Chris Dandurand, P.EngKiewit Infrastructure Group

Large Hydro Perspective on the Permitting Process & Environmental Approvals

How current design, construction and operating permitting process works

Our experience with the process Recommendations on how to improve

Agenda

Environmental Assessment Certificate (EAC):

• Granted to Developer by MOE and Ministry of Energy Mines and Petroleum Resources

• Sets out a Table of Commitments for the Project

• Commitments influenced by relevant parties such as:

Multiple Provincial and Federal Government Agencies First Nations Groups Forest Tenure Holders Public/Community Advisory Groups Sports and Recreation Groups

How it Works

How it Works

Environmental Assessment Certificate (EAC):

• Commitments range from Design / Pre-Construction to Operation of the Facility

Wildlife, Vegetation & Habitat Protection and Alteration Recreational and Commercial Land Use First Nations Agreements & Archaeological Preservation Construction, Operations and Access Restrictions Transmission Line Vegetative Maintenance and Visual Impacts Ecological Community Protection and Reclamation

How it Works

Conditional Water License (CWL):

• Granted after EAC• Outlines scope of design and construction• Sets out the critical parameters for plant design and

operation• Defines deliverables• Sets out approval protocol (Construction Leaves)• Defines Role of the Independent Engineer (IE)• Defines Role of Independent Environmental Monitor (IEM)

Role of the Independent Engineer

Hired by Developer and reports directly to MOE Required to have an engineering background in order to fully

understand design criteria and plans Confirms that the design, construction and operation of the

Facility are in accordance with the CWL, TOC and Developer’s Environmental Management Plan (EMP)

Reviews with the duty to protect the interests of:• The Public• The Environment• The Licensee• Riparian Owners• Owners of Land Adjacent to Project

Detailed design review not part of scope Grant Leave to Construct Permissions for Work Packages on

behalf of MOE

Role of the Independent Environmental Monitor

Hired by Developer Full time site presence to observe and report on construction

works in relation to relevant permits and the CEMP Sign off on construction work plans and recommend best

practices to contractor Provide written reports directly to the IE Facilitates communication between Developer, Contractor,

and Agencies

TOC Commitment 11 States:

“…proponent will commit to developing a Fish Habitat Compensation Plan for any harmful alteration, destruction or disruption (HADD) to fish habitat, including wetlands...that cannot be avoided through mitigation measures.”

Case Study – Transmission Line HADDs

EAC reference document, EAC Application:

“Ongoing consultation with First Nations, provincial and federal government agencies, stakeholder groups, and the general public will ensure that no sensitive areas are affected by the Project.”

Case Study – Transmission Line HADDs

TOC Commitment 55 states:

“The Proponent will continue to liaise with the licensees of TFL X and TFL Y, and will liaise with BC Timber Sales, the Ministry of Forests and Range, and forest licensees.”

Our Expectation that:• Transmission Line routing intended to minimize stranded

timber where practicable

• Coordinate logging activities with construction activities

• Confirm line clearances over access roads

Case Study – Transmission Line Clearances

TFL Holder Expectation of Clearance

EPC Contractor Expectation of Clearance

What is an access road?

TOC Commitment 68 states:

“Criteria for the maximum acceptable rate of stage change (in units of cm/hr) within the tailrace must be developed to ensure that fish colonizing the tailrace are not stranded.”

Case Study – Tailrace Design

Case Study – Tailrace Design

Approved Flat Bottom Tailrace

Flat Bottomed Tailrace design approved by DFO Construction completed without incident Subsequent DFO inspection revealed perceived fish stranding risk

during long term shutdown DFO mandated removal and replacement of tailrace with new

design

Four tailraces were modified after the initial design was constructed

Until actual construction was complete, agencies did not have a full grasp of how the plants would operate

Tailrace “approved” without meaningful agency consultation to ensure that intent was truly understood

Case Study – Tailrace Design

Case Study – Montrose Tailrace

“V-Shaped” Tailrace X-Section

Original authorized design had a flat bottom

Example of real time design modification to address DFO concerns

TOC requirements are often vague but encompass many reference documents

As the developer, understand the limitations or ability for Agencies to review a design drawing for operational criteria

Agencies have a strong presence on the project even after TOC and CWL are granted

Observations

Need to improve Agency understanding at the conceptual design phase

Increased clarity in TOC = Less Risk Involve the IE and IEM in the formation of the TOC and Agency

review Get IE to take agency responsibility after we get the table of

commitments and liaise with all agencies

Recommendations