Underlying the corporate philosophy of the wind industry is the suggestion that its projects are socially valuable. We often hear rhetoric claiming that the industry is an alternative to destructive energy sectors such as oil and gas and mining.
While there is likely some truth to this, the assumption that windfarms are green projects and thus sustainable development is problematic. Nowhere is this more evident than in the Peace Region of BC. Here the provincial government’s promotion of unfettered renewable energy development is in conflict with the public interest to protect caribou from extinction.
The proposed Hackney Hills Windfarm Project issituated on top of alpine ridges in the Rocky Mountains approximately 25 km north of the Williston Reservoir and adjacent to Butler Ridge Provincial Park. The initial phase is 370 megawatts with a predicted construction footprint of approximately 902 ha, including permanent infrastructure such as new roads, a 230 KV power line, 180 turbines, and four substations.
What makes the Hackney proposal challenging from an environmental point of view is its location, as a substantial portion is situated within four Ungulate Winter Ranges (UWR) and three Wildlife Habitat Areas (WHA). Both the UWRs and the WHAs were enacted by BC to protect the wintering, calving, and rutting areas of the Graham caribou herd and are vital to the survival of the herd. Dr. Dale Seip, BC’s top caribou scientist, has stated that “[t]he core winter ranges are a very limited habitat and support high caribou densities. Any activities which degrade this limited habitat, or displace caribou from the area, pose a significant risk to the caribou population.”
The windswept alpine ridges, currently growing the terrestrial lichen which supports high densities of caribou, will be replaced by all-season roads and turbines. The proposal will likely destroy 493 ha of critical habitat.
Forgotten Caribou in the Midst of Industrialization
Historically a sea of caribou roamed the mountains and boreal forest of the Peace Region. Today, however, the species has dwindled down to small herds because of cumulative impacts. Their population is now legally defined as threatened under the Species at Risk Act (SARA). In recognition of the dire situation and the need for immediate action, SARA and the subsequent Accord between Canada and BC include a legal obligation for government to develop and implement recovery strategies by June 5, 2007 for caribou throughout the province. Despite this obligation, the recovery planning process for the Graham herd (as well as six other herds) in the South Peace was permanently discontinued in 2003 by the BC government.
Even the Government of Canada has turned a blind eye, which is more egregious given that it has the legal authority to protect the caribou even if BC refuses to do so. Such blatant inaction on the part of our governments has given industry a green light. Within the Peace Region there are roughly 32,000 existing oil and gas well sites, five coal mines, clear-cuts blanketing the land-base, and two large-scale hydroelectric dams. There is also an assortment of infrastructure – thousands of kilometres of power lines, roads, and pipelines as well as hundreds of industrial facilities. With approximately 190 wind tenures, three windfarms have been approved and an additional eight are awaiting approval, including the Hackney proposal. The cumulative impacts on caribou herds will be more intense in the years to come.
Hackney’s EIA: Another Farce?
Because of the power generation potential, the Hackney proposal is subject to an Environmental Assessment (EA) pursuant to BC’s Environmental Assessment Act. It is currently entering the review stage of the process. Once it enters the review, the documents will be available on the EAO website. Whether the proposal will be reviewed under the Canadian Environmental Act is currently unknown.
Not surprisingly, the Environmental Impact Assessment (EIA) for the Hackney proposal is similar to many others administered by BC’s Environmental Assessment Office (EAO): technocratic documents replete with circular reasoning and little to no ecosystem-based approaches. For example, the EIA discusses protective measures for caribou associated with the UWR and the Motor Vehicle Prohibition Regulation (MVPR), and then highlights how these measures do not apply to oil and gas and mining companies but are applicable to the wind industry. Through implication, and perhaps a sense of entitlement, the EIA uses the precedent set by non-renewable industries to justify its own proposal. It will likely be applying for exemptions from the management directions in the UWR and MVPR that are designed to protect the Graham herd from going extinct.
The EIA states that a census in 2009 produced a population estimate of the Graham herd of approximately 301 animals, in comparison to a 2002 study that concluded there were 282. While the EIA does note that the population is declining and that the trend is “uncertain,” the scale of the decline is significantly downplayed by the omission of earlier scientific data.
The EIA does not mention a 1989 census, with an estimated population at approximately 1,174 animals. While seemingly high, the 1989 findings are consistent with the findings of a 1988 study and are harmonious with historical-local knowledge that maintains a “sea of caribou” once existed. In addition, the 1989 study demonstrates that calf recruitment has decreased from 15.7% (an indication of a stable population) in 1989 to roughly 10% (an indication of an unstable population) by 2009. The omission of data calls into question not only the accuracy of the baseline, but also the validity of the impact analysis itself – and perhaps the entire EIA.
Recently, a set of Best Management Practices (BMP) have been developed. They are based on the best available science and are applicable to all of the industrial sectors. Not all of these BMPs, however, have been taken into consideration by the EIA. The omitted BMPs include:
• do not reduce the terrestrial lichen ground cover,
• do not reduce the arboreal lichens,
• do not create disturbances which will disturb or displace caribou from the area, and
• do not create improved predator or human access.
The EIA does not provide a rationale for including some BMPs while excluding others. Nor does it present new data that renders the existing scientific knowledge invalid. What’s clear is this: the BMPs that have been excluded are incompatible with the various components of the Hackney proposal.
The EIA concludes there will be no cumulative impacts. In the age of climate change and the scientific uncertainty noted in the assessment, such a contention is unsubstantiated. Further, the EA explicitly notes that there are industries such as oil and gas and industrial forestry operating in the area, but fails to analyze and discuss the impacts to the caribou of the past, present, and foreseeable activities of such industries.
Mitigation, Not Recovery
Various mitigation methods are suggested in order to lessen the impacts to caribou. Some are obvious, like reducing the footprint size where possible and planning construction activities to coincide with timing windows. Others are not. Most notable is the idea of creating “maternal pens,” which is a euphemism for building cages and rounding up the caribou as though they were cattle. These cages are intended to compensate for the loss of calving habitat and to increase calf recruitment; however, the EA does not include precise details as to how the capturing and caging of caribou will work. Our wildlife belongs in the wild, not in cages.
The EIA contends once mitigation has occurred, the potential impacts from the Hackney proposal are insignificant. However, there is no evidence that the mitigation will be successful. There is also no guarantee that other industries in the area will not render the mitigation efforts worthless, especially since their activities have not been adequately considered. Moreover, the terms and conditions in an Environmental Assessment Certificate issued by the BC EAO are not legally binding on other industries. Ultimately, the approach to mitigating impacts is more akin to spinning a roulette wheel than it is to science-based decision making.
What makes the sustainability of certain wind projects questionable in BC’s northeast are the adverse effects of existing industrialization, cumulative impacts, and the lack of recovery planning. Windfarms have a place on the landscape, but not at the expense of potentially losing a species that we are desperately trying to protect for future generations.
Bruce Robert Muir is an environmental planner. When he’s not looking over the shoulder of industry, you can find him fly fishing in one of the many beautiful rivers in northeast BC.
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