Water Stewardship Information Sources

Citation Hatfield Consultants. 2013. Review of habitat monitoring at twenty-two independent power projects. Prepared for Fisheries and Oceans Canda.
Organization DFO
URL http://www.dfo-mpo.gc.ca/Library/348172.pdf
Abstract/Description or Keywords Under the auspices of Fisheries and Oceans Canada, Hatfield Consultants Partnership
conducted a review of habitat monitoring performance at 22 Independent Power
Producer (IPP) projects across British Columbia and the Yukon. Overall industry
performance was evaluated based on compliance with monitoring requirements outlined
in the project specific Fisheries and Oceans Canada subsection 35(2) Fisheries Act
Authorizations. A further review of monitoring data analyzed alignment with long term
monitoring protocols presented in “Long-Term Aquatic Monitoring Protocols for New
and Upgraded Hydroelectric Projects” (Lewis et al. 2012). Because these long-term
monitoring protocols were developed subsequent to the construction and operation of the
IPPs assessed in the current study, the analysis was conducted to determine how much
industry effort would be needed to align with this new standard.
A full compliance audit of all IPP regulatory requirements was beyond the scope of this
study and would have been redundant with a recent audit by BC Ministry of Forests,
Lands and Natural Resources on ramping rates and documented fish kills (C. Menezes,
2012). Compliance with instream footprint requirements was also not part of the current
study but could be a corollary study based on information in submitted “As-Built”
drawings gathered through the current study. Similarly, matters regarding potential
violations under the Fisheries Act currently under investigation at several IPPs were not
included in this study as they will be addressed through other avenues.
The evaluation of the IPPs was based on a review of project monitoring reports provided
by Fisheries and Oceans Canada, the BC Ministry of Natural Resource Operations and
project proponents. The major limitation encountered during this review was a lack of
available information that could be used to document compliance/conformance.
Following the review of available monitoring reports, compliance ratings were assigned
to each Authorization condition and alignment ratings to each of the long-term
monitoring protocols. Results were summarized in three categories: (1) conformance
ratings for monitoring/reporting criteria specified in the Terms of Reference;
(2) compliance ratings for project specific Authorization conditions as they relate to
monitoring; and (3) alignment ratings for the industry as a whole as they relate to the
long-term monitoring protocols presented in Lewis et al. (2012). It should be noted that
although the long-term monitoring protocols presented in Lewis et al. (2012) are based on
existing published industry guidelines and methodologies, the final document was
published in July 2012, and all of the project monitoring plans were developed prior to its
release. Furthermore, the long-term monitoring protocols are not written requirements of
regulatory approval documents. The intent of this review is to better understand the level
of effort required by industry to achieve conformance to this new standard.
The level of compliance with DFO Authorizations and alignment with the long-term
monitoring protocols varied across projects and DFO Areas; however, for the projects
reviewed there was a common trend in compliance with project specific Authorizations
versus alignment with the long-term monitoring protocols. All projects typically complied
more to their respective Authorization than they aligned with the long-term monitoring
protocols prepared for the industry as a whole. Industry trends in compliance with Authorization conditions were less apparent because each Authorization is project
specific; however, some common Authorization conditions that consistently failed to
achieve full compliance included:
ƒ Frequency/timing of monitoring activities were not consistent with
Authorization conditions;
ƒ Submission deadlines were not achieved;
ƒ As-built drawings were not provided or missing information; and
ƒ Photographic assessments failed to fulfill requirements of the Authorization.
The following industry trends regarding alignment with the Lewis et al. (2012) long-term
monitoring protocols were noted:
ƒ The frequency and location of water quality monitoring generally was
inconsistent with the protocol;
ƒ A lack of ramping studies was apparent prior to commissioning;
ƒ Monitoring of instream flow requirements was consistently documented;
however, the frequency of monitoring was less than specified in the protocol;
ƒ The number and location of transects required to monitor stream channel
morphology was less than specified in the protocol;
ƒ A lack of footprint verification through the submission of as-built drawings;
ƒ Monitoring of fish habitat compensation was not provided; compensation
monitoring reports provided were typically missing comparisons to habitat
suitability indices;
ƒ Monitoring of species at risk was inadequate;
ƒ Detailed photo-documentation to compare critical habitat sites prior to, during
and post-construction were not provided; and
ƒ Projects with intakes at or in proximity to the outlet of a lake failed to follow lake
monitoring protocols.
A few similarities were observed between both the Authorization conditions and the
long-term monitoring protocols with respect to the inability to demonstrate full
conformance/alignment: frequency/timing of monitoring activities; submission of
as-built drawings for footprint verification; and detailed photo-documentation.
To address the major limitation encountered during the current review (i.e., lack of
available information), it is recommended that a web-based compliance monitoring
system be developed to track compliance with approval requirements. The tracking system should be developed by and maintained by the regulatory agencies, but should
provide limited access for proponents to upload compliance documents. A notification
system should also be incorporated to automatically notify the proponent and
appropriate agency when specified submission dates or project milestones are
forthcoming. This system would allow the appropriate regulator to easily confirm that
required monitoring documentation has been received and uploaded to a common
database. Non-compliance could be assessed more quickly, allowing for immediate
enforcement and/or mitigation measures. Common feedback received from proponents
was a frustration with the lack of non-compliance notification by regulators until the end
of the monitoring program rather than early on in the life of the project when corrective
measures are more easily implemented.
Based on feedback from DFO staff, it is recommended that the definition of operational
non-compliance be standardized within the industry and include the development of a
non-compliance reporting template for documenting the non-compliance.
Specific conditions of DFO Authorizations and BC MoE Water Licenses will always vary
between projects; however, an IPP generic set of Authorization Conditions related to
monitoring would provide continuity in standards across all projects with regards to
monitoring. Further, if these generic set of Authorization conditions aligned with the
Long-Term Monitoring Protocols (developed jointly by industry, provincial and federal
regulators) proponents would likely be able to develop one monitoring plan that satisfies
both levels of government. It is also recommended that the Long-Term Monitoring
Protocols be periodically updated by an expert review panel or technical working group
as the science of IPP monitoring evolves.
Information Type report
Regional Watershed Coast Region
Sub-watershed if known
Aquifer #
Project status complete
Contact Name
Contact Email