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HONOUR SOLEMN TREATY PROMISES AND RESTORE CONFIDENCE IN FEDERAL SITE C DICISIONS

November 19th, 2015 Honourable Justin Trudeau, Prime Minister of Canada Honourable Jody Wilson-Raybould, Minister of Justice Honourable Catherine McKenna, Minister of Environment and Climate Change Honourable Hunter Tootoo, Minister of Fisheries, Oceans and the Canadian Coast Guard Honourable Carolyn Bennett, Minister of Indigenous and Northern Affairs Honourable Lawrence MacAulay, Minister of Agriculture and Agri-Food Honourable Marc Garneau, Minister of Transport Liberal Members of Parliament for British Columbia Dear Prime Minister Trudeau, Honourable Ministers and BC Liberal MPs, HONOUR SOLEMN TREATY PROMISES AND RESTORE CONFIDENCE IN FEDERAL SITE C DECISIONS At the outset, let me congratulate you on forming a government committed to making real, positive change both in what the federal government does, and how it does it. I am writing on behalf of the Peace Valley Landowner Association (PVLA) to urgently request the assistance of your new government to restore open, transparent and accountable federal government decision-making regarding the controversial $8.8 Billion Site C Dam project on British Columbia’s Peace River. The decisions your government makes on Site C over the upcoming days and months present a once-in-a-mandate defining opportunity to demonstrate your commitment to: • Set and meet a higher bar for openness and transparency in government, • Renew the most important relationship we as Canadians have – that with Indigenous Peoples - based on recognition of rights, respect, co-operation and partnership, • Respect and uphold Treaty Rights, • Review and modify the federal Site C litigation strategy consistent with the above commitments, • Take immediate steps to restore public confidence in federal environmental assessment decisions, permits, processes, oversight, and enforcement, and • Identify, research and pursue other renewable energy options that are more effective at tackling climate change, minimizing the destruction of prime agricultural land, and promoting employment and economic spin-offs, especially for Indigenous Peoples.

In the balance of this letter I will elaborate on this unique opportunity and litmus test of your government’s commitment to real change. WHO IS THE PEACE VALLEY LANDOWNER ASSOCIATION? PVLA is a group of farmers and residents affected by the Site C dam. We are part of a large, diverse group of individuals, organizations and indigenous leaders who have called for the suspension of construction to allow time for further independent review of Site C and the completion of court cases challenging project approvals. Some of the many organizations and individuals who share our concerns are listed below. Of particular note, two respected individuals who support a delay in Site C construction are Dr. Harry Swain, economist and chair of the federal/provincial Site C Joint Review Panel and a respected former federal public servant and Mr. Richard Bullock, former chair of BC’s Agricultural Land Commission. Dr. Swain is on record as saying that the failure to fully consider alternatives to Site C such as wind, solar, and geothermal amounts to a “dereliction of duty.” Mr. Bullock is on record as saying the removal of prime agricultural land from the Agricultural Land Reserve for Site C is a “sin against humanity.” WHY DOESN’T THE SITE C DAM HAVE SOCIAL LICENCE? The sole agency independent of the proponent (BC Hydro) and its sole shareholder (the Province) to examine Site C was the federal/provincial Environmental Assessment Joint Review Panel chaired by Dr. Harry Swain. In a familiar pattern under the previous Conservative government, this environmental assessment process had many failings, including a compressed hearing timetable, lack of resources for intervenors, and no opportunity for cross-examination. A further description of procedural flaws in the review of Site C is listed in Appendix A. { 'This lack of procedural safeguards was compounded by the decision of the BC to exempt Site C from the expert, open and independent review to which such a project would normally be subject by the British Columbia Utilities Commission and the Agricultural Land Commission'.} In its May 2014 Report, the Joint Review Panel found: • the need for Site C has not been demonstrated, • it had neither the information, time or resources to conclude on the accuracy of the cost estimates put forward for Site C, and • Site C and energy alternatives should be subjected to further review by the BC Utilities Commission. The Joint Review Panel made numerous other findings that call into question the wisdom of proceeding with Site C in the absence of demonstrated need concluding:

The Panel was asked to present evidence that could lead to justification of the environmental, social, economic, health and heritage costs of the Project. Those costs are large, and governments in the past have been cautious about licencing projects with significant adverse residual effects. Justification must rest on an unambiguous need for the power, and analyses showing its financial costs being sufficiently attractive as to make tolerable the bearing of substantial environmental, social, and other costs. [Page 308 – JRP Report] Other experts not retained by BC Hydro or the Province of BC also found that the need for the Site C dam had not been demonstrated, and confirmed or added to the JRP findings noting: 1. Alternatives such as solar/wind backed by geothermal/natural gas would be half the cost and save BC taxpayers $4 billion+ in capital costs as well as resulting in lower unit energy costs. Refer to the report by respected energy economist Robert McCullough in Appendix B or video report at

2. Renewable alternatives would generate more long term economic spin-offs and employment for indigenous and non-indigenous communities. Refer for example to the information on Geothermal at Appendix C or the November 14, 2014 final draft report by KPMG entitled “Economic and Social Impacts of the Clean Energy Sector in B.C.”; 3. The government would save $200 million or more by delaying Site C for 2 years to properly research other renewable options - whether or not Site C proceeds. Refer for example to the analysis of savings from a delay to the start of Site C set out in Appendix D; 4. The lands flooded by the Site C dam reservoir would create a permanent significant adverse impact on the environment and destroy: a. agricultural land that could provide fruit/vegetables for 1 million people which is needed now more than ever in light of climate change and the California drought, b. critical wildlife habitat, c. significant archaeological and historic sites, including two of BC’s earliest fur trading posts; 5. Discount rates used in the supporting financial analysis were not appropriate and are inconsistent with the approach recommended by the CD Howe Institute ; {C.D. Howe Institute, The Valuation of Public Projects: Risks, Cost of Financing and Cost of Capital, Commentary No. 388, September 2013, Pages 3-4.} 6. Site C would increase electricity rates for hard pressed BC ratepayers significantly beyond the current phased increase of 28%; 7. Site C is not a green project and has a greater carbon footprint than other renewable alternatives. Refer for example to correspondence at Appendix E;