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).
1.0 Introduction
"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?]
6.6
"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.]
Conclusion:
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.