July 17, 2009
Submitted by electronic mail
Graeme McLaren, Projects Assessment Director
Environmental Assessment Office
PO Box 9426, Stn Prov Govt.
Victoria, B.C. V8W 9V1
Re Proposed Garibaldi at Squamish Project (2006)
Dear Sir
The following is the submission of the Steelhead Society of British Columbia regarding this matter.
We urge the Environmental Assessment Office to not issue a certificate to the project proponent because the project, as currently described, will almost certainly have significant and permanent impacts on steelhead habitat in Brohm Creek.
Brohm Creek is a uniquely productive steelhead stream because of unusually high levels of naturally occurring phosphorous, and is therefore capable of producing 3 to 5 times as many steelhead as other streams of similar size. It is the major steelhead spawning tributary of the Cheakamus River, which in turn is the most important spawning tributary of the Squamish River.
The uniquely productive water chemistry in Brohm Creek also makes the stream exceptionally fragile and susceptible to pollution impacts.
The Garibaldi Project threatens Brohm in at least three ways:
o Removal of water resulting in lower stream flows and changes to Brohm’s hydrograph;
o Changes in water chemistry; and
o Physical changes to aquatic and riparian fish habitat.
Development in headwater areas has the highest opportunity to influence the overall aquatic ecosystem supported by the drainage. Headwater habitat largely defines the water quality and chemical composition of the stream water. Headwater health also plays an important role in food and nutrient contribution and debris flow. Whatever changes occur in the headwater areas can be expected to affect the entire watercourse downstream and all its inhabitants. There are too many examples involving poor forest practices that make this point very clear considering the damage done to many small streams over a very short period of time as a result of logging in headwater areas.
This proposed development is positioned over the entire headwaters of Brohm Creek. There will be road, trails, golf course fairways, ski hill runs all crossing Brohm Creek over and over again. Essentially, the headwaters of this creek will become semi-urbanized overnight. While the project EA states that the development will only result in approximately 6% impervious surface, there are still likely to be impacts such as:
* Altered hydrograph due to stormwater contributions;
* Elevated nutrient levels and changes to water chemistry as a result of golf course fertilizer and runoff water;
* Elevated temperatures as a result of insolation occurring in exposed channels and pond discharge and runoff from water surface (i.e., roads)
* Elevated sediment loads as a result of development and operation. A casual attitude to erosion and sediment control during the development phase alone could render Brohm Creek sterile for many years, if not permanently. We did not see this issue addressed anywhere. High sediment loads over a prolonged period of time are insidious. Even with the best ESC management, there will still be sedimentation impacts and considering the massive scope of the proposed development, likely a lot of sedimentation will occur.
Brohm Creek is too small, too sensitive and much too valuable to use as a domestic water supply for this project. The Steelhead Society has concerns that the methodology used by the proponent to determine water supply was inappropriate in this case. We assert that the outstanding issues regarding surface water withdrawal should not be deferred to a post- Environmental Assessment Certificate stage as these issues are difficult and potentially without remedy. In addition, the domestic water requirements of the development may be significantly underestimated.
It has been noted that there is only one Brohm Creek and that there is a conservation concern for steelhead in this watershed and elsewhere in southern BC. On the other hand there is no shortage of golf courses or ski hills in the Squamish area. Why would we take the chance that this development could irreparably damage the function of this extremely important stream?
Discharge of treated sewage into the Cheakamus River is proposed. Accidents happen. All we need is another spill in the Cheakamus. The EA document did not address the potential for accidental releases of deleterious substances.
We recommend that the proponent modify the development proposal as follows:
1. Find an alternative source of water so no water is directly or indirectly removed from Brohm Creek;
2. Reduce the amount of impervious surface in the headwater development, and take additional steps to minimize headwater development impacts on Brohm’s hydrograph and water chemistry; and
3. Delete the proposed golf course development from the lower Brohm valley.
We further recommend designation of the lower Brohm watershed downstream of Brohm Lake as a park or other protected area in order to preserve these unique steelhead values in perpetuity.
Please publish this submission on your website.
All of which is respectfully submitted,
Poul Bech, Ralf Kroning and Trevor Welton
Directors,
Steelhead Society of BC