M/s Golder Associates Ltd of Canada were entrusted to conduct Environment Audit and prepare a report with recommendations on Transmission Reinforcement Project in Vancouver Island. The excerpts of the report are as follow.

Construction Activities

These were:

a) Clearing and brushing along ROW on Vancouver Island from Vancouver Island Terminal (VIT) to Sansum Narrows, and along the western portion of Salt Spring Island from Sansum Narrows to the Salt Spring Island Substation (Area A) was completed by Khowutzun Forest Services.

b) Access trail construction activities from VIT to the Salt Spring Island Substation would be completed by Gregson (Copan) after this clearing.
(Ref Table 1. for status)

Priority Issues

Environmental Management Plan, Monitoring and Reporting Commitments

Prior to commencing construction activities, the Environmental Management Plan (EMP) was provided to the overhead line contractor (Allteck) and their environmental consultant, White Pine Environmental Resources Inc. (White Pine).

The preliminary draft EPP, as submitted, was reported as having deficiencies like:

a) The Environmental Management Plan (EMP) requires that the contractor prepare several activity and site-specific Environmental Protection Plans.

b) Draft EPP (Environmental protection, mitigation and restoration) provides generic reference that measures will be implemented to meet these various requirements. However, it does not provide specific details to describe how these mitigation procedures will be implemented.

These are observed in various processes like sedimentation and erosion control fuel storage and oil management waste control and CO2 bubbler for cementatious materials equipment.

Allteck has not addressed these deficiencies, nor submitted the above-referenced activity specific EPPs. White Pine has advised that Allteck’s EPPs will be submitted by May 22nd, 2007. It is imperative that these EPPs are established, as this deficiency affects project compliance (i.e. risks of potential liability, conditions of the Environmental Assessment Certificate, and compliance with the EMP and commitments).

Land-Use Planning Commitments

BCTC will provide contractors personnel working within environmentally sensitive areas (ESAs) and Development Permit Areas (DPAs) with environmental awareness training.

To date, copies of the Contractor Environmental Pre-Work Orientation Records have not been provided to BCTC or Golder for review.

Engineering Design and Quality Control/ Quality Assurance Commitments

BCTC requires personnel to have electrical hazard training to reduce the risk of potential accidents.

This is outstanding for a number of individual, including Environmental Monitors.

Construction Waste: (i) Contractors are to maintain a waste management log detailing disposal of waste materials. To date, Allteck has not provided a Waste Storage, Handing and Management Plan, as one of the required EPPs.

ii) Measures to be taken during drilling in the Potential Acid Rock area and disposal of drilling dust.

Allteck has not supplied copies of its emergency response and Spill Prevention Plan, including details of their spill containment protocols.

Environmental Management and Mitigation Measures Implemented

Terrestrial Wildlife and Vegetation Management Commitments

BCTC has committed to minimizing the clearing of natural habitats and removal of structures during the passerine bird nesting and breeding period, which is typically from March 15 to August 15 in the lower mainland and Gulf Islands. Where work is required during this period, a nesting bird survey program is being conducted by Golder’s wildlife biologists prior to clearing and brushing activities to identify and protect active migratory bird nests, in accordance with protocol established by Canadian Wildlife Service (CWS).

Archaeological Concerns

White Pine identified that two Culturally Modified Trees (CMTs) exist on Salt Spring Island near structure number 52/1. These areas have been flagged off with a 10m buffer to avoid potential disturbance.

Recommendations

a) Issues Requiring Immidiate Action

i) Allteck (White Pine as Alteck's Environmental Monitor) is to submit the following activity, Environmental Protection Plans (EPPs):

• Sediment and Erosion Control Plan
• Hazardous Materials Handling Plan
• Emergency Responsed and Spill Prevention Plan
• Concrete Handling, Placement, and Curing Plan
• Occupational Health and Safety Plan
• Traffic Management Plan
• Hazardous Materials Control Plan
• Concrete Handling, Placement and Curing Plan

Contractor Environmental Pre-Work Orientation Record needs to be completed and signed-off for each of Allteck, Dent and Pacific Blasting.

White Pine is to submit the Contractor Environmental Per-Work Orientation Record with detailed schedule.

ii) Allteck is to minimize disruption of herptile breeding periods and avoid mortality of amphibians and reptiles.

The pond at transmission structure number 54/1 on Salt Spring Island provides potential habitat for the red legged frog, which is a species of concern under federal (Species at Risk Act – SARA) legislation.

Should draining of this pond be required, it will be necessary to undertake an amphibian salvage subject to terms and conditions of a Wildlife Permit.

b) Developing Issues

Allteck and their subcontractors (specifically Dent) are to maintain a waste management log detailing disposal of waste materials, as referenced in the EMP. White Pine as Environmental Monitor is to inspect this log for compliance.

The silt fence that failed between structures 53/1 and 53/2 should be reinstated and inspected by White Pine prior to further work in this area of Salt Spring Island.

Anchor holes drilled within bedrock have resulted in small piles of drilling dust at each site. White Pine’s Daily Environmental Reports propose the drilling dust be used as backfill when completing the footing works.

In view of the acid rock drainage potential of the rock on Maple Mountain, and since the rock drilling dust is a contrcution waste with no structural quality as backfill, Go0lder recommends that the rock drilling dust be collected and removed offsite to an approved landfill.

Allteck is to restore disturbed riparian areas along ROW to preconstruction conditions. White Pine is to document these activities in the Daily Environmental Monitoring Reports.

Golder personnel (qualified professionals) are currently undertaking on-going bird nesting surveys in accordance with this commitment.

Allteck is to control the introduction and spread of noxious weeds and invasive species.

Allteck is to follow mitigation measures per Wildlife Risk Management System, Fuel Management Handbook and Vegetation Management Standard VM 06.190, and to follow applicable provincial wildfire legislation. White Pine as Allteck’s Environmental Monitor is to monitor this commitment.