Information selected from the

SaskPower Project Proposal, Appendix A. ERIN Consulting Final Report, 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 second document represents only a preliminary analysis of SaskPower's submission. 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 from Appendix A. of the SaskPower Submission to SERM. In square brackets and italics are comments by Forest Fringe Citizens Coalition (FFCC).

( 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.)

1. Executive Summary

"Development in the riparian and continuous forested lands should be mitigated, as these biologically diverse habitats are sensitive and can be adversely affected by powerlines. Powerline construction on riparian areas can cause erosion and sedimentation problems, destroy breeding areas, and adversely affect habitat that is crucial for many wildlife species. Powerlines in forest disrupt the ecological integrity of this habitat; many wildlife species such as bears, other mammals, and many birds require large areas of continuous forest. Furthermore, powerline corridors facilitate the introduction into the forest of exotic and invasive weeds that can negatively affect native plants. In addition, insect pest outbreaks such as the spruce bud worm and tent caterpillars are increased in forest that have large areas of forest edge.

"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. Other habitats that are common and located throughout the study area include small forest fragments, tree shelter belts, and shrub hedges. These habitats are used by some birds and mammals to breed, forage, and avoid predators. Most of these species are common in the study area, but a few uncommon and species at risk such as the loggerhead shrike also use these shrubby habitats. Powerline construction will remove forest fragments along the corridor, but wildlife will readily use similar habitat that is abundant in other locations. Thus, development will not significantly affect the ecology of agricultural or small forest fragments, tree or hedge row habitats." [This selection opens the ERIN report to SaskPower. It

was also first shown to representatives of "Stakeholder Groups" in April 2001 at the same meeting where SaskPower planners revealed their plans to run two of three route options directly through continuous forest in the Christopher Lake region. It was as if the planners had not even seen the ERIN report commissioned by SaskPower itself.]

5.1 Vegetation Communities

5.1.3 Rare Plants

"A search of the database of the Saskatchewan Conservation Data Centre indicated that three quartersections contain a rare species and 48 quartersections have had a rare species observed in the area (see Map 2 in Appendix 7). In 1999 Golder Associates found two rare plant populations. ERIN found an additional ten rare populations, all of which are located in the forest within the Boreal Upland area."

5.3.1 "The collected baseline information also supports the fact that owls occur in the continuous forest areas in the study areas, especially in the Boreal Upland area..... Thus the continuous forest provides an important habitat for owls."

5.3.2 Breeding Birds

"Each survey route samples different areas and habitat areas in the study area (see Map 1 in Appendix 7). The third route started just north of the study area to obtain a sufficient sample of continuous forest in the Boreal Upland area." [Most of this route is along Highway 2, a very busy and noisy transportation corridor at all times of the year, and especially during the time of the survey. Since the survey was a roadway auditory survey, it is questionable how many sound indicators of birds were missed because of this highway noise.]

"The continuous forest in the Boreal Upland had numerous songbirds that are forest specialists that require large areas of continuous forest."

5.3.3 "Only five small mammals were caught in traps.. . In addition small mammals tend to huddle and move little in cool temperatures to conserve heat. Thus small mammals were less likely to move and be trapped in the cool weather experienced in the early summer." [The summer of 2000 was particularly cool and wet. During the time of these live-animal trapping efforts on SE 16 53, 26 W of 2, one study session was cut short because of hypothermia risk to the researcher. At this time of season there was also an abundance of natural foods that may have been much more attractive to the mammals being sampled than was the bait foods being used.]

"A deer or elk overwintering site was found in the Boreal Upland area as well. Indeed, seven to eight elk are known to overwinter in this area. (Olson, pers. Comm.) In addition, two of the eight radio collared elk, which were released for the Montreal Lake Elk Reestablishment Project, have relocated to the Boreal Upland forest in the study area (Messier and Kowal 1999)" [This 'overwintering site' was in SE 16, 53, 26, W of 2^nd, a quarter section which Pink Alt 3 crosses.]

"Cougars have been historically spotted in the study area... This large mammal has been ranked as S2S3 rarity. Nevertheless, cougars are unlikely to be currently found in the study area, as this species is sensitive to human disturbances." [Cougars have been regular in this area. of continuous forest, and have been seen by the residents of this forest area. A recent sighting was made by Henderson in the winter of 2001.]

6.0 HABITAT SENSITIVITY RANKING

6.1 Table 10. [Directly quoted from the ERIN Report]

[It must be noted that SaskPower's selected route throughout its entire northern portion goes through areas with an average sensitivity rank of 14. While the Mitigation advice was to avoid these areas, SaskPower has targeted these areas exclusively. The other forest route that SaskPower had considered, the Blue route, has an average sensitivity rank of 13 throughout its northern portion. SaskPower's Yellow route, in the northern area, even when the portion through the NPF for the final distance to the connect point is included, had an average sensitivity rank of 6, the same as the Yellow Route modifications suggested by the FFCC. Even the Mitigation advice given for areas ranked from 4 to 7, of selecting routes along fragment edges, was ignored in the design of the Yellow option. Instead of adjusting the pole positions to route along fragment edges and move over into hay lands or open fields a short distance, SaskPower's designers rigidly followed straight line corridors that destroyed large sections of sensitive forest blocks adjacent to low sensitivity lands. Farmers affected in this fashion have frequently said, "If SaskPower has to come through here, move it into my hayfield and leave my forest alone. I can work around the poles and I don't want my forest destroyed." This too is advice which was ignored by the SaskPower planners. Mitigation suggestions which suggest that impact be minimized by strategically placing poles makes sense if the area is open or fragmented habitats However, in continuous forest it is meaningless because the entire area of the powerline corridor will be totally destroyed and altered forever. The only way to reduce damage is to avoid the forested lands completely by routing through already cleared lands.]

6.1.1 "Agricultural lands and other clearings such as clear-cut in forest and roadsides are not environmentally sensitive to powerlines. They have already been cleared of native plants and are mostly planted with monocultures. Exotic weeds have already invaded cleared areas as well. The ecology of these habitats would not be significantly altered by construction of a powerline. Wildlife would use the agriculture and clearings habitat under powerlines in the same way as other similar habitats."

6.1.2 "In general, wetlands are sensitive to disturbance....some wetlands are susceptible to additional problems, such as erosion and sedimentation that can be caused by powerline construction."

"Some wetlands are, however, small enough that they can be spanned by power poles that are spaced 300 m apart... Thus wetlands and their vegetation buffers that can be spanned by poles are given a low sensitivity tanking of 3." [This consideration applies to wetlands in open areas or areas of tree fragments, but not to areas of continuous forest where the entire area under the 70 - 80 m wide corridor will be stripped of all trees and treated with herbicides to keep it that way. No where in ERIN's analysis of impact on wetlands is there mention of the impact of herbicide use and herbicide leeching into wetlands or water bodies. This is one of the very major concerns of people in the forest area because they rely on ground water for domestic use, and also contamination of surface bodies of water will kill the delicate balance that exists in these spring-fed ponds and marshes. While this is a serious concern for the pond located in Friendly Forest, it especially applies to Christopher Lake because Pink Alt 3 for its entire length west of Highway 2 in the forest region goes through a narrow watershed above Christopher Lake. At some points the water of Christopher Lake itself is only 3/4 mile from the back of the private properties along Highway 2, and SaskPower's corridor will be within this narrow stip of forest watershed.]

6.1.3 Ranking of forest habitats

"A powerline development will affect forested habitats differently than other habitats as the forest under a powerline will be permanently altered and removed from the landscape. An artificial clearing is created and permanently maintained, as forests would naturally regenerate. In contrast, natural vegetation can regenerate under powerlines in wetland or other habitats."

"... Indeed, humans have not been able to reproduce the same type of diverse mature forests by replanting that is created by natural regeneration."

"Continuous forests are considered higher quality and more sensitive habitat than fragmented habitats where the forest is restricted to distinct and isolated patches. Fragmented habitats are susceptible to the invasion of exotic weeds. Indeed, a powerline can introduce numerous weeds that can easily grow along the open3d corridor. Furthermore, destructive insect pests such as the spruce budworm and tent caterpillar benefit from habitat fragmentation, as increased tree growth found along opened forest edges provides top quality food.... Forest fragment subtypes are already disturbed, as they are negatively affected by habitat fragmentation and edge effects. Consequently, these subtypes would be less adversely affected by a powerline further fragmenting the forest than compared to continuous forest types."

"The continuous forests are given high ranking because these high quality habitats are particularly sensitive to powerline development."

"The continuous forests are high quality habitats that are sensitive to powerline development. The Boreal Upland occupies a larger area than the Nesbitt forest, therefore, it is classed as 'development can proceed with mitigation". Nevertheless, the Boreal Upland is a unique habitat subtype; very few large continuous forested areas are left intact along the boreal forest and boreal transition ecoregion borders. This border has an exceptionally rich biological value because elements of both ecoregions increase the diversity found in the area." [It is important to note that the ERIN conclusion to not identify the Boreal Upland as a completely "no development" zone was based on its relatively larger area only, and not on a lesser biological sensitivity. The draft copy of the Transmission Line Routing Review Panel specifically referred to Transitional Boreal Forest areas, especially those privately owned, as unique regions that should be so designated in SERM guidelines. This is another recognition that this type of habitat is very scarce in Saskatchewan, largely due to extreme pressures on these areas by agricultural development and also commercial timber exploitation. The best defenders of the integrity of this special habitat appears to be the human forest resident who chooses to live in the forest because of the values it represents to people. This is consistent with the idea that one defends what one values, and values what one knows. Yet, SaskPower has selected Pink Alt 3 as its preferred route, a route that destroys significantly more of this "unique habitat" than any other route option, and much more than its lowest impact alternative, the Yellow route or the Yellow Route with the modifications suggested by the FFCC.]

"The powerline corridor must, however, traverse the Boreal Upland area because of the northern tap off point. Thus ERIN recommends that a powerline be routed through the lesser quality and lesser environmentally sensitive forest subtypes in the Boreal Upland area to minimize disrupting the ecological integrity of this area." [Access to this tap off point is possible from the east rather than from the west and south as is the case with Pink Alt 3. Access from the east is able to cross mainly open agricultural lands with few or distant habitable dwellings, is able to cross large sections of open community pasture, and crosses the shortest possible length of continuous forest. While SaskPower has incorrectly claimed that Pink Alt 3 is an acceptable alternative because it coincides with Weyerhaeuser cutting plans, the area that approaches the tap off point from the east IS part of Weyerhaeuser's tree harvest plans being submitted in the fall of 2001. This has been confirmed by Weyerhaeuser harvest planners as recently as September 26, 2001.]

8.4 Appendix 4. Reports of rare plants

"Rare plant occurrence report 1. And Report 3 " [Both are found on Gerald Regnitter's land. SaskPower's Bernie Bolen told Lakeland RM # 521 Council that no rare plants were found along the route selected by SaskPower. ERIN reports such as these , and also locations found in the summer 2001 along the corridor west of highway 2, indicate otherwise. Although the quadrant study was not conducted where the powerline corridor is planned on Pink Alt 3, the two plants are also found precisely where SaskPower plans to destroy the total forest habitat in which they exist and permanently destroy it and allow the invasion of other exotic weeds well beyond the actual corridor. SaskPower's claims does not stand up to their own reported data.]

8.7 Appendix 7. Maps Map 2 Sensitivity Areas

"ERIN Consulting recommends that the ideal mitigation measure is to avoid routing a powerline through known sensitive areas."

"....In these cases, ERIN Consulting Ltd. recommends that poles are not built directly on the sensitive area and construction should minimize impacts. For example, a forest has to be cleared by hand around rare plant species to minimize disturbing these plants." [This example is very strange. In forest areas the entire area of the corridor will be totally destroyed and changed forever. How will hand cutting trees around rare plants protect them if all living things in the entire area are going to be killed?]

Concluding comments: These quotes from the full ERIN Report contained in Appendix A of the SaskPower submission to SERM indicate repeatedly that the Pink Alt 3 route through continuous Boreal Upland forest does the most damage to the environment of all the areas considered for this powerline in the northern portion of the Study Area. It is impossible to accept a conclusion that SaskPower has selected an environmentally responsible route option. Rather, the only valid conclusion seems to be that narrow engineering and construction factors seeking high ground near the highway were the only real factors that support the Pink Alt 3 route in this area. Even cost arguments pale when considered by the facts: The total cost increase for routing by way of the lowest environmental impact, highest cost alternative, according to SaskPower figures, would be 1.2 million dollars. SaskPower submission to SERM shows that SaskPower stands to save 1.5 million per year of operating the line at 138 kV instead of the current 72kV. Thus, if SaskPower had been prepared to route the corridor through the areas of lesser environmental impact two years ago when this project was first made public, the entire cost of all routing along a longer, but environmentally more responsible corridor, would already have been saved!

SaskPower must not receive approval for Pink Alt 3.