Watershed Watch submits comments to EAO on Upper Lillooet hydro project
Watershed Watch has submitted a letter to the Environmental Assessment Office containing comments regarding the Application for an Environmental Assessment Certificate for the Upper Lillooet Hydro Project. The letter provides an overview of concerns related to low instream flows, migration barriers, ramping impacts from unplanned shutdowns, and cumulative effects.
The letter concludes: “Watershed Watch Salmon Society has grave concerns about the future of many watersheds in the Sunshine Coast and Lower Mainland, where rampant development of private hydropower projects threaten ecosystem function. While we are not against river diversion projects in principle, proponents of hydropower projects and involved agencies must uphold environmental assessments to rigorous standards in order to ensure protection and conservation of ecosystem function. While impacts of the project on cultural, health and economic values may be predictable, there is considerable uncertainty regarding the long-term effects of river diversion projects on aquatic ecosystems. Most notably, this includes impacts related to extremely low flows for most of the year, for decades on end, to both the diversion reach and downstream regions. Based on the uncertainty underlying the long-term impacts and lack of monitoring data as yet collected from existing river diversion projects, the invariable conclusion by proponents that there will be no significant impacts after mitigation is unjustified, especially given that there is a lack of certainty that proposed mitigations or compensation will be successful and the inherent difficulty in monitoring and measuring mitigation success. The inadequate consideration of cumulative impacts, especially with reference to the potential for long-term, downstream negative impacts to the aquatic environment, is a serious failure on the part of the proponent.”