Springbank Off-Stream Reservoir Project

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Attachment Administrator on behalf of Springbank Community Association

2021-04-29 0:00
  • Reference Number 1376
  • NRCB Hearing Outcomes & SCA Comments: SR1 Project
  • Please see the attached submission
  • Attachment Included
  • 1 Delivered by email to iaac.springbank.aeic@canada.ca Impact Assessment Agency of Canada (IAAC/CEAA) Attention: Jennifer Howe (IAAC / CEAA) April 26, 2021 Re: Biodiversity and Fish Summary of Findings: • Offsetting plans and costs for wetlands and fish offsets are missing from the Proponent’s submissions. • Fish impacts are negative and rescue operations, as discussed by the Proponent at the NRCB hearing are costly and unrealistic. • SR1 contravenes the SSRP’s statements on intact native grasslands. • Wetland Policy • Desktop analysis for Elk mapping is inconsistent with observed elk in the area. • SR1 is at odds with Alberta Wetland Policy. • Cumulative impacts have not been adequately considered and the regional assessment area is not consistent with the Terms of Reference. Offsetting Plans: The Stoney Nakoda raised omissions in the offsetting plans for fish, which they have apparently been told will include offsetting ...
  • Attachment Included
  • 1 Delivered by email to iaac.springbank.aeic@canada.ca Impact Assessment Agency of Canada (IAAC/CEAA) Attention: Jennifer Howe (IAAC / CEAA) April 26, 2021 Re: SR1 Benefits, Costs and the Impact of the Bow River Reservoir Summary of Findings: SR1 flood-only design is dependent on new drought management capabilities on the Bow River. SR1 benefits are lower than MC1 benefits. SR1 capital costs continue to increase while operating costs are not disclosed. SR1 operating costs estimates are insufficient. SR1 benefit/cost ratio does not appear to include the worst case for operating costs in a design flood, but assumes worst case scenario is avoided in the “benefits” calculations. Drought on the Bow and Flood Mitigation on the Elbow Beginning on page 102 of Ex 349, Mr Rae asks a series of questions about drought and the scope of the SR1 analysis. This is a crucial line of questioning that we hope regulators are taking seriously. In Ex 325, ...

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Attachment Administrator on behalf of Springbank Community Association

2021-04-28 0:00
  • Reference Number 1364
  • Required NRCB Hearing Outcomes & SCA Comments: SR1 Project
  • Hello Ms Howe,   The Springbank Community Association submits the attached comments to IAAC following the SR1 NRCB hearing.   We may have additional comments as we are still working through a review of the hearing transcripts.      Regards,     -- Karin Hunter President   https://springbankcommunity.com/  https://www.facebook.com/springbankcommunityassociation
  • Attachment Included
  • 1 Delivered by email to iaac.springbank.aeic@canada.ca Impact Assessment Agency of Canada (IAAC/CEAA) Attention: Jennifer Howe (IAAC / CEAA) April 26, 2021 Re: Sediment & Air Quality Summary of Findings: The Proponent released new information on sediment and air quality on March 12, 2021. This new information has drastic implications for the Project and that impact the conclusions reached by IAAC on human health and on the environmental impact of the Project. Sedimentation is a serious environmental and health outcome that affects IAAC’s report and conditions. Sediment: In our view, sediment is the most problematic operational and environmental outcome of SR1. New sediment maps released by the Proponent in Exhibit 327 pdf page 190 show that sediments over 10cm in depth have increased 3x since the EIA in 2018, from 260 acres to 790 (early release) and 832 acres (late release) for a design flood! This change, dated March 12, is so material ...
  • Attachment Included
  • 1 Delivered by email to iaac.springbank.aeic@canada.ca Impact Assessment Agency of Canada (IAAC/CEAA) Attention: Jennifer Howe (IAAC / CEAA) April 26, 2021 Re: SR1 Flood Effectiveness Summary of Findings: The MC1 project is superior to SR1 for flood mitigation for all communities and at flood events far larger than the 2013 event. This is demonstrated through a comparison of flow rates. This information was available in March 2016, at the latest, and was reaffirmed in 2017 reports for MC1. Why weren’t SR1 and MC1 compared using flow rates? Why was the basis of the comparison between the two projects total storage volume? Were flow rates accidentally overlooked or was this comparison intentionally avoided? Storage Volumes vs River Flow Rates: An unacceptable oversight At the NRCB hearing for SR1, Alberta Transportation (AT) stated clearly that floods are caused by flow rates, not volumes. NRCB Exhibit 350 Transcript page 156: Matt ...

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Attachment Administrator on behalf of Lee Drewry

2021-04-22 0:00
  • Reference Number 1363
  • SR1 and NRCB Hearing
  • It is my understanding that, although a Joint Review Panel was not agreed to by the IAAC, the IAAC would be monitoring and considering the information raised during the NRCB Hearing on the SR1 Project in its final determination of the approval or rejection of this project.   The attached document outlines some of the many concerns raised at the recent NRCB Hearing regarding the SR1 project.  The evidence provided during the NRCB Hearing differs in many significant ways from the overly positive views outlined in the Proponent’s Environmental Impact Statement submitted to the IAAC in 2018.  It is my belief that this information should cause the IAAC to revisit its Draft Environmental Assessment Report.  The environmental consequences of the SR1 project are much worse than was reported in 2018.  Further, the consultation record provided by the Proponent, with regard to both First Nations and the Public, seems to ...
  • Attachment Included
  • Springbank Reservoir (SR1) - Summary of Relevant Information from NRCB Hearing The following is a summary of some of the information provided at the NRCB Hearing into the SR1 project that is relevant to the decision made by IAAC regarding the environmental impacts of the project. Project Benefits It is clear from the evidence presented at the Hearing that the benefits provided to Albertans from the SR1 project are uneven. The project provides 1 in 200 year flood protection to residents downstream from the Glenmore Reservoir in Calgary and significantly less than that to residents upstream of the Glenmore Reservoir in Calgary and residents in Rocky View County downstream from SR1. Residents in the towns of Redwood Meadows (on the Tsuut’ina Nation) and Bragg Creek also receive less than 1 in 200 year flood protection from berms to be built in those towns. Interestingly, in a 2015 presentation to the Calgary River Communities Action Group, the Proponent ...

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Attachment Administrator on behalf of Flood & Water Management Council (FWMC)

2021-03-13 0:00
  • Reference Number 1355
  • Serious risks with the SR1 project have not been addressed before the hearing
  • Dear Laura, Jennifer, and respectable members of the hearing panel, In our submission of Thursday, February 25, 2021, we presented three main concerns and questions have to do with the Springbank dry reservoir (SR1); dam safety, water quality and Environment protection. We urged the NRCB not to ignore any of these serious and high risk issues. A reply from the proponent posted on the NRCB’s site did not address these three issues, providing unsatisfactory reply on one of the issues stating in P. 72, “AT notes that SR1’s capacity accommodates a design flood based on the largest flood on record for the Elbow River, which is the 2013 flood…”. This statement blatantly contradicts a previous acknowledgment of the fact that records show there have been two floods in Alberta 30% larger than the 2013. The attachment includes the three main issues of concern: 1-      ...
  • Attachment Included
  • 1 Table of Contents 1.1 Serious Issues with the Springbank Off-Stream Reservoir Project ...........................3 1.1.1 Back-to-back floods/a semi-filled reservoir ......................................................3 1.2 More alarming issues with Springbank Off-Stream Storage Project .........................4 1.3 December 18, 2020 report DID NOT address the main safety concerns ..................6 1.4 History of failing projects and financial blunders in our province ............................8 1.5 TsuuT’ina Nation Clean Water Immediate Challenges .............................................8 1.6 STUDYING THE ALTERNATIVES, AND THE NEED FOR AN INNOVATIVE APPROACH ..........................................................................................................11 1.6.1 Critical relevant facts .......................................................................................12 1.7 blatant conflict of interest ...

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Attachment Administrator on behalf of Ermineskin Cree Nation

2021-03-4 0:00
  • Reference Number 1353
  • Langlois (JFK) to Howe (IAAC) Comments on Draft EA Report and Potential Conditions
  • Good Afternoon Jennifer,   Our firm is legal counsel to Ermineskin Cree Nation in relation to the Springbank Offstream Reservoir Project.  Please find attached the following documents:   1.       Comments on Draft EA Report and Potential Conditions (attached); and 2.       Enclosures (found at this link (https://jfklawcorp-my.sharepoint.com/:b:/g/personal/jwasyluk_jfklaw_ca/ESlIc_xE7VVDg3nD0UhwuToBtXCiMNsZMyM5H_wHHdMgUw?e=nKFxYX)).   Will you please confirm receipt of this email?   Kind regards,   Jackie Wasyluk to Blair Feltmate (she/her/hers) Legal Assistant   JFK ...
  • Attachment Included
  • March 4, 2021 Delivered by Email: (IAAC. Springbank.AEIC@canada.ca; jennifer.howe@canada.ca) Impact Assessment Agency of Canada Prairie and Northern Region #1145, 9700 Jasper Avenue Edmonton, AB T5J 4C3 340-1122 Mainland Street Vancouver BC V6B 5L1 T 604 687 0549 F 604 687 2696 www.jfklaw.ca Jeff Langlois he/him/his Principal Direct Line: C E File No. 1184-009 Attention: Jennifer Howe, Project Manager, Prairie and Northern Region Re: Comments on draft EA Report and potential conditions Our firm is legal counsel to Ermineskin Cree Nation (“Ermineskin”) for the proposed Springbank Off-Stream Reservoir Project (the “Project”). We write to provide comments on the draft Environmental Assessment Report (the “draft EA Report”) and potential conditions published by the Impact Assessment Agency of Canada (the “Agency”) on January 4, 2021. Ermineskin appreciates the Agency extending the timeline to provide these comments. Prior to ...

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Attachment Administrator on behalf of Blood Tribe/Kainai

2021-03-4 0:00
  • Reference Number 1354
  • Langlois (JFK) to Howe (IAAC) - Blood Tribe Kainai - Comments on draft EA Report and Potential Conditions
  • Good Afternoon Jennifer,   Our firm is legal counsel to Blood Tribe/Kainai in relation to the Springbank Offstream Reservoir Project.  Please find attached the following documents:   1.       Comments on draft EA Report and Potential Conditions (attached); and 2.       Enclosures found at this link:  TLU - Traditional Knowledge_ Land_ and Resource use Study - By Dermot O Connor - June 2018(107639.1) (https://jfklawcorp-my.sharepoint.com:443/:b:/g/personal/jwasyluk_jfklaw_ca/EfNafp54yQdMnrY09yV1vFIBu6fEkznAt2U42UBxWDm4mg?e=4:C51TIv&at=9)   Will you please confirm receipt of this email?   Kind regards, Jackie Wasyluk Legal Assistant to Blair ...
  • Attachment Included
  • March 4, 2021 Delivered by Email: (IAAC. Springbank.AEIC@canada.ca; jennifer.howe@canada.ca) Impact Assessment Agency of Canada Prairie and Northern Region #1145, 9700 Jasper Avenue Edmonton, AB T5J 4C3 340-1122 Mainland Street Vancouver BC V6B 5L1 T 604 687 0549 F 604 687 2696 www.jfklaw.ca Jeff Langlois he/him/his Principal Direct Line: C E File No. 1184-009 Attention: Jennifer Howe, Project Manager, Prairie and Northern Region Re: Comments on draft EA Report and potential conditions Our firm is legal counsel to Blood Tribe/Kainai (“Kainai”) for the proposed Springbank Off-Stream Reservoir Project (the “Project”). We write to provide comments on the draft Environmental Assessment Report (the “draft EA Report”) and potential conditions published by the Impact Assessment Agency of Canada (the “Agency”) on January 4, 2021. Kainai appreciates the Agency extending the timeline to provide these comments. Prior to engaging ...

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Attachment Administrator on behalf of Springbank Community Association

2021-02-18 0:00
  • Reference Number 1350
  • SR1 Comments on CEAA Report and Conditions
  • Please see the attached submission.
  • Attachment Included
  • 1 Impact Assessment Agency of Canada (IAAC/CEAA) National Resources Conservation Board (NRCB) Delivered by email Attention: Laura Friend (NRCB) Jennifer Howe (IAAC / CEAA) February 13, 2021 Re: Air and Human Health (CEAA Sections 6 and 7) Our comments address CEAA’s draft conditions of January 4, 2021 along with Package 4-Technical Review Round 2, March 23, 2020 and July 2020, and the Proponent’s land-use plan from October 2020 (Question 4-05) among other items from the Proponent’s prior submissions. We have not had the opportunity to adequately review the most recent December 18, 2020 Project Design given the holidays and requirement to comment on CEAA draft conditions by February 3, 2021. We remind regulators that we are community volunteers who spend inordinate amounts of time keeping up to date with submissions. We also express dismay that the NRCB Pre-hearing took place before the latest design was released. We did not have any ...
  • Attachment Included
  • 1 Impact Assessment Agency of Canada (IAAC/CEAA) National Resources Conservation Board (NRCB) Delivered by email Attention: Laura Friend (NRCB) Jennifer Howe (IAAC / CEAA) February 17, 2021 Re: SR1 Risk Comments Our comments address CEAA’s draft conditions of January 4, 2021 along with Package 4-Technical Review Round 2, March 23, 2020 and July 2020, and the Proponent’s land-use plan from October 2020 (Question 4-05) among other items from the Proponent’s prior submissions. We have not had the opportunity to adequately review the most recent December 18, 2020 Project Design given the holidays and requirement to comment on CEAA draft conditions by February 3, 2021. We remind regulators that we are community volunteers who spend inordinate amounts of time keeping up to date with submissions. We also express dismay that the NRCB Pre-hearing took place before the latest design was released. We did not have any indication that this updated ...
  • Attachment Included
  • 1 Impact Assessment Agency of Canada (IAAC/CEAA) National Resources Conservation Board (NRCB) Delivered by email Attention: Laura Friend (NRCB) Jennifer Howe (IAAC / CEAA) February 14, 2021 Re: SR1 Project General Comments Our comments address CEAA’s draft conditions of January 4, 2021 along with Package 4-Technical Review Round 2, March 23, 2020 and July 2020, and the Proponent’s land-use plan from October 2020 (Question 4-05) among other items from the Proponent’s prior submissions. We have not had the opportunity to adequately review the most recent December 18, 2020 Project Design given the holidays and requirement to comment on CEAA draft conditions by February 3, 2021. We remind regulators that we are community volunteers who spend inordinate amounts of time keeping up to date with submissions. We also express dismay that the NRCB Pre-hearing took place before the latest design was released. We did not have any indication that ...
  • Attachment Included
  • 1 Impact Assessment Agency of Canada (IAAC/CEAA) National Resources Conservation Board (NRCB) Delivered by email Attention: Laura Friend (NRCB) Jennifer Howe (IAAC / CEAA) Re: SR1 Land Use (CEAA Sections 6 & 9) Our comments address CEAA’s draft conditions of January 4, 2021 along with Package 4-Technical Review Round 2, March 23, 2020 and July 2020, and the Proponent’s land-use plan from October 2020 (Question 4-05) among other items from the Proponent’s prior submissions. We have not had the opportunity to adequately review the most recent December 18, 2020 Project Design given the holidays and requirement to comment on CEAA draft conditions by February 3, 2021. We remind regulators that we are community volunteers who spend inordinate amounts of time keeping up to date with submissions. We also express dismay that the NRCB Pre-hearing took place before the latest design was released. We did not have any indication that this ...
  • Attachment Included
  • 1 Impact Assessment Agency of Canada (IAAC/CEAA) National Resources Conservation Board (NRCB) Delivered by email Attention: Laura Friend (NRCB) Jennifer Howe (IAAC / CEAA) February 15, 2021 Re: SR1 Project and Migratory Birds (CEAA Conditions Section 4) Our comments address CEAA’s draft conditions of January 4, 2021 along with Package 4-Technical Review Round 2, March 23, 2020 and July 2020, and the Proponent’s land-use plan from October 2020 (Question 4-05) among other items from the Proponent’s prior submissions. We have not had the opportunity to adequately review the most recent December 18, 2020 Project Design given the holidays and requirement to comment on CEAA draft conditions by February 3, 2021. We remind regulators that we are community volunteers who spend inordinate amounts of time keeping up to date with submissions. We also express dismay that the NRCB Pre-hearing took place before the latest design was released. We ...
  • Attachment Included
  • 1 Impact Assessment Agency of Canada (IAAC/CEAA) National Resources Conservation Board (NRCB) Delivered by email Attention: Laura Friend (NRCB) Jennifer Howe (IAAC / CEAA) February 14, 2021 Re: SR1 Project and Wildlife / Biodiversity (CEAA Conditions Section 5) Our comments address CEAA’s draft conditions of January 4, 2021 along with Package 4-Technical Review Round 2, March 23, 2020 and July 2020, and the Proponent’s land-use plan from October 2020 (Question 4-05) among other items from the Proponent’s prior submissions. We have not had the opportunity to adequately review the most recent December 18, 2020 Project Design given the holidays and requirement to comment on CEAA draft conditions by February 3, 2021. We remind regulators that we are community volunteers who spend inordinate amounts of time keeping up to date with submissions. We also express dismay that the NRCB Pre-hearing took place before the latest design was ...

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Attachment Administrator on behalf of Transport Canada

2021-02-17 0:00
  • Reference Number 1342
  • Commented During Project Phase: Environmental Assessment Report
  • Commented On Participation Notice: Public Notice - Public Comments Invited on the Draft Environmental Assessment Report and Draft Potential Conditions
  • For Approval Transport Canada Comments on the Springbank Off-Stream Reservoir Project - draft EA report and potential federal EA conditions
  • Good Day,   On behalf of Jackie Barker, please find attached Transport Canada’s comments on the draft EA report.  Transport Canada appreciates the opportunity to review and provide comment on the draft EA report and draft potential conditions for the Springbank Off-Stream Reservoir Project.   Please find our proposed edits and comments (in track changes) of the draft EA report within the attachment.  Specifically, we have noted on Pages iv, 55, and 64 that the Canadian Navigable Waters Act should be referenced, rather than the repealed Navigation Protection Act.  Additionally, we have noted two comments/suggestions on Page 133 for your consideration.   We also reviewed the new version of the draft potential conditions and note that our previous comments were considered and therefore we have no further comments to provide for that ...
  • Attachment Included
  • Springbank Off-Stream Reservoir Project Draft Environmental Assessment Report January 2021 © Her Majesty the Queen in Right of Canada, represented by the Minister of Environment and Climate Change, 2021. This publication may be reproduced in whole or in part for non-commercial purposes, and in any format, without charge or further permission. Unless otherwise specified, you may not reproduce materials, in whole or in part, for the purpose of commercial redistribution without prior written permission from the Impact Assessment Agency of Canada, Ottawa, Ontario K1A 0H3 or iaac.information.aeic@canada.ca. This document has been issued in French under the title: Projet de réservoir hors cours d'eau de Springbank- Rapport préliminaire d’évaluation environnementale mailto:iaac.information.aeic@canada.ca Draft Environmental Assessment Report – Springbank Off-Stream Reservoir Project iii Executive Summary Alberta Transportation ...

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