1) sr1 eis sect 2.2 vol 4 append b.doc a) information required … · 2020. 1. 14. · sr1...
TRANSCRIPT
Jennifer Howe
Project Manager, Prairie and Northern Region
Canada Environmental Assessment Agency / Government of Canada
RE: CEAA Project #80123 IR Submission May 2019
Greetings Jennifer;;;
I am submitting my official cursory CRITIQUE of the Alberta Transportation/ Stantec IR
submission to CEAA SR1 Project #80123. It is important for such submittal to intercede the
CEAA Review of the IR validation of complete specifications adherence to ATTACHMENT
(SR1 EIS Sect 2.2 Vol 4 Append B.doc).
1) SR1 EIS Sect 2.2 Vol 4 Append B.doc a) The EIS specifications are complete and thorough to identify the:
Information Required to Conform I. Update the EIS and EIS Summary, as applicable, to include an alternative
means assessment in accordance with the Agency’s Operational Policy statement entitled “Addressing “Purpose of” and “Alternative Means”;
II. An analysis of alternative means for the main Project components and for Project design components described above;
III. identification of the evaluation criteria for the alternative means analysis; and
IV. An assessment of the environmental effects (as per Section 5 CEAA 2012) for the alternative means considered.
b) Therefore the alternative means analysis does not comply. c) The Questions and Responses Provided did not identify the Issue of Concern
Question Response which was Submitted to the Communica and Stantec in responce to the CEAA Public Document stage,
2) JULY 2013 FLOOD - INITIAL CONCEPTUAL EVALUATION OF WATERSHED
MITIGATION.
a) At his invitation I submitted my Proposed Concept to Allan Markin, Chair of the Alberta Flood Mitigation Advisory Committee in July of 2013. There was one Committee volunteer Member from Stantec, . He included his staff to be budgeted as the sole Committee staff, under Russ Mackenzie P.Eng. Civil Engineering , Stantec Vice President Tino DiManno.
b) Nothing that I researched and recommended was acknowledged then as their option of examination. One of the staff saw what I was proposing and requested some of my drawings to present. Stantec decided to examine only one proposal to construct one huge rocky boulder dam upstream of the Elbow 300+/- ft high and 450+ ft downstream and 2miles+ wide. It was to hold back 100,000,000 m3 of flood water until the rain subsided and was to be released over time at
180m3/s into the Elbow embankment east of the Glenmore Reservoir to flow into the Bow at Inglewood.
c) I interviewed a member of the Alberta Parks staff while examining their mapping resources. Parks would not agree to a huge dam that was so far out of scale with the natural wilderness landscape. My alternate smaller dams across the Elbow drainage course was thought to be acceptable, should we have the opportunity to be directed by their Minister.
d) Therefore I and my consultant consortium were not engaged to provide a Feasibility examination. A FEASIBILITY ANALYSIS is required to examine and LIDAR Scan each of all MICRO Watersheds in order to be able to determine which ones can be reached along a dryed simmer river and creek bed in order to motorize the rock moving equipment to push the “glacio-fluvi”o into a 2 to 3 meter wet or dry dams. Only then could the volume of MICRO WATERSHED IMPOUNDING be estimated. Not as STANTEC and IBC has unprofessionally verbally described.
Respectfully Submitted;;;
Charles Hansen
SR1 CEAA/NRCB – EIS Section 2.2/ STANTEC EIA Volume 4 Appendix 4
CEAA EIS GUIDELINES: Volume 1, Section 3.0 of the EIS provides a description of the various Project components including the diversion system (floodplain berm, access road, auxiliary spillway, diversion structure, and diversion inlet), diversion channel, emergency spillway, off stream reservoir, off stream dam, and lower outlet works. The EIS includes information on the Project Alternatives considered and a detailed comparison of the Project with a location upstream on the Elbow River near McLean Creek. However, there is no description of the alternative means considered for the specific Project components and design components listed in Part 2 Section 2.2 of the EIS Guidelines, other than the design criteria outlined in Volume 1 Section 3.1 of the EIS. There is no description of the evaluation criteria considered (e.g., the approach used in identifying a preferred means), including the environmental effects used to evaluate the alternative means.
The EIS includes information on the Project Alternatives considered and a detailed comparison of the Project with a location upstream on the Elbow River near McLean Creek. However, there is no description of the alternative means considered for the specific Project components and design components listed in Part 2 Section 2.2 of the EIS Guidelines, other than the design criteria outlined in Volume 1 Section 3.1 of the EIS. There is no description of the evaluation criteria considered (e.g., the approach used in identifying a preferred means), including the environmental effects used to evaluate the alternative means.
Information Required to Conform
a) Update the EIS and EIS Summary, as applicable, to include an alternative means assessment in accordance with the Agency’s Operational Policy statement entitled “Addressing “Purpose of” and “Alternative Means”; i. An analysis of alternative means for the main Project components and for Project design components
described above;
ii. ii. Identification of the evaluation criteria for the alternative means analysis; and iii. iii. An assessment of the environmental effects (as per Section 5 CEAA 2012) for the alternative means
considered.
STANTEC EIA Volume 4
Questions and Comments Taken Into Consideration for the EIA or Project Design
(No Follow-up Requested) Issue or Concern Question Consideration or Result of Question
Appendix B Springbank Off-stream Reservoir Questions and Responses Summary
Summary of Questions and Responses Provided
Issue or Concern Question Response
Decision Making Process What other options has the The project team provided information, considered aside from SR1? in electronic format, information on the Government of Alberta's responsibilitie in regard
TRUE Copy – Response to CEAA Information Request August 31 2018 --- May 2019
ALBERTA TRANSPORTATION SPRINGBANK OFF-STREAM RESERVOIR PROJECT RESPONSE TO CEAA
INFORMATION REQUEST PACKAGE 3, AUGUST 31, 2018
Alternative Means May 2019 MICRO-WATERSHED IMPOUNDING CONCEPT Details on the Micro-Watershed Impounding scheme have not been provided to Alberta Transportation and the only available information that Alberta Transportation is aware of is on the TRJR website. Alberta Transportation does not know who its proponent is, nor does Alberta Transportation have any details to evaluate its merit, or feasibility. Alberta Transportation assumes that Micro-Watershed Impounding scheme refers to a series of low-head dams or weirs placed throughout Elbow River and its tributaries. This concept would require significant disruption to the Elbow River system as a whole with the installation of multiple low-head dams that would be required to meet the active flood storage capacity requirements for flood control on Elbow River. Micro-hydro and other low-head dams have been proven to be barriers to fish, and mitigations using fishways are often rarely successful at these facilities. This scheme is likely to render the river impassable at multiple points in the watershed. The Micro-Watershed Impounding scheme would also require road and utility access to each of the micro-impoundment facilities. There are currently very few roads (both inactive and active) within the Sheep, Elbow and Highwood River watersheds, and disturbance from this access would likely have a considerable effect on the watershed, the fish and wildlife, and the area’s stakeholders. CONCLUSIONS\ The TRJR, as it is proposed, cannot meet the Province’s flood mitigation objectives. The Micro-Watershed Impounding scheme is not feasible as a flood mitigation solution for Elbow River because of its environmental impact and inefficiency in achieving Alberta’s flood mitigation objectives. REFERENCES AEP (Alberta Environment and Parks). 2016a. Wildlife Sensitivity Maps. Available at: https://www.alberta.ca/wildlife-sensitivity-maps.aspx#toc-0 AEP. 2016b. Alberta Grizzly Bear (Ursus arctos) Recovery Plan (Draft). Alberta Environment and Parks, Alberta Species at Risk Recovery Plan No. 38. Edmonton Ab. 85 pp Hemmera Envirochem Inc. 2017. Elbow River at McLean Creek Dam (MC1) Environmental Impact Screening Report. Report prepared for Alberta Transportation by Hemmera Envirochem Inc, September 2017. Hemmera Envirochem Inc. 2019. Assessment of Potential Effects of the MC1 Option on Indigenous Health and Socio-Economic Conditions, Cultural Heritage and Current Use of Lands and Resources for Traditional Purposes, and Physical Heritage. Report prepared for Alberta Transportation by Hemmera Envirochem Inc, April 2019.
228 Stantec
CRITIQUE of the May 2019 Stantec ERRORS and OMMISSIONS- Charles Hansen - EKISTICAL URBAN ARCHITECT PLANNER
B ARCH – MAJOR THESES URBAN DESIGN INFRASTRUCTURAL PLANNING
HANSEN REGIONAL COMPREHENSIVE PLANNING CONSULTING
STRATEGIC EKISTICAL CONCEPT LAND USAGE--------------------DYMAXION DEVELOPABILITY URBAN DESIGN
ALBERTA TRANSPORTATION SPRINGBANK OFF-STREAM RESERVOIR PROJECT RESPONSE TO CEAA INFORMATION
REQUEST PACKAGE 3, AUGUST 31, 2018
Alternative Means May 2019
MICRO-WATERSHED IMPOUNDING CONCEPT ::::: MWIC
Details on the Micro-Watershed Impounding scheme have not been provided to Alberta Transportation and the only
available information that Alberta Transportation is aware of is on the TRJR website. Alberta Transportation does not
know who its proponent is, nor does Alberta Transportation have any details to evaluate its merit, or feasibility.
The Proponent is well documented with CEAA and Stantec VP Russ Mackenzie P.Eng who called to discuss a
shorthanded verbal questioning, not a engaged Feasibility Analysis.
Alberta Transportation assumes that Micro-Watershed Impounding scheme refers to a series of low-head dams or
weirs placed throughout Elbow River and its tributaries. This concept would require significant disruption to the
Elbow River system as a whole with the installation of multiple low-head dams that would be required to meet the
active “flood storage capacity” requirements for flood control on Elbow River. Micro-hydro and other low-head dams
have been proven to be barriers to fish, and mitigations using fishways are often rarely successful at these facilities.
“This scheme is likely to render” the river impassable at multiple points in the watershed. The Micro-Watershed
Impounding scheme would also require road and utility access to each of the micro-impoundment facilities. There
are currently very few roads (both inactive and active) within the Sheep, Elbow and Highwood River watersheds, and
disturbance from this access would likely have a considerable effect on the watershed, the fish and wildlife, and the
area’s stakeholders. CEAA has submitted over 50 Emails and ATTACHMENTS in their Public Documents to Alberta
Transportation to validate their IR’s. “likely to render” is not a scientific, P.Eng responsible Feasibility Analysis. MWIS
requires no new roads. Existing roads allow equipment access to pushing riverbed aggregate to stack 2&3m dams. No
“utility access” is needed. “flood storage capacity” was estimated on NUMEROUS SUBMISSIONS to accommodate the
100Km3 2013 flood surge vector forces, which was the major engineering purpose to retain small MICRO DAMS.
CONCLUSIONS
The TRJR, as it is proposed, cannot meet the Province’s flood mitigation objectives. The Micro-Watershed
Impounding scheme is not feasible as a flood mitigation solution for Elbow River because of its environmental impact
and inefficiency in achieving Alberta’s flood mitigation objectives. A Feasability Analysis was proposed to Premier
Prentice.
REFERENCES ::::: All REFERENCES do not relate or impact a Feasiblity examination of MWIC
AEP (Alberta Environment and Parks). 2016a. Wildlife Sensitivity Maps. Available at: https://www.alberta.ca/wildlife-sensitivity-maps.aspx#toc-
AEP. 2016b. Alberta Grizzly Bear (Ursus arctos) Recovery Plan (Draft). Alberta Environment and Parks, Alberta Species at Risk Recovery Plan No. 38. Edmonton Ab. 85 pp
Hemmera Envirochem Inc. 2017. Elbow River at McLean Creek Dam (MC1) Environmental Impact Screening Report. Report prepared for Alberta Transportation by Hemmera
Envirochem Inc, September 2017.
Hemmera Envirochem Inc. 2019. Assessment of Potential Effects of the MC1 Option on Indigenous Health and Socio-Economic Conditions, Cultural Heritage and Current Use of Lands
and Resources for Traditional Purposes, and Physical Heritage. Report prepared for Alberta Transportation by Hemmera Envirochem Inc, April 2019.
228 Stantec
<Personal information removed>
Subject: FW: AMEC SELECTION as Flood Control Project Evaluation and Engineering Consultant.RE:Phone Calls of 21NOVEMBER2013.
GREETINGS Monica and Blair;;;;;;;;;
After our happenstance passing-by greeting at the exit door in the Glenmore
Inn October 4th 2013 Public PANEL/Corbould presentation, you said you would
contact me later after your assignment scope was contracted.
After many calls and E:mails you told me that you did not need any sub-
consulting inclusion within your Elbow Watershed
Charles Hansen
HANSEN REGIONAL COMPREHENSIVE PLANNING CONSULTING STRATEGIC CONCEPTUAL LAND USAGE -- COMPREHENSIVE DEVELOPABILITY PLANNING
From: Charles Hansen
Sent: November 15, 2013 1:00 PM To: '[email protected]'
Cc: '[email protected]' Subject: AMEC SELECTION as Flood Control Project Evaluation and Engineering Consultant.
Greetings, Monica;;;
<Personal information removed>
<Personal information removed>
As time progresses, may I respectfully pose the question about which I have
been calling. I am willing to either share my research upon alternate solutions to
STANTEC’s final report for the PANEL as a sub-consultant to amec or work thru
Chief ADM Andre Corbould, independently.
In my communications with STANTEC’s Russ MacKenzie on his PANEL interpretive
Final solution of their headwaters and upstream storage plan, I have discussed
alternatives, based upon research of the insitu geophysical, hydrogeological ,
geological and regulatory conditions. His conclusive recommendation is as
follows :
My consulting team resourcefulness could best be applied collaboratively
as sub-consultants to amec.
amec now has a critique opportunity to independently examine the
PANEL/STANTEC solutions to the GoA.
amec may investigate all salient factors that they identify to recommend
another planned solution.
CADM Corbould may otherwise recommend any other solution to Minister
Doug Griffith (GoA), to provide the best construction process.
May I suggest that various Regulatory processes will have a dominating
influence and affect upon any Solution.
I am sure you are well advanced upon your critique analysis. You may not
wish to engage my supplementary Team.
This is my Respectful offering to you, as an adjunct to my earlier Proposal. This is
positioning is what I have been calling for.
Best Regards and good luck with your very important role in providing Upstream
Watershed FLOOD CONTROL Storage.
Charles Hansen
HANSEN REGIONAL COMPREHENSIVE PLANNING CONSULTING STRATEGIC CONCEPTUAL LAND USAGE -- COMPREHENSIVE DEVELOPABILITY PLANNING
<Personal information removed> <Personal information removed>
From: Scandinadian
Sent: June-14-18 5:16 PM
To: '[email protected]'
Subject: FW: Springbank Off-stream ReservoirProject #80123 EIA-CEAA EIS
Open House Invitational Response - #1 of a series of a
Singular/Evidential Submissions
Attachments: v6.Community-Flood-Mitigation-PDF-Publication-copy.pdf; Critical
Path Method NODAL SCOPING.doc; SCAN0008.JPG; RESPONSE
#4 SUGESSTED STABLE OF CONSULTANT CONSORTIUM
COLLABORATORS.doc; HANSEN Critique WaterSMART.doc;
SCAN0007.JPG
Jennifer;;;;;;;;;;; This is My formal #1 Submittal. It will be followed by at least a #2 Submittal
dealing with the STANTAC-COMMUNICA-PUBLIC ENGAGEMENT NEARLY 600 PAGES
of reproductive meaningless documentation and graphic charting .
From: Scandinadian Sent: June-13-18 2:51 PM
To: '[email protected]'
Subject: Springbank Off-stream ReservoirProject #80123 EIA-CEAA EIS Open House Invitational Response - #1 of a series of a Singular/Evidential Submissions
Springbank Off-Stream Reservoir Project Canadian Environmental Assessment Agency Canada Place, 9700 Jasper Avenue, Suite 1145 Edmonton, Alberta T5J 4C3
Ms Jennifer Howe
Project Manager, Prairie and Northern Region
Canada Environmental Assessment Agency / Government of Canada
<Personal information removed>
<Personal information removed>
Greetings;;;
RE: 1ST SUBMISSION of a SERIES to a SINGULAR RESPONSE CRITIQUE of #80123 EIS
PREAMBLE :
This is geographical landscape evaluation of a Proposed Sequence of Upstream Impounding Dam construction events. Its purpose is to
scientifically examine all GIS conditions which were not done by the “v6- ATTACHMENT” above.
Page 2 :did not “Examine innovative solutions aimed at preventing future flood damage
on a community wide basis” .
Page 7 : did not “..To hear from Albertans, and find Alberta Solutions to what is now recognized
as...”
Page 15 : did not “empty to lowest workable level”. It only emptied 10 feet/3m, within
the61foot Dam depth.
Page 30: EC1 (Canyon Creek) and EQ1 (Quirk Creek) were the only options
envisioned within the 17 MICRO Watershed swails such as SCAN0008 and of
the 20km+/- of Canyon Creek wich shows numerous options to locate MICRO dams between the steep mountain slopes.
Page 31: Lidar contours show sequential crossing locations where 3m
MICRO Dams could be located instead of the One massive shape proposed on Page 45.
Page 56: In Closing This crucial part of the Alberta Flood Mitigation System is achievable and
necessary within an expedited timeline.
The time line was without immediate contact with DOE CEAA as originally specified in 2013. Therefore the subsequent SR1 IDC and design
development Civil Engineering by STANTEC continued at their own EIA format without the benefit of the CEAA EIS GUIDELES, which are now
underway in 2018 and to be followed by the Alberta NRCB application and public hearings. Depending upon the Alberta Environment and Parks Water
License Application and Approval, the affected private property owners can Appeal theLicense
to the Alberta Environmental Appeal Board. The last Elbow River diversion
Application Approval Appeal, #00388473-00-00, has been taking One year to process.
The Conceptual Design Master Plan origin is naturally contained within the
Micro watersheds at the tops of the Kananaskis Mountain Range of Alpine
and Forested land as it drains into the Highwood, Sheep and Elbow River Basins. All 3 Basins originate from the same 10,000 Ft high mountain ridge within a <1KM radius.
MICRO µ WATERSHED IMPOUNDING CONCEPT
CRITICAL PATH METHOD NODAL SCOPING & CRITERIA
BOW-ELBOW-HIGHWOOD-SHEEP-RED DEER
MICRO µ WATERSHED UPSTREAM DRAINAGE COURSE STORAGE BERM/DAMS
October 2013
NODAL CRITERIA:
All downstream Flooding can be restrained by storing water coursing flow of upstream impounding within;
1) Dry Dams to be time released and
2) Wet Dams shall be retained for drought and Irrigation.
3) Flood Flow Vector Force Summation Σ of F = ma, will be
4) Dynamic load mass of river bed hydrologic erosion.
River Bed Impounding Dams can retain water volumes in accordance with Up-Stream flood mapped Geographical and Hygrogeological
evaluation of Geospatial GIS experience. Insitu glaciofluvial Boulder/Rubble/Rock Berm/Dam construction is
economical with no offsite material delivery. Wet Dams shall contain Bauer Foundation type soil-cement cast in
place compression walls within the Berm core. SCADA WiFi controlled release steel gates will be installed to time
release temporarily Impounded Flood Flow. Fish spawning migration ladders will integrate all construction.
Alpine and Sub-Alpine various release of SNOW weight loading will be estimated to initiate vector force loading of the mass of the Flood
Flow. The mass load of precipitation times the gravitational vertical force of
gravity will determine the volume Σ of Flood Flow to be retained
hydrologically within each of the 40 to 80 1km spaced Berm/Dams across the Elbow River, Canyon Creek & Little Elbow River stream bed.
________________________________
______________________________________
CONCEPTUAL ELBOW RIVER FLOOD MANAGEMENT CPM WORK
SCOPE.
August 2013 meet / amec RFP JV
It will manage future flood control and treat the Little Elbow River, Elbow River
and Canyon Creek as a self contained SCADA controlled water VESSEL .
Three prime design factors will establish a Feasibility Planning Program
Scope of Work to examine 3 geo-spacial categories of VESSEL containers
e.g.:
1. The Elbow River below the Glenmore Dam is VESSEL #1
2. The Glenmore Reservoir, VESSEL #2 and its impounded Weaselhead
VESSEL #3 wetlands/flood flow will be formulated into the Master
Plan as a safety valve.
3. All newly planned upstream impounded temporary storm water
storage VESSELS # 4,5,6,7,8,9, ETC will be released as directed by the
Calgary normal river embankment flow directed by Calgary Water
Resource Flow business unit dep’t.
The 3 VESSEL categories, when added to the17 MICRO Watersheds and
about 40 to 80 in stream Micro wet and dry insitu dams, as determined by
Hydro geological and civil engineering retention and detention vector
force design.
The Elbow will occupy any storm surge within its normal river level vessel
embankments.
The Reservoir dredged will provide A 22 Mm³ storage vessel to control flow
and maintain the Elbow consistently within its natural banks.
The Reservoir will SCADA-Remotely control each upstream MICRO
impounding structure vessel into the snow packed headwater mountains
MICRO watershed .
Therefore dredging and impounding for additional flood retention storage within
the Elbow mountain headwaters is the most logical solution to eliminate Calgary
Flooding economically and without engaging any Private Property (such as SR1)
as follows :
This Concept needs to be addressed as an immediate scope of work
engagement to isolate the Feasibility of structural storm water storage
options.
The Province is the only jurisdiction to engage their provincial water-for-life
ownership and Crown Land resource availability.
In the final consideration, it makes no difference how often the flooding
occurs whether cyclical or not. The Maximum Probable volumetric storm
stream flow will prevail as the primary design engineering factor.
Maximum Probable Meteorological Weather Hydrologic cell motions and
Radar volumetric interpretation will be a key work item to determine a
Maximum Probable Order-of-Magnitude of precipitation, snow pack and
solar cell conjugation.
US ARMY CORPS of ENGINEERS format for estimating a Hydrologic
Probable Maximum Storm Storage and Kinetic Wave Routing will be the
engineering quantification to the MICRO Watershed analysis and
providing stream flow engineering load for environmental impact
assessment.
______________________________________________
______________________________________________
______________________________________________
__________
2013 FLOOD CONTROL Regional Master Planl Environmental Design
Mitigation
August 2013 meet / amec RFP
JV
There are 6 Geo-physical conditions of watershed factors to be
examined;
1. The annual volumetric mountain snow-cover density melting rate to
estimate MICRO Dam locational riverbed vector forces.
2. The Probable Maximum low pressure ATMOSPHERIC RIVER precipitation
system which moves up the Eastern Rockies from the Gulf of Mexico
SUBTROPICAL STORM PATH to join within a jet stream convergence with a
Northern high pressure arctic cold system.
3. Vector forces are generated from the snowpack stone faced Kananaskis
Ridges which travel down all storm water drainage courses to accelerate
the stream flow surge power of all creeks and connectors into a flooding
River gravitational flow.
4. All possible locations of potential earthen/glacio fluvial/granular/boulder
constructed impounding Dams to store intercepted surge vector forces
will be evaluated.
5. A potential conjugation of all meteorological and geo-physical elements
of stream-flow surge conditions above will be annotated for their size of
influence upon maximal River basin flood water surge and volume affect.
6. Any alteration within any watershed area will be subject to regulatory
measures of the DFO, DOE and Alberta Parks and Sustainable Resources.
Each functional influence factor of Flooding contribution to a will be isolated and
envisioned for potential alterations to Urban FHA Flooding solutions.
1. Annual snow fall sequences & melt rate will be estimated with 3
evaluations;
Consult Parks Canada Avalanche Team Probable Maximum advise.
Consult Sunshine Village Ski Patrol Captains measured experience.
Consult Alberta Parks field monitoring staff experience & advice.
2. Probable Maximum Meteorological Precipitation evaluation
Probable Maximum US Meteorological Radar tracing of Gulf of
Mexico SUBTROPICAL STORM PATH systems.
Consult US ARMY CORPS of Engineers Maximum Probable safety “N”
factor application.
3. Vector Force estimation “F = Mass/weight X Acceleration of gravity”:
From #1 above determine the Probable Maximum weight of snow
load.
From #2 above determine the Probable Maximum weight of
rainwater.
Measure the F1 on the hypotenuse face of the mountain range to
determine the actual loading of the dynamic load factor to a ∑ surge
F2.
The mapped Alpine snow capped mountains cover about 4oo
Acres. By adding the hypotenuse surface of snow pack the vertical
area of weight F1.
Respectfully Submitted;
Charles Hansen
Dymaxion Ekisitcal Architect Planner
HANSEN REGIONAL COMPREHENSIVE PLANNING CONSULTING
STRATEGIC CONCEPTUAL LAND USAGE ------------------------------------- COMPREHENSIVE DEVELOPABILITY PLANNING
<Personal information removed>