in the BCCGE mailroom will persevere and continue to do everything they can to get the real story out and make sure the real public interest, not special interest, is being served.

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