Analysis and Comments from the Forest Fringe Citizens' Coalition (FFCC)
on SaskPower's Submission to SERM asking for approval of their selected power line PINK ALTERNATE 3 route in the area of Christopher Lake, Saskatchewan.
( This analysis follows principles of the Forest Fringe Citizens' Coalition that urged SaskPower to stay out of the pocket of continuous forest near Christopher Lake and supported a route which does the least damage to environment and stays the farthest from people's homes.)
" This Project Proposal has been prepared by SaskPower and submitted to SERM requesting environmental approval for the preferred route option, Pink Alt 3, pursuant to the Saskatchewan Environmental Assessment Act. SERM approval is required before construction can proceed." (Quoted from section 4.4 of the SaskPower document)
SaskPower's document quoted above, in many places openly acknowledges that the selected route, Pink Alt 3, does the most serious damage to the environment and adversely affects the most people of all the route options available to SaskPower. This approval should be refused by SERM and opposed by all levels of elected officials and by the general public. The project routing is not a good decision, and the impact of this mistake will be a major and permanent scar on a very sensitive and beautiful land which is the natural heritage of the local community and of the entire province of Saskatchewan.
The two main arguments provided by SaskPower for selecting the environmentally most damaging route are that it would impact on less private land, and that the damage in the Northern Provincial Forest (NPF) would be happening anyway because of SaskPower's claim that Weyerhaeuser plans to harvest the area east of Christopher and Oscar Lakes in the immediate future. On investigation, the Forest Fringe Citizens' Coalition has found that both of these claims are proven to be false.
SaskPower's definition of "affecting private land" narrowly based on the physical location of the actual power poles, refuses to include many residents who will be significantly and adversely impacted by the power line corridor even if the poles are not physically on their private property. The entire length of Pink Alt 3, except for the final few km located directly beside Highway 2 at the north end of this project, impacts directly on adjacent private lands. This is especially the case in the Christopher Lake area where the very wide powerline corridor of Pink Alt 3 will destroy forest in a wide swath on its entire path through the R.M. of Lakeland # 521. The location of this powerline corridor through the Northern Provincial Forest in the narrow and environmentally sensitive strip of boreal forest and water between Christopher Lake and the private properties along Highway 2, will have impact on thousands of local residents living on, and people using Christopher Lake, as well as the many tourist visitors this area hosts each year.
Information obtained from Weyerhaeuser Saskatchewan about their harvest plans for the forests to be affected by Pink Alt 3, illustrates that the claims made by SaskPower are invalid. (See comments on Section 4.3) The precise and accurate harvest plans can be checked by contacting Weyerhaeuser harvesting planners as was done for this analysis.
Eventually Weyerhaeuser does plan to harvest in the area where SaskPower plans to route Pink Alt 3, but not in the short-term . When the harvesting eventually does happen, the harvest of trees will follow a very different process than the continuous clear-cut pattern required for SaskPower's Pink Alt 3 power line corridor. When the forest is harvested, cutting pattens are designed to prevent the cut area being visible from the adjacent lake, and immediately after the harvest, restoration of the forest is undertaken and then the area is closed to further access. This is in recognition that continued access into these areas will devastate the game populations that will seek out the new growth.
In stark contrast to Weyerhaeuser's harvest strategies, SaskPower's plan, for the entire length of the line in the forest, a 70 - 80m wide corridor will be stripped and all tree growth permanently eliminated by chemical and mechanical means. SaskPower then plans to replace the area of destroyed forest with non-forest grasses and maintain it in this manner for the life of the line. After the line is decommissioned the area will be abandoned and allowed to recover as best it can on its own. The line corridor will be a major ATV and snowmobile access route. This will happen even if the ends are "gated". This is known by anyone who understands the issue.
Since most homes and businesses located west of Highway 2, and immediately against the cleared power line corridor are situated to the west ends of the properties, this invasion of hunters and ATV and snowmobile traffic will be into side and back yards for the entire length of Pink Alt 3 in the forest area. This is also true for the rest of the forest area lands along the presently forested road allowance right-of-way. If SaskPower had accepted the advice of many and approached their "connect point" from the east, this would not be the case. This area to the east is not part of the north-south snowmobile traffic routes, and goes through areas of fenced farm lands which are able to stop this traffic.
SaskPower's claim that Weyerhaeuser's eventual tree harvest plans for this area minimize or negates the impact of SaskPower construction through this area is completely inaccurate.
Submissions over the past two years, made by many citizens expressing concerns over powerline corridor construction through forest lands in this region apply completely to the Pink Alt 3 Route decision made by SaskPower in August 2001.
The people of Saskatchewan through elected officials and the Environmental assessments Branch of SERM must not grant this project approval.
The following document is a preliminary analysis of the SaskPower submission to SERM requesting approval for their selected route option. The reader is strongly encouraged to obtain the full document from SERM or SaskPower and to conduct their own analysis or to see the full context of the selections that are quoted in the analysis that follows here, as well as to see maps, charts, drawings and reports that are part of this submission.
Information selected from the
SaskPower Project Proposal, Prince Albert to Timber Cove (PA 8) 72 (138kV Transmission Line Rebuild Stage One - Phase II
- submitted to Saskatchewan Environment and Resource Management - Assessment Branch August 2001.
This document represents only a preliminary analysis of SaskPower's document. Further study may bring other issues to the surface. Since the Submission to SERM is a public document, the reader is encouraged to obtain a copy of the full original document from SERM or SaskPower.
Material in quotation marks and regular type font are direct quotes from the numbered sections of the SaskPower Submission to SERM. In square brackets and italics are comments by Forest Fringe Citizens Coalition (FFCC).
"The transmission line is being constructed exclusively to reinforce energy supply to La Ronge and communities north of Prince Albert." [Does the expected growth of La Ronge justify the significant increase in capacity that will eventually be carried by this 138 kV line?]
" ... utilizes road allowances and crosses a small portion of the Northern Provincial Forest...." [The implication of this wording is that the road allowances in question have been developed as roads, when the fact is that they are fully forested, undeveloped road allowance rights-of-way. The Rural Municipality is highly unlikely to ever build a road on this stretch of road allowance. This road allowance approaches the highway near the crest of a large hill and at a point of high embankment, both factors making highway access at this point unsafe and very expensive. In fact, the Department of Highways requires a service road to be built parallel to the highway should future development in the area require additional highway access points. (A caveat to this effect exists on title for LS2, SE16, 53, R26, W of 2nd ) These facts are known by SaskPower because 15 years ago SaskPower constructed an underground cable right down the middle of this road allowance when it was bringing local electrical service to properties along Highway 2.
"Pink Alternate 3 Route:
...affects only 12 new landowners that do not currently have the existing PA8 line on their property." [This reference appears to not include all landowners along Pink Alt 3 who have road allowance right of way on their land nor does it include those whose properties are directly against the corridor along the west of Highway 2.]
"SaskPower's policy is to construct and maintain transmission lines in a manner consistent with the principles of sustainable development. Sustainable development essentially entails ... maintaining the ecosystem in respect of future generation needs." [The Forest Fringe Citizens' Coalition has consistently been asking SaskPower to follow such principles in designing this route. However, the selected route will destroy a large portion of the small pocket of Transition Boreal Forest that still exists in this area and which is still privately owned and not subject to Forest Companies clear cutting plans, and which is not already completely altered by agricultural development. Owners of private forest land who are also resident in the forest have proven to be the strongest defenders of preserving the integrity of the existing forest.]
"Reduces transmission losses on PA8, which provides for complete recovery of capital expenditures." [This points out that the cost of this project is negligible and in fact should be viewed as a total cost saving to SaskPower. As a consequence any costs associated with routing the line in a less damaging manner are much less than if there was not this substantial cost recovery built into the project.]
3.0 Regional Overview / Environmental Studies
3.1 "The isolated wetlands are surrounded by agriculture in the southern two-thirds of the study area and by continuous forest in the north." [This points to the fact that removal of the continuous forest near and above these wetlands would have a much greater impact on the ecology of the wetlands than would be the case in areas where the wetlands are already surrounded by agricultural development. Yet, SaskPower's selected route crosses or comes near a large number of these wetlands within the continuos forest and deliberately stays away from the wet areas in agricultural lands.]
3.2 "The study methodology, which was reviewed and accepted in principle by Saskatchewan Environment and Resource Management (SERM), was designed to quantify and rank habitat sensitivity to power line development." [It should be noted that this was an early and "in principle" review and did not include endorsement of the actual ranking scheme, and in particular the subsequent derivative creation of "Map 3. Development Sensitivity Class" created by ERIN Consulting Ltd. This is significant, because SaskPower repeatedly uses this map to justify line development through the very sensitive forest areas east of Christopher Lake. This map, by the process of its derivation, purposefully hides the impact and significance of Map 4. " Quartersection Habitat Sensitivity Rankings. Only the derivative Map 3 was sent out to landowners in the Study Area, not the more informative, Map 4. These maps are found in Appendix A. ]
3.3 "Buildings and associated yards are also found throughout the study area. These human habitats are essentially considered as clearings." [This seems to indicate that human beings and their homes are not considered to be part of the environment of this area.]
3.3 "Some of the Crown land in the north part of the project area is included in Weyerhaeuser's Forest Management Area, and forest in the northwest has been allocated for harvesting in their five-year plan." [This is the first of many references to Weyerhaeuser's harvest planning as it relates to this SaskPower project. See comments relating to section 4.3 later in this analysis.]
3.3 "Other secondary land uses in proximity to the proposed line include big game, upland bird and waterfowl hunting, trapping and other recreational activities such as fishing, camping, and boating. Christopher Lake serves as a major recreational resort during the summer months." [This listing omits a major Lutheran Bible Camp, Camp Kinasao, which will be less than ½ mile from the corridor, and Christopher Lake itself which is less than 3/4 mile from the powerline corridor .]
4.0 Routing Analysis
4.1 "After the Panel had submitted their report, SaskPower reviewed and included the Panel's recommendations in the route selection for Phase II." [This reference to the SaskPower response to the Report of the Transmission Line Routing Review Panel, a 141 page document, requires a completely separate analysis. Although SaskPower declares that they adopted 25 of 28 recommendations, the manner in which they were qualified and modified frequently makes the original recommendation unrecognizable in its "adopted" form. A separate analysis of this document and SaskPower's response will be prepared in another document.]
4.1 "Proposed line routes were then selected from the line route possibilities that include (a) the most direct route from point of source to point of load, (b) avoided most areas of highest environmental ranking and c) line routes suggested by the public." [In the northern area, SaskPower's preferred route only avoided one small pocket of 'highest' ranking, and in its entirety, went through areas with average sensitivity rankings of 14/16. The only portion of route suggested by the FFCC that was incorporated was to cut east SOUTH of Northside instead of near homes and through forest NORTH of Northside.]
4.2 "The Forest Fringe Citizens' Coalition presented a new route to SaskPower on July 20, 2001..." [It should be noted that this proposal to SaskPower suggested modifications to SaskPower's Yellow Route in the north. It included the specific commentary that left SaskPower engineers to choose the precise placement of the line. SaskPower was also advised to avoid sensitive features, such as the Garden River. It was also noted that SaskPower has considerable experience and skill in placing powerlines through lower or wet areas, especially with the large spans of this type of construction. This capacity has been demonstrated throughout Northern Saskatchewan.]
4.3 " ... 11 line route segments and nine route alternatives... In completing its assessment ERIN Consulting divided the nine alternatives into three sections - one combined northern route, three northern routes and three southern routes." [Since factors in the southern and northern areas are significantly different, a much clearer understanding can be achieved by separating north from south areas.]
4.3 "In addition Table 2 in Appendix H identifies the number of habitable dwellings that are located within 100m , 250m and 500 m of each of the 11 route segments and the nine route alternatives." [A careful examination of Table 2 shows the following: The northern portion of the SaskPower's preferred route comes closer to more homes (21 homes ) compared to any other northern route segment: yellow (10 homes), blue (3 homes) and the FFCC Route suggestion in the northern area avoids ALL dwellings within 500m of the line! Table 2 fails to acknowledge this benefit of the FFCC suggestion. .
In addition the FFCC route modifications to Segment 9 in the southern area, accepted by SaskPower, reduced by 17 the homes between 250m and 500m compared to SaskPower's original Pink route!]
4.3 "The reader should keep in mind that all routes and alternatives are nearly exclusively situated in habitats ranked as development with mitigation or no development restrictions." [This is once more a reference the ERIN Consulting's derivative Map 3 which obscures the impact of Map 4.]
4.3 "The combined northern route (segment 4):...follows Highway 2 disturbance - minimizes fragmentation effects ... goes through mature aspen continuous forest (unavoidable)" [Of note is that part of this 'combined' section planned to be along the EAST side of Highway 2 is one of the areas scheduled to be included in Weyerhaeuser's annual operating plan submission for 2001 - 2002. An approach to the southern termination/connect point of Phase I through this area from the east rather than from the south would reduce the initial impact of this SaskPower line in the southern area of the NPF.]
4.3 "Assessed as having the least environmental impact in this portion of the study area is YELLOW..."
4.3 "Assessed as having the second least environmental impact in this portion of the study area is BLUE..."
4.3 "Assessed as having more environmental impact compared to Yellow and Blue Routes is PINK ALT 3..."
4.3 "Note that the general area of the NPF is included in the five year harvesting plan of Weyerhaeuser." [Note comments provided later in this section.]
4.3 "Assessed as having the greatest amount of environmental impact is the FFCC Route." [This is SaskPower's assessment, based on an examination of aerial maps by ERIN Consulting without the benefit of an in depth study.]
4.3 "For the northern routes the Yellow Route was rated as the least environmental impact as it would require cutting the least amount of mature forest and avoids the environmentally sensitive stands of mature conifer forests. The Blue Route was rated as the route with the second least impact, but this route does run through a large patch of very sensitive mature conifer forest.... The Pink Alt 3 Route was rated as having higher environmental impact in comparison with the other routes in this portion of the study area... With respect to the issue of this route requiring the most harvesting of mature forest, it should be noted that the section of the NPF in which the Pink Route is located, has been identified by Weyerhaeuser Saskatchewan, as part of their five year harvesting plan. Thus the impact on the forest by the proposed route is reduced." [The Weyerhaeuser Operating Area referred to in the five year planning segments comprises a large block essentially south of Anglin Lake, and situated between the National Park and Highway 2. This area will have harvesting plans to happen within three time periods: 1- 5 years, 6- 10 years, and 11-20 years. The planning is scheduled in this manner to respond to the many interests that will be affected by these harvest plans. Weyerhaeuser planning will, as in the past and as has already been the case in the area south of Anglin Lake, take into account the recreational sensitivity of the area and the need for consultations with the Lakeland Stakeholders's Advisory Committee. When considering these five-year operating plans, the area of present concern is the southern portion lying immediately east of Oscar and Christopher Lakes and west of Highway 2. The key considerations in developing the southern portion of the block are issues of access resulting from the fact that this portion of the block is surrounded by private land on the east and southern sides, independent logging activities within a designated Independent Logging Area. It is definitely not in the 2001 - 2002 harvest plans, and unlikely to be in the following 2002 - 2003 plans because of the previously mentioned issues. Weyerhaeuser strategies for harvesting this area will not consist of a single large clear cut area of the length of the Pink Alt 3 route where it goes west of Highway 2. ]
4.3 "The FFCC Route was determined to have the most environmental impact for the northern section, due to proximity to the Garden River, crossing of bog areas and potential impact to wetlands." [The FFCC proposal recommended staying back from the Garden River in the haylands and open fields . Also, SaskPower's claim, elsewhere in its submission to SERM, repeatedly supports their ability to span rivers such as the Spruce River without any environmental impact on such a riparian area. SaskPower's submission to SERM definitively states that there are no peatlands in the entire Study Area.]
4.3 "Taking into consideration the fact that Weyerhaeuser has five year harvest plans for the NPF area that the northern portion of the Pink Alt 3 Route is located... the overall significance of the difference in potential environmental impacts between the three routes is reduced." [This statement is quite misleading and needs to be weighed against a proper description of Weyerhaeuser's forestry plans in the area as described earlier in this section.]
4.4 Preferred Corridor "The Pink Alternate 3 Route has been selected by SaskPower as the preferred route due primarily to the fact that this route minimizes the number of newly affected landowners and minimizing the amount of private forest lands that will be impacted....incorporates a routing suggestion presented to SaskPower by the FFCC."
[It needs to be noted that in this analysis SaskPower does not include forest landowners along the selected route where the powerline corridor exceeds the road allowance on which the actual powerline posts are situated ( an additional 5 landowner homes), nor the forest landowner properties that are immediately beside the powerline corridor as it goes northward west of Highway 2 through the NPF ( an additional 8 landowner homes). All of these newly affected landowner homes and businesses are considered by SaskPower to NOT BE "impacted' by this project because the centre point of the line will be on road allowance or Crown forest lands. The FFCC suggestion in the northern area stays more than 500m from ALL homes along the route , and in the southern area, the FFCC suggestion accepted by SaskPower, reduces by 17 the number of homes less than 500m from the line.]
4.4 "requires an area of tree clearing of approximately 87.4 ha." [This estimate seems to be based on a corridor width of 40m through the forested portions of the line. Tree heights through most of the forest along private lands on SaskPower's preferred route will have corridor widths of 70 - 80 metres. See SaskPower's drawing Figure 12, Appendix E.]
4.4 "Timber harvesting by Weyerhaeuser in this area of the NPF has already been approved as part of their five-year harvest plan. (Brian Christensen, Weyerhaeuser, personal communications June 2001), and is completely independent of SaskPower's intentions for the PA8 Reinforcement project." [See comments provided for Section 4.3 earlier in this document.]
4.4 " This Project Proposal has been prepared by SaskPower and submitted to SERM requesting environmental approval for the preferred route option, Pink Alt 3, pursuant to the Saskatchewan Environmental Assessment Act. SERM approval is required before construction can proceed."
[Since Pink Alt 3 does the most damage to the environment and adversely affects the most people of all the route options considered, SERM should refuse to provide this approval. The two main arguments provided by SaskPower for selecting the environmentally most damaging route are that it would impact on less private land, and that the damage in the NPF would be happening anyway because of Weyerhaeuser plans to harvest the area in the immediate future.
Since SaskPower's analysis of "affecting private land" fails to include many residents who will be very significantly and adversely impacted by the power line corridor even if the poles are not physically on private property, this argument is invalid. The entire length of Pink Alt 3, except for the final few km along Highway 2, impacts directly on private lands.
According to information about Weyerhaeuser harvest plans provided in earlier comments in Section 4.3, the arguments made by SaskPower are also invalid. The precise and accurate harvest plans can be checked by contacting Weyerhaeuser harvesting planners as was done for this analysis. Eventually Weyerhaeuser does plan to harvest in the area where SaskPower plans to route Pink Alt 3, but that is not in the Company's immediate planning, and the eventual harvesting will follow a very different process than the continuous clear-cut pattern required for the power line corridor. When the forest is harvested, cutting pattens are designed to prevent the cut area being visible from the adjacent lake, and immediately after the harvest, restoration of the forest is undertaken and then the area is closed to further access. This is in recognition that access into these areas will devastate the game populations that will seek out the new growth.
With SaskPower's plan, the entire 70 - 80m wide corridor will be stripped and all tree growth permanently eliminated by chemical and mechanical means. SaskPower then plans to replace the area of destroyed forest with non-forest grasses and maintain it in this manner for the life of the line. After the line is decommissioned the area will be abandoned and allowed to recover as best it can on its own. Also, for the duration of the line corridor, it will be a major ATV and snowmobile access route. This will happen even if the ends are "gated", and this is known by anyone who understands the issue. Since most homes and businesses located west of Highway 2 and immediately against the cleared power line corridor are situated to the west ends of the properties, this invasion of hunters and ATV and snowmobile traffic will be into side and back yards for the entire length of Pink Alt 3 in the forest area. If the route had followed the easterly approach to the connect point, this would not be the case as this eastern area is not part of the north-south snowmobile traffic routes, and goes through large areas of fenced farm lands which would be able to stop this traffic.
To suggest that Weyerhaeuser plans for this area minimize or negates the impact of SaskPower construction through this area is inaccurate.
SERM must not grant this project approval.]
5.0 Project Development Description
5.1 "SaskPower requests environmental approval of a line route corridor. The corridor provides room to move the line should unknown obstacles be encountered in the survey and design of the final centre line. The corridor that SaskPower proposes is 200m wide where located on private and Crown land.... Where the line is proposed to be located in the Road Allowance and highway right of way south of the NPF boundary, the corridors are 50m wide on each side of the road allowance and highway right of way. The corridor SaskPower proposes in the NPF is 200m wide on Crown land; however, the exception to this is that the corridor does not extend onto adjacent private land." [Based on this plan, the line posts could be constructed as far as 60 m into private land that has Road Allowance right-of-way on it, and with an additional 34 m cleared corridor beyond the post position because of tree height in the area, place the cleared corridor 94 m or more inside a property line. This is a major intrusion on and damage to the property.]
5.3 "...the line will be located 0.6 m inside road allowance boundaries. In some cases tree clearing will be required to obtain fall over clearance from trees..." [This tree clearing may be an intermittent requirement in open lands or where there are forest fragments, but in the northern area, it will need to be done along almost the entire length of the line. The height of the trees in most areas will require total corridor width of 70 - 80 m. The repeated reference to a corridor of 40 m with a subsequent reference to "additional tree clearing to obtain fall-over clearance" is deliberately misleading when referring to the forest in the northern areas of Pink Alt 3. This pattern of speaking about corridor width happens throughout this submission to SERM.]
5.4.1 Required Approvals "Approvals and /or permits for construction will be obtained from the following: ... Saskatchewan Environment and Resource Management, RURAL MUNICIPALITIES ...."[Once more SaskPower is declaring that it requires these approvals/ permissions, acknowledging the authority of these agencies .]
5.4.3 "Compensation is provided for the easement and for land out of production because of the structures and for damage to crops or property resulting from construction or maintenance activities. Examples of compensation packages are presented in Appendix F." [These examples indicate very reasonable compensation for land out of use on open agricultural land, but for forest lands a very minimal one-time-only payment at a rate equivalent to vacant pasture lands. The power line corridor in this forest will take "out of use" 992 times as much land as a corridor over an open field or pasture land, yet compensation to the forest land owner is a small fraction of that allowed for the farmer for the same length of line construction.]
5.4.5 "The value of merchantable timber salvaged on private land will be paid to the landowner of private land that has the rights to the timber." [ SaskPower plans absolutely no compensation, nor timber salvage on private lands under Road Allowance right of way, declaring this timber to not belong to the titled land owner. (In phone conversation with Bernie Bolen September 21, 2001.) ]
5.6 "SaskPower proposes to utilize herbicide application or mechanical means or hand cutting of trees for long-term vegetation control, as per the corporation's Vegetation Management Policy (attached in Appendix I) and as per landowner request for preference of right-of-way maintenance method." [This landowner preference applies only to privately owned land, and according to SaskPower's considerations and policies, herbicides WILL be used on road allowances and in the NPF portions of the route despite concerns of adjacent and area residents.]
5.7 Decommissioning and Abandonment "The easement will be relinquished by SaskPower and allowed to return to its natural condition." [This declaration by SaskPower points out that after 50 + years, or when the line is abandoned, there is no commitment to restore the corridor to forest. This means that forest renewal will be at landowner expense and take a very long time.]
6.0 Public Involvement Program
6.1 "SaskPower adopted, or adopted in principle, 25 of the Panel's recommendations, many of which were incorporated into the PA 8 routing process (see appendix)"
[When the SaskPower response to the Transmission Line Routing Review Panel's recommendations is compared carefully to the original report, one will find that many of recommendations said to have been adopted by SaskPower have so many qualifiers and conditions added as to significantly change the direction of the original recommendations. Among the key suggestions of the Routing Review Panel was that a third party facilitator should be used to resolve difficulties between SaskPower and the community with regard to projects already under way, including the PA 8 Rebuild. This was not done.]
6.3 "One individual forwarded a series of e-mail petitions on nine occasions; however these were determined not to be relevant as they were solicited over the internet based on an inaccurate project description, and in large part were from people who were not directly affected by the PA8 Project." [This series of emails were forwarded by Gerald Regnitter of the Forest Fringe Citizens' Coalition in separate mailings to avoid mailbox overload at SaskPower. These were 213 letters that contained this key phrase quoted here from one of the submissions:
" We, Jan and Elzbieta Romanowski of Christopher Lake, support the Forest Fringe Citizens' Coalition opposition to the Sask Power Project, PA8 Rebuild, planned to pass through privately-owned forest lands." This statement of support came from local residents, and also from others in the area, Province and further afield. If SaskPower can unilaterally discard these communications of support, how many other communications were deemed not relevant because they were what SaskPower did not want to hear?]
6.5.1 "One of the factors in the route decision was the amount of tree clearing required, and analysis showed that as the line was lengthened to go around treed areas near Christopher Lake, the overall amount of tree clearing required was not significantly reduced, and in some cases increased." [An examination of SaskPower's Pink, Blue and Yellow routes in the northern portion of the area when overlaid on a map showing forest vs. cleared areas, clearly illustrates that the Pink route goes through significantly more continuous forest than any other route. The Blue Route also destroys large lengths of continuous forest. As SaskPower's own data from ERIN Consulting shows, the environmental damage resulting from going through continuous forest vastly exceeds the damage of tree removal from forest fragments or fence-line trees. Routing along the Yellow or the FFCC recommended modifications to the Yellow route significantly minimized the forest damage despite a total increase in line length.]
6.5.2 "The environmental study shows that only about 5% of the study area has been identified as 'no development / development restriction'...." [This is another reference to Erin's derivative Map 3. With a ranking scale from 1 to 20, where only the water of Christopher Lake is ranked at 20, and the highest land ranking is 18, to put all land rankings other than 18 and 1 and 2 into a single "middle" category effectively obliterates the scale of sensitivity rankings that were first applied to the study area. Add to this the fact that SaskPower only mailed its derivative Map3 to landowners, and not the more informative Map 4. Here we see a process that is much less than the professional and honest disclosure citizens of Saskatchewan should expect from one of their own crown corporations.]
6.5.2 "It is important to note that in the Christopher Lake area there has already been significant development of roads, powerlines... the original habitat has already been fragmented and impacted by local residents, businesses and tourist traffic..." [ It is equally important to note that SaskPower's selected Pink Alt 3 route, in this area near Christopher Lake, in its entirety, goes through the most INTACT forest lands and avoids entirely the lands most disturbed as a result of agricultural farming and grazing activities and other habitat changes.]
6.5.3 "One of the main recommendations from landowners in the forest fringe area was that 'routing through private forests should be considered only as a last resort' and that they would prefer 'routing through already cleared land or Crown forests'. The Pink Alternate 3 Route reduces the amount of private forest affected by utilizing forested Crown land and public road allowances where practical..." [This is a major distortion of the principles for routing proposed by the Forest Fringe Citizens' Coalition. A full reading of the FFCC recommendation being quoted in part here shows that the direction was to minimize damage to forest lands and route where the corridor would do the least damage to the environment and stay the furthest from the homes of area residents. The areas of cleared land and Crown forests which are away from the homes of people are to the east and north in this area, NOT to the west where the selected route destroys the most forest and comes closest to the most homes of any route alternative. A copy of the principles of the Forest Fringe Citizens' Coalition is available from the Forest Fringe Citizens' Coalition members. These principles were unchanged over two years. Anyone who declared support for these principles is deemed to be a member of the Coalition.]
6.5.4 "there is no evidence to suggest that powerlines have a negative impact on either the number of tourists in an area or the quality of their experience..." [This position has been disputed by many people involved in the Tourism sector in this area, and has been attested to by many tourists. This is particularly so after visitors to the area have seen the impact of the PA8 Rebuild Phase I already completed a few kilometres north of the Christopher Lake area.]
6.5.9 "... powerlines do not have significant effects, if any, on either property resale values or the viability of businesses..." [ This is likely true for local 14.5 kV service lines. It is hard to conceive that the impact of the wide corridor and the large structures associated with 138 kV lines on Forest Residential lands, on businesses such as Lakeland Gallery and Friendly Forest Products ,which draw customers because of the beautiful forest setting, and on the many full-time and seasonal homes of the Christopher Lake area , would have no economic impact on resale values of these small land holdings. The generality of this SaskPower claim cannot apply to this area of the project. ]
6.5.13 "In treed areas, at initial clearing the landowner will receive compensation for the merchantable timber....Principles for the Determination of Compensation for Electrical Transmission Powerline Easements that is included in Appendix F" [This appendix F document classifies forest residential lands in the same category as vacant pasture lands and suggests compensations equal to the compensation for the minimal impact a few sets of posts would have on open grazing land . The amount of "land out of use" in the Christopher Lake area forest per unit of line distance is 992 times greater than "land out of use" in areas of already open lands. This great disparity of impact is not recognized in SaskPower documents or planning.]
6.6 "August 14, 1999: Several small acreage owners east of Christopher Lake requested a special meeting with SaskPower..." [The actual number of area residents that attended this 'special meeting' was over 70 persons. It was the insensitive response of SaskPower officials to these residents that brought about the formation of the Forest Fringe Citizens' Coalition.]
6.6 "June 13, 2001 - R.M. of Paddockwood ... June 28, 2001 - Forest Fringe Citizens Coalition" [This listing of meetings with the public omits mention of the SaskPower Open House on June 20 in Christopher Lake, at which about 100 area residents arrived at 7:00 PM as a group to demonstrate to SaskPower that there was a significant number of residents opposed to routing plans through private forests in the area. A report on this meeting with the public is omitted in SaskPower's description of public input in this section of the Submission to SERM document.]
6.6 "July 20, 2001 - Forest Fringe Coalition ...that the proposed route would be 10 km longer and in excess of $1.2 million greater cost than the SaskPower preferred route..." [It is to be noted that the route modifications proposed by the Forest Fringe Citizens representatives increased the length of the Yellow Route designed by SaskPower by less than 3 km , and in doing so stayed more than 500 m away from all homes in the area and avoided damage to larger blocks of forested lands.]
6.7 "Although a small number of landowners affected by the northern segment of the line still do not agree with the line... that the majority of landowners, municipal officials and environmental organizations are in agreement that the proposed route satisfies environmental concerns and has been satisfactorily modified to accommodate landowners wishes to minimize impacts on private land." [On September 20, 2001, in a phone conversation with Gerald Regnitter of the FFCC, Bernie Bolen of SaskPower was asked to provide a list of organizations that supported this statement. Mr. Bolen was unwilling or unable to do so. The fact that within 4 weeks over 1000 persons (as of September 25, 2001) have "adopted"a tree in the selected corridor of Pink Alt 3, to represent them, standing in protest in front of a SaskPower bulldozer, is powerful evidence that many people disagree with this declaration by SaskPower. An analysis of the 1000+ adopting persons shows that 77% are from Saskatchewan, with the majority of these from Christopher Lake and area. Many of the out- of- area tree adopters, and even out-of- Province tree adopters are people who have summer residences in the area affected, or have family in the affected area, or are summer visitors to this area, speaks to the degree of concern for what is happening. The RM of Lakeland # 521 has nearly all of the northern portion of Pink Alt 3 within its boundaries. The Council of the RM of Lakeland # 521, has written a letter to SERM and its Minister expressing its concerns about this routing plan, and has asked to meet with the Minister directly about the matter. In light of all these considerations, it is not possible to accept that this declaration by SaskPower has majority support either here or elsewhere.]
7.0 Sustainable Development
7.1.2 (2.2) "Within the NPF, small wetlands and bogs are present within the proposed corridor. These areas will either be avoided ...or can be easily spanned by the structures." [This declared capacity to minimize or avoid damage to smaller bodies of water should also be applicable to the water / wet areas on the Yellow or FFCC route proposals. SaskPower's document lacks information to indicate the impact of this route development on the watershed and groundwater in the region above Christopher Lake. In particular there is no information about the specific kinds of herbicides that will be used and the effect of these as they move down toward Christopher Lake and into groundwater.]
7.2.2 "location of the line in order to minimize impact on wildlife habitat." [Pink Alt 3 creates a new major corridor through the forest and continues the corridor adjacent to Highway 2. Both of these will impact greatly on wildlife behaviours and increase exposure of game animals to uncontrolled hunting pressures.]
7.2.2 "Large areas of continuous forested lands are uncommon in the study area and are concentrated in the northwest corner. Development can proceed without significant impacts in the remaining half of the study area. Much of the area is comprised of agricultural habitats which are not environmentally sensitive to powerline development." [This selection from the Executive Summary of the ERIN Consulting report correctly identifies the area of the Pink Alt 3 selected route (in the northwest corner) to be the area of highest impact, and the open lands to the east to be the areas of least impact. Yet SaskPower has selected Pink Alt 3, the area of greatest impact.]
7.2.2 "The impact of harvesting mature forest within the NPF on the west side of Highway 2 is minimized significantly with the known plans of the area being harvested within the next five years." [As noted earlier, this claim is not supported by recent descriptions of Weyerhaeuser harvest planning for this area.]
7.2.2 "The creation of a new access and thus a potential for increased opportunity for hunting is not an issue with the location of the line in the NPF as it is in such close proximity to Highway 2." [the impact on game animal behaviour in the corridor along Highway 2 is already being observed by some, with the resulting increased exposure to uncontrolled hunting. The corridor into the NPF behind the private properties adjacent to the highway will provide hunter access into an area close to homes and more difficult to supervise by SERM officials.]
SaskPower's preferred route proposal repeatedly and correctly recognizes that the disturbance caused by a power line corridor has more negative impact through forested land than already cleared land. SaskPower, however, justifies putting the line through the route with the most forest on the basis that it will be harvested anyway and that La Ronge needs the power.
The FFCC has always supported the need to ensure La Ronge has an adequate power supply, and recognizes wood harvesting as a valid use of forest land - the forest returns quickly, especially with assistance. What SaskPower fails to appreciate is that its preferred route proposal will permanently destroy much more sensitive forest land than is necessary.
There is a cost for doing the right thing. Protection for the environment and respect for the people who live on the land does not happen by accident. Developments must deliberately incorporate these values in their planning, construction and decommissioning phases. As long as lower construction and maintenance costs for SaskPower are the primary consideration in power line construction, poor decisions that do not include environmental and human costs will result.
No where in SaskPower's preferred route proposal is there any mention of the fact that over the past two years, the corporation has received a 'mountain' of correspondence from concerned citizens regarding this development, specifically with respect to routing the powerline through forest land. Submissions over the past two years, made by many citizens expressing concerns over powerline corridor construction through forest lands in this region apply completely to the Pink Alt 3 Route decision made by SaskPower in August 2001.