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APPENDIX 2A – GARIBALDI AT SQUAMISH PROJECT

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									APPENDIX 2A – GARIBALDI AT SQUAMISH PROJECT


    GARIBALDI AT SQUAMISH PROJECT WORKING GROUP ISSUE TRACKING TABLE1
            WORKING GROUP COMMENTS, PROPONENT’S RESPONSES
                AND SUMMARY OF MITIGATION AND COMMITMENTS


List of Acronyms used in Appendix 2A for Working Group Members

District of Squamish (DOS)
Environmental Assessment Office (EAO)
Fisheries and Oceans Canada (DFO)
Garibaldi at Squamish Inc. (GAS)
Ministry of Community and Rural Development (MCRD) (previously Ministry of Community
Development, prior Ministry of Community Services)
Ministry of Environment, Environmental Protection Division (MOE – EPD)
Ministry of Environment, Environmental Stewardship Division (MOE – ESD)
Ministry of Environment, Environmental Stewardship and Parks and Protected Areas (MOE –
Parks)
Ministry of Environment, Water Stewardship Division (MOE – WSD)
Ministry of Forests and Range (MOFR)
Ministry of Tourism, Culture and the Arts (MTCA)
Ministry of Transportation and Infrastructure (MOTI)
Resort Municipality of Whistler (RMOW)
Squamish-Lillooet Regional District (SLRD)
Transport Canada (TC)




1
  The Working Group Issue Tracking Table contains comments submitted by the Working Group on the
2003 Application and Addenda #1 through #3 from 2007 through 2009 and GAS Inc.’s responses
including mitigation and a summary of commitments. A detailed description of the commitments is
contained in Appendix 3 – Table of Owner’s Commitments and Assurances.
                                                          APPENDIX 2A    GARIBALDI AT SQUAMISH PROJECT
                                                                  GAS INC. WORKING GROUP ISSUES TRACKING TABLE, 2007-2009

ISSUE     DATE       ISSUE                                   ISSUE RAISED                                        GARIBALDI @ SQUAMISH INC. RESPONSE                              MITIGATION AND
  #                 RAISED                                                                                                                                                       COMMITMENTS
                       BY
TOPIC: SKI AREA DEVELOPMENT
  1.    July 9,    Squamish-   Discrepancy between “agreed to” comfortable carrying capacity (CCC) of Garibaldi at Squamish Inc. (GAS) revised the CCC                  GAS commits to a maximum bed unit
        2007       Lillooet    12,000 and proposed 15,250 skiers per day. Further discrepancy with and bed units based on project design and financial                  count of 21,922 as agreed to with the
                   Regional    proposed bed unit count of 22,846.                                     considerations. GAS will continue to work with                    Ministry of Tourism, Culture and the
                   District                                                                           Ministry of Tourism, Culture and the Arts (MTCA)                  Arts (MTCA) during the master plan
                   (SLRD)                                                                             during the master plan review and with local                      review. This number is based on the
                                                                                                      government through the Official Community Plan                    All    Season      Resort      Guidelines
                                                                                                      (OCP) amendment and rezoning processes to                         (ASRG’s) and is subject to there being
                                                                                                      finalize bed units which will be based on All Season              sufficient servicing in place to support
                                                                                                      Resort Guidelines (ASRG).                                         that many bed units and appropriate
                                                                                                                                                                        zoning. GAS commits to working with
                                                                                                                                                                        local government through the OCP
                                                                                                                                                                        amendment and rezoning processes
                                                                                                                                                                        to finalize bed units for the Garibaldi at
                                                                                                                                                                        Squamish development.

  2.    July 9,    SLRD        5600 day skiers estimated. How does day skier visits influence the calculation Skier visits do not determine bed units (BU). BU are      GAS commits to a maximum bed unit
        2007                   of bed units? We understand that the bed unit count does not drop determined under ASRG; based on skier capacity                         count of 21,922 as agreed to with the
                               proportionately – so it would seem that there are several thousand “excess” and other parameters.                                        Ministry of Tourism, Culture and the
                               bed units built into the formula and/ or there will be occasions when the resort                                                         Arts (MTCA) during the master plan
                               operates well beyond its comfortable carrying capacity.                                                                                  review. This number is based on the
                                                                                                                                                                        All    Season      Resort      Guidelines
                                                                                                                                                                        (ASRG’s) and is subject to there being
                                                                                                                                                                        sufficient servicing in place to support
                                                                                                                                                                        that many bed units and appropriate
                                                                                                                                                                        zoning. GAS commits to working with
                                                                                                                                                                        local government through the OCP
                                                                                                                                                                        amendment and rezoning processes
                                                                                                                                                                        to finalize bed units for the Garibaldi at
                                                                                                                                                                        Squamish development.

  3.    July 9,    SLRD        Climate and snow pack information should be updated to include 2006 data. A      If climate change advances to the point of adversely    GAS will work with MTCA during the
        2007                   more detailed discussion of the potential impacts of climate change is           affecting the practicality of winter recreation as we   finalization of the master plan
                               recommended: How will climate change affect the resort’s long term viability?    know it today, Garibaldi and the majority of mountain   agreement to determine weather-
                               How much might the freezing level rise over time? Will the requirement for       resorts across North America will be confronted with    monitoring requirements. GAS Inc.
                               water to make snow increase over time?                                           the need to develop new amenities for wintertime        commits to installing an on-site
                                                                                                                mountain recreation.. Garibaldi is proposed as a        weather station(s) to record weather
        December               As SLRD noted in its comment above climate change is a fundamental year round resort development – not as a stand-                       information and to provide annual
        4, 2007                variable that has not been dealt with in a proactive way. The proposed ski hill, alone ski area development.                             analysis to MTCA on its impacts to
                               with its coastal location and relatively low elevation, will be particularly                                                             skier operations.
                               vulnerable to climate change. Substantively addressing this issue, verifying
                               the longevity of the resort given climate change projections, is necessary to
ISSUE     DATE         ISSUE                                   ISSUE RAISED                                     GARIBALDI @ SQUAMISH INC. RESPONSE                            MITIGATION AND
  #                   RAISED                                                                                                                                                  COMMITMENTS
                         BY
        January 7,             justify the environmental impacts of the project.
        2010
                               SLRD again reiterates that climate change considerations are not addressed.
                               While resort is year round Bed Units are clearly assigned based on ski
                               capacity. If that capacity diminishes there is no apparent option that would
                               viably replace skiing.

  4.    July 9,      SLRD      Which trails provide local and regional trail connections?        How many Trail lengths and trail connections have yet to be GAS commits to working with MTCA,
        2007                   kilometers of paved multi use trail?                                       determined. However, the GAS project will provide BC Parks and local governments to
                                                                                                          a significant net gain in multi-use trails. GAS has develop a regional trail strategy.
                                                                                                          been working with MTCA, District of Squamish
                                                                                                          (DOS), SLRD, BC Parks and local trail groups to
                                                                                                          prepare a Recreation Trails and Sites Management
                                                                                                          Plan for the master plan that will include a
                                                                                                          comprehensive layout and design of the trails
                                                                                                          network. This information was submitted to MTCA
                                                                                                          in February 2009 as part of the Master Plan
                                                                                                          Addendum.

  5.    July 9,      SLRD      Cash flow pro forma shows $1.35 million for trails and public art which appears Roads and trails require very different engineering     GAS commits to develop trails in
        2007                   to be extremely low given the estimated cost of road construction.              and construction; hence costs are not comparable.      accordance with its Recreation Sites
                                                                                                               During detailed master planning, the total number of   and    Trails    Management     Plan
        January 7,             Feasibility of commitments to amenities such as trails should be confirmed trails will be determined and appropriate costs set         (RSTMP) that it is developing in
        2010                   prior to approvals. Can be addressed at OCP/Rezoning stage.                     aside to develop trails.                               consultation with MTCA, DOS, SLRD,
                                                                                                                                                                      SN, BC Parks and stakeholder groups.

  6.    July 9,      SLRD      More detail on the 1900 parking spaces is needed (this may be addressed in a Parking requirements will be determined by MTCA         GAS commits to develop parking
        2007                   different volume). What will they be surfaced with? What will be done to to meet all season resort guidelines. Parking will be       capacity that meets the ASRG’s, and
                               mitigate the impacts of this parking?                                        developed in phases in keeping with skier capacity.     to address parking lot run off, parking
                                                                                                            See Volume 7 for an environmental assessment            facilities will be developed in keeping
                                                                                                            (EA) of parking lot impacts.                            with the stormwater management plan
                                                                                                                                                                    and BMP’s as approved by MoE, and
                                                                                                               If permitted day lots will be maintained with gravel the amount of impervious parking
                                                                                                               surfaces. Volume 7 mentions the potential for the surfaces will be minimized..
                                                                                                               use of porous pavement in parking lots or
                                                                                                               conventional pavement with perimeter infiltration.
                                                                                                               The detailed design studies will determine the
                                                                                                               appropriateness of this and other LID techniques for
                                                                                                               the project site.

  7.    July 9,      SLRD      What about hotel and other resort employee (+-1000 other workers?) GAS will provide employee parking and develop a                     GAS commits to working with local
        2007                   transportation and parking?                                             transit plan that will link to Squamish transit system.        government to develop a transit plan
                                                                                                       during the rezoning and OCP amendment process.                 connecting   the  resort   to    the
        January 7,             SLRD noted that this comment can be addressed t the OCP/Rezoning stage.                                                                community of Squamish.
        2010

  8.    December     SLRD      The resort Competitive Analysis brings forward some interesting research that GAS updated its skier visit projections based on the
ISSUE     DATE        ISSUE                                  ISSUE RAISED                                          GARIBALDI @ SQUAMISH INC. RESPONSE                         MITIGATION AND
  #                  RAISED                                                                                                                                                   COMMITMENTS
                        BY
        10, 2007              points to an increasing number of skiers visiting British Columbia in the future.   2007/2008 winter-season. The updated skier visit
                              However, a number of important facts that are relevant to Garibaldi at              projections were provided in the Addendum 1 to
                              Squamish seem to be deemphasized. For example between 2001 and 2006                 MTCA. The industry may have seen a decline in
                              the industry saw a decline of 200,000 skiers. Ski resorts in BC are not             skier visits in any one season; however, skier visits
                              operating at full capacity. The winter of 2006/2007 was the best Whistler has       in B.C. and the interior of B.C. in particular have
                              seen for years and still the average occupancy rate was 50 per cent. The            increased by 29 percent over the ten-year period
                              report stated that Tamarac, a resort in Idaho that opened in 2004, had ‘actual      ending in 2007 as per the SE Group report (page 5).
                              skier visits significant lower that projected.’ Additionally, the US has seen a     The 2007/08-ski season reported a record volume
                              ‘weather-induced decrease’ in the number of skiers.                                 for skier days for BC with more than 6.6 million skier
                                                                                                                  visits to BC resorts.
                              Given the Garibaldi at Squamish will be a relatively low elevation ski hill
                                                                                                       It is important to note that the SE Group report cited
                              subject to coastal weather, and that the ski industry has only begun to revive in
                                                                                                       other reports. There is ample evidence to suggest
                              the last few years, the conclusions drawn in the report seem optimistic. SLRD
                                                                                                       that the skier visits in the industry are growing, and
                              recommends that a more tempered view of the industry be used to inform all
                                                                                                       that BC will continue to increase its market share,
                              aspects of this development, from the environmental assessment certificate
                              (EA certificate) to the permitted number of bed units.                   and can do so even more so with additional
                                                                                                       capacity, and improving supporting infrastructure,
        January 7,
                                                                                                       such as improvements to the Sea to Sky Highway,
        2010
                              SLRD notes that RMOW commented in detail on this issue. RMOW has Vancouver International Airport, the Canada Line, as
                              extensive experience & expertise in resort issues. SLRD therefore has no well as improvements to the highway system in the
                              further comment.                                                         Interior as well as the expansion of the Kelowna
                                                                                                       International Airport.
                                                                                                                  With respect to the average occupancy rate of 50%
                                                                                                                  RMOW is very successful in other measurements.
                                                                                                                  In any event, there are likely a number of factors
                                                                                                                  affecting the hotel occupancy rate, including how the
                                                                                                                  universe of hotel inventory is calculated, i.e. does it
                                                                                                                  include resort condos with or without a hotel flag;
                                                                                                                  townhouses in rental pools; the short term negative
                                                                                                                  effect of the Sea to Sky Highway construction; the
                                                                                                                  value of the Canadian dollar versus the US dollar;
                                                                                                                  the downturn in the US economy, etc. all of which
                                                                                                                  are not permanent factors.
                                                                                                                  With respect to the Tamarack experience, the report
                                                                                                                  notes that the skier visits were less than projected
                                                                                                                  due to the isolation of the project and poor weather
                                                                                                                  conditions It is important to note that Tamarack also
                                                                                                                  lacked a bed base to accommodate skier visits.
                                                                                                                  GAS has followed the ASRG for determining bed
                                                                                                                  units.
                                                                                                                  With respect to the SLRD’s comment that GAS will
                                                                                                                  be a relatively low elevation ski hill subject to coastal
                                                                                                                  weather… GAS’s village site is 1,400 feet higher
                                                                                                                  than    that     of   Whistler/Blackcomb.        Whistler
                                                                                                                  Blackcomb as well as Mount Washington, and the
                                                                                                                  three local ski areas in Greater Vancouver, at much
ISSUE     DATE        ISSUE                                       ISSUE RAISED                                         GARIBALDI @ SQUAMISH INC. RESPONSE                               MITIGATION AND
  #                  RAISED                                                                                                                                                             COMMITMENTS
                        BY
                                                                                                                      lower elevations, generate cumulative annual skier
                                                                                                                      visits of 3,650,000.
                                                                                                                      MTCA Addendum 1 documents provides an
                                                                                                                      assessment of the potential impacts of the Garibaldi
                                                                                                                      resort project on Whistler and concluded “When
                                                                                                                      viewed as one component of the B.C. tourism
                                                                                                                      market, the development of Garibaldi at Squamish
                                                                                                                      will complement other existing and future destination
                                                                                                                      facilities. Accordingly, Garibaldi at Squamish will
                                                                                                                      support the overall tourism and economic goals of
                                                                                                                      the Squamish and Whistler communities, as well as
                                                                                                                      British Columbia”.

  9.    April 30,   BBC            There appears to be a disagreement among knowledgeable persons whether             Comment noted. GAS ski area designers (SE                  GAS commits to work with MTCA to
        2008        Research &     the GAS site offers the prospect for a serious destination resort, or if its       Group) are the longest established and most                monitor and address, as required,
                    Consulting     limitations will produce a smaller regional ski area. Acknowledging his            extensively utilized ski area consulting company in        impacts    to skier   visits  and
                    on behalf of   competitive interests, nevertheless, Mr. Forseth’s detailed concerns about the     the world. SE Groups ski area design expertise and         accommodation rates in the Sea to
                    Resort         site-access, elevation and terrain and exposure- aspect issues –were               knowledge of successful resort criteria is without         Sky Corridor.
                    Municipality   compelling…. It is unlikely that any ski area designer or additional study will    parallel. The Brohm Ridge ski area terrain and
                    of Whistler    resolve this issue. MTCA if it moves forward, should acknowledge these             capacity have been reviewed on many occasions by
                    (RMOW)         terrain concerns, and document the consequences of a resort development            recognized ski area consultants. These experts
                                   that is not fully functioning, destination offering and thus presents an           have all agreed at different times, that the area
                                   experience inferior to it Whistler neighbor. If opponents are correct in their     offers the significant ski terrain and capacity needed
                                   assessment of the site’s inadequacy, the Ministry and the town of Squamish         for a destination resort. BC (and Alberta and the
                                   should analyze the consequences and be prepared for a project that may             PNW) is home to a variety of ski areas, with different
                                   affect the local economy in a different manner than a full fledged destination     elevations, exposures, aspects and terrain. No two
                                   resort. In these circumstances, BBC Research & Consulting would anticipate         ski areas are the same and that contributes to the
                                   more day-skier use, additional commuting to whistler for skiing, less demand       variety of the skier and tourist experience in BC.
                                   for lodging and retail, pronounced weekend traffic and more traffic per visitor.
                                   Analysis of this prospect and appropriate modeling of likely socioeconomic         There will be an increased volume of visitors to GAS
                                   effects would seem a valuable addition to the public process.                      and also to Whistler and Blackcomb as a result of
        July 8,                                                                                                       the project given the increased critical mass and
        2009                       RMOW reiterated that MTCA and DOS should assess the consequences of a              ability of the 2 resort areas (Squamish and Whistler)
                                   resort development that is not fully functioning, and should analyze the           to draw from new markets and to increase the length
                                   consequences and be prepared for a project that may affect the local economy       of stay of those visitors, increasing the demand for
                                   in a different manner than a full-fledged destination resort. Although this        hotel accommodation in both areas. International
                                   comment was made in context of terrain concerns, Whistler contends that this       and destination travel tends to occur outside of the
                                   assessment should be made in light of the changes to the global economy and        weekend periods and can contribute to a reduction
                                   consequences to destination visitation and resort community performance. In        in peak travel demand. It can also be argued that
                                   light of these economic conditions, it is important to confirm that there is a     local and Vancouver skiers will not travel as
                                   reasonable scenario that has a chance of development success, and                  frequently to Whistler, reducing the traffic volume, air
                                   determine the consequences of that scenario on Whistler, Squamish and the          emissions, and risk of accident on highway 99, and
        January                    Corridor.                                                                          relieving the weekend day use congestion at
        20, 2010                                                                                                      Whistler and Blackcomb.
                                   It continues to be important for Whistler and the neighbouring communities that
                                   GAS assess the consequences of the resort not fully functioning as a
                                   destination offering, which is a possible outcome. In addition, Gas should
ISSUE     DATE         ISSUE                                 ISSUE RAISED                                      GARIBALDI @ SQUAMISH INC. RESPONSE                       MITIGATION AND
  #                   RAISED                                                                                                                                            COMMITMENTS
                         BY
                               assess the consequences of the project not proceeding beyond each phase,
                               and of failure. GAS is a capital intensive, market uncertain new resort that
                               requires public protections and contingencies.

  10.   July 8,      RMOW      Under issue #9 above, the RMOW through BBC Research & Consulting,    The resort project will be a phased development,
        2009                   suggested that the MTCA and District of Squamish should assess the   balanced and fully functional, in accordance with the
                                                                                                    ASRG approved master plan and master
                               consequences of a resort development that is not fully function, and should
                                                                                                    development agreement. The province in terms of
                               analyze the consequences and be prepared for a project that may affect the
                                                                                                    GAS performance will control subsequent phase
                               local economy in a different manner than at full-fledged destination resort.
                                                                                                    developments in the current phase. Economic
                               Although this comment was made in the context of terrain concerns, Whistler
                                                                                                    change is anticipated but as a long term plan the
                               contends that this assessment should be made in light of the changes to the
                               global economy and consequences to destination visitation and resort resort project can develop in stand-alone phases
                                                                                                    and return to development when market conditions
                               community performance. In light of these economic conditions, it is important
                                                                                                    and demand warrant that. GAS has committed to
                               to confirm that there is a reasonable scenario that a chance of development
                               success, and determine the consequences of that scenario on Whistler,monitor performance indicators. The GAS market
                               Squamish and the Corridor.                                           will be both day use and destination, a viable
                                                                                                    combination, and not reliant on one specific market.
                                                                                                    Past skier and summer demand and bed unit
        January                                                                                     utilization has grown and continues to grow at BC
        20, 2010                                                                                    mountain resorts, despite ongoing increases in
                               RMOW reiterated its earlier comment that the consequences of GAS not regional and competitor capacity, changing market
                               proceeding beyond each phase should be analyzed. See #9 above        conditions and ageing demographic profiles. There
                                                                                                    is an equal opportunity of growing the international
                                                                                                    market attracted to the sea to sky corridor based on
                                                                                                    additional and new (fresh) resort product at
                                                                                                    Squamish, driven by post 2010 market awareness,
                                                                                                    new airport improvements and the much improved
                                                                                                    highway access. This synergistic impact of multiple
                                                                                                    resorts has been witnessed in Utah, Colorado,
                                                                                                    France and Austria.


TOPIC: RESORT BASE DEVELOPMENT
  11.   July 9,      SLRD      The plan needs to be updated to reflect the new Riparian Area Regulations Prior to submission of the Master Plan update          GAS commits to providing streamside
        2007                   and the 30 meter riparian assessment area. Any setbacks of less than 30 Addendum 1 to MTCA in February 2009,                     protection and enhancement areas for
                               meters from water ways will need to be reassessed.                        ENKON Environmental               ground-truthed all   all   residential   and     commercial
                                                                                                         watercourses within the Phase 1-2 development          developments as per the Fish
        January 7,             The response adequately addresses the issue raised by SLRD.               areas to confirm to a greater degree the location of   Protection    Act-   Riparian   Areas
        2010                                                                                             streams and watercourses in relation to the base       Regulation,      Water      Act    and
                                                                                                         area plans, so the base area plans could take this     Regulations or the current regulations
                                                                                                         information into consideration at this preliminary     at the time of construction. Should
                                                                                                         level of design. This information was incorporated     minor infringements to the Streamside
                                                                                                         into Volume 3: Resort Base Master Plan update.         Protection and Enhancement Areas be
                                                                                                         Based on ENKON’s report, Perkins Design                unavoidable, GAS Inc. will comply
                                                                                                         then used a 15m setback for non-fish bearing           with DFO’s fisheries policies.
                                                                                                         streams and a 30m setback for fish bearing streams,
                                                                                                         to update the resort base area plans included in the
ISSUE     DATE         ISSUE                                    ISSUE RAISED                                     GARIBALDI @ SQUAMISH INC. RESPONSE                              MITIGATION AND
  #                   RAISED                                                                                                                                                     COMMITMENTS
                         BY
                                                                                                                MTCA Addendum 1, Volume 3: Resort Base Master
                                                                                                                Plan update. As a result areas 1 and 13 had
                                                                                                                significant changes in the resort base layout due to
                                                                                                                ENKON’s watercourse verification report, which
                                                                                                                identified a number of previously unmapped
                                                                                                                streams. If the GAS project is certified, this
                                                                                                                preliminary design information, combined with recent
                                                                                                                LIDAR mapping and further detailed design, will
                                                                                                                allow GAS to develop its base area design reflecting
                                                                                                                the RAR and in line with the EA commitments.

  12.   August 23,   Ministry of   Consider regional concern about the need for affordable housing and worker   An “Employee Housing Strategy” was submitted to GAS is committed to ensuring
        2007         Community     housing.                                                                     MTCA in February 2009 in the Master Plan update appropriately priced housing is not a
                     and Rural                                                                                  Addendum 1.                                            limiting factor for workers and will
                     Developme                                                                                                                                         consider alternative and innovative
                     nt (MCRD)                                                                                  GAS is planning to offer as many positions as housing options for employees should
                                                                                                                possible to Squamish and area residents, it is hoped this become necessary.
                                                                                                                that this commitment will help minimize employee-
                                                                                                                housing issues. It is anticipated that the majority of
                                                                                                                non-local workers will come from Greater Vancouver
                                                                                                                and that many of these workers will choose to
                                                                                                                commute to Squamish from Vancouver for the
                                                                                                                duration of their contract. Workers who do not fit
                                                                                                                into either of the above categories will need to rely
                                                                                                                on available rental accommodation in Squamish.
                                                                                                                However, GAS has indicated that it is committed to
                                                                                                                ensuring appropriately priced housing is not a
                                                                                                                limiting factor for workers and will consider
                                                                                                                alternative and innovative housing options for
                                                                                                                employees should this become necessary.             In
                                                                                                                addition to this, a number of construction workers
                                                                                                                now involved in major projects like the highway
                                                                                                                upgrades, 2010 venues and housing construction
                                                                                                                generally in the area (with housing) will become
                                                                                                                available for the GAS project as these projects
                                                                                                                complete.

  13.   August 23,   MCRD          Consider possible need to identify sites for other community services if the The socioeconomic impact assessment has                GAS Inc. commits to work with the
        2007                       resort is built out – like schools etc;                                      identified needs for additional community services,    province, District of Squamish and SLRD
                                                                                                                including a potential need for additional school       to determine servicing requirements and
                                                                                                                spaces as the project approaches build-out.            locations, and identify emergency and
                                                                                                                                                                       community facilities in the master plan and
                                                                                                                                                                       through the OCP amendment process.


  14.   August 23,   MCRD          Consider the kinds of community issues other resort communities are dealing Comment noted. If necessary, GAS will provide
        2007                       with – how does GAS attract and retain commercial/retain services like incentives to attract commercial enterprises during
                                   laundromats etc. when real estate values are so high.                       the early stages of the project. At later stages of
ISSUE     DATE         ISSUE                                     ISSUE RAISED                                      GARIBALDI @ SQUAMISH INC. RESPONSE                            MITIGATION AND
  #                   RAISED                                                                                                                                                     COMMITMENTS
                         BY
                                                                                                                  development, commercial services are expected to
                                                                                                                  be self-sustaining. This challenge has been faced
                                                                                                                  by other resort projects in BC and can be
                                                                                                                  successfully addressed at Garibaldi.

  15.   August 28,   District of   It would appear that the applicant would have to make application for OCP and GAS will submit applications to both jurisdictions if   GAS commits to submitting OCP and
        2007         Squamish      Zoning changes in both the SLRD and the DOS.                                  necessary. We understand that SLRD and the DOS          zoning applications to DOS and
                     (DOS)                                                                                       could conduct a coordinated review.                     SLRD, as directed by the local
                                   DOS has always maintained that this project should only proceed if it becomes                                                         governments, post EA certification.
                                   part of DOS.                                                                  There currently are three options for governance: (2)
                                                                                                                 GAS resort becomes part of the DOS. (2) GAS
                                                                                                                 resort becomes part of the SLRD.            (3) GAS
                                                                                                                 becomes a resort municipality.         GAS favours
                                                                                                                 becoming part of the DOS.

  16.   August 28,   DOS           It would be appropriate to plan for a complete community to include all the GAS has provided the appropriate funding to the           GAS commits to work with the
        2007                       services required on site (RCMP, fire hall, medical, schools, recreation District of Squamish (DOS) to conduct the fiscal             province, DOS and SLRD to
                                   services, etc.). These would likely be located at the Garibaldi at Squamish site impact/socio-economic study.       The DOS has       determine servicing requirements and
                                   at full build out, regardless of what model of governance is in use.             contracted MMK Consulting to conduct the study.      locations,  and     identify needed
                                                                                                                    The MMK report will identify the need for            emergency and community facilities in
                                                                                                                    emergency, institutional and community facilities    the MTCA Master Plan and OCP
                                                                                                                    within the resort boundaries; these sites will be    amendment process.
                                                                                                                    incorporated into the GAS master plan.

                                                                                                                  A community amenity plan and transit plan linking
                                                                                                                  the resort and the community of Squamish will be
                                                                                                                  developed as part of the rezoning and OCP
                                                                                                                  amendment process.


  17.   August 28,   DOS           What will the impact of GAS be on Highway 99 in the short- and long-term?      Volume 5 Road Design, Access and Traffic Impacts
        2007                                                                                                      prepared by McElhanney assessed potential traffic
                                                                                                                  impacts from the Garibaldi project.         Traffic
                                                                                                                  projections show that GAS will not impact the
                                                                                                                  capacity of Highway 99 over the term for which the
                                                                                                                  current upgrade is designed.

  18.   August 28,   DOS           It is crucial that an EA certificate not be issued without understanding the fiscal GAS has provided the appropriate funding to the  GAS commits to work with the SLRD
        2007                       impact of the project to the DOS and the corridor.                                  DOS to conduct the fiscal impact study. The DOS and DOS to complete the Fiscal
                                                                                                                       has contracted MMK Consulting to conduct the Impact Study/Socio-economic update
        August 29,                 DOS expectation is that the fiscal impact study be completed and the results study, which has been completed and is currently study currently underway.
        2007                       considered prior to the EA process coming to a conclusion about the Project.        being reviewed by DOS.

  19.   August 28,   DOS           The Ministry of Community and Rural Development expects the proponent to       GAS will work with the DOS and/or SLRD GAS Inc. commits to submitting OCP
        2007                       work with the DOS and the SLRD to develop the necessary OCP and Zoning         (depending upon the final governance decision) to and zoning applications to the DOS
                                   Bylaws.                                                                        develop the necessary OCP and Zoning Bylaws.      and SLRD, as directed by the local
                                                                                                                                                                    governments, post EA certification.
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  20.   November   Resort         The GAS proposal of 22,295 beds in the base area appears to be in significant    MTCA has finalized an amendment to the ASRG to          GAS commits to a maximum bed unit
        20, 2007   Municipality   contravention with the Province’s ASRG. Under Balanced Resort Capacity           encourage First Nations economic participation in       count of 21,922 as agreed to with the
                   of Whistler    (BRC) calculations, the number is likely to fall within 10,000 to 12,000 Bed     resort developments by providing additional points in   Ministry of Tourism, Culture and the
                   (RMOW)         Units. Consideration of on-mountain destination quality facilities such as       the Bed Unit Calculation based on the degree of         Arts (MTCA) during the master plan
                                  conference centres, spas, skating, etc. would supplement the level of            First Nations’ economic participation in a resort       review. This number is based on the
                                  development permitted.                                                           development. Given the high level of Squamish           All    Season      Resort      Guidelines
                                                                                                                   Nation participation in the GAS proposal. MTCA has      (ASRG’s) and is subject to there being
                                                                                                                   advised GAS that it is eligible for the maximum         sufficient servicing in place to support
                                                                                                                   number of points (4 additional points).                 that many bed units and appropriate
                                                                                                                                                                           zoning. GAS commits to working with
                                                                                                                   This change along with changes resulting from           local government through the OCP
                                                                                                                   MTCA’s review of GAS’ point allocation in the bed       amendment and rezoning processes
                                                                                                                   unit calculation provided in the 2003 Base Master       to finalize bed units for the Garibaldi at
                                                                                                                   Plan will result in a maximum proposed bed unit         Squamish development.
                                                                                                                   count of 21,922 bed units based on a skier
                                                                                                                   Comfortable Carrying Capacity (CCC) 15,250. Non-
                                                                                                                   mountain destination quality facilities have been
                                                                                                                   identified in the Master Plan update Addendum 1.

  21.   November   RMOW           If GAS is being presented as a destination resort, then key competitors such The SE Group report includes a section on the
        20, 2007                  as resorts in Colorado, Utah and California – many of whom are also adding Comparison of British Columbia Growth with U.S.
                                  capacity should be included in the business case/economic analysis.          Skier Destinations, which covers the Colorado, Utah
        July 8,                                                                                                and Idaho markets. The report notes that …These
        2009                      July 8th comment – RMOW expressed concerns that GAS include key and many other programs are designed to maintain
                                  competitors such as resorts in Colorado, Utah and California in the business skier visits around the 12-13 million mark,
                                  case/economic analysis. GAS has represented that with the addition of recognizing that Colorado is a mature market with
                                  Tamarack to the Idaho market, that average visits to Sun Valley were few remaining opportunities to increase ski area
                                  unaffected, showing that the addition of Tamarack to the Idaho market, that supply. When comparing B.C. to Colorado, it is
                                  average visits to Sun Valley were unaffected, showing that the entire region evident that B.C. continues to be an emerging
                                  actually witnessed a steady increase in skier visitation growth. GAS Inc. market with significant growth opportunities
                                  should update comments on the Idaho market with the introduction of a new sponsored by the government, while Colorado has
                                  ski area. Tamarack has failed and no longer exits.                           enacted strategies to compete in the world
                                                                                                               marketplace in order to maintain skier visits.
        January
        20, 2010                                                                                                   With respect to the Utah market, the report notes As
                                  Tamarack’s development was based on a similar business model to that of          Utah was able to expand their exposure through the
                                  GAS, namely being entirely dependent on investor purchases, which requires       Olympics, the increase supply was absorbed. This
                                  appreciation in value in order for subsequent investors to purchase. Our         scenario bodes well for B.C. in a post-Olympic
                                  consultants advise that Tamarack was in trouble well before the significant      period.
                                  market adjustment in the United States. They were over-extended and could        With respect to the Idaho marker, the report notes
                                  not recoup their development and operating costs through skier visits and real   that even with the addition of the new Tamarack
                                  estate sales. Less than 30% of investors intended to use accommodation           resort, Sun Valley maintained their average visits
                                  purchased for personal use, meaning that over 70% purchased as an                and was unaffected by Tamarack. This shows that
                                  investment. Tamarack’s failure was due to the model and the economic             with the addition of Tamarack the entire region has
                                  circumstances. The other resorts in this area continue to operate.               actually witnessed a steady increase in skier
                                                                                                                   visitation growth.
                                  RMOW continues to request that GAS include key competitors such as resorts
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                            in Colorado, Utah and California in the business case/economic analysis.             Response to the July 8th comment: Skier market
                                                                                                                 expectations and skier market forecasts have
                                                                                                                 been updated as part of the Masterplan review with
                                                                                                                 MTCA. GAS acknowledges the Tamarack closure
                                                                                                                 and other resort setbacks in the US as a result of the
                                                                                                                 most significant financial market adjustment in the
                                                                                                                 US since the Great Depression. Notwithstanding
                                                                                                                 that, this resort project is planned for development
                                                                                                                 over the long term, and the US and Global economy
                                                                                                                 is recovering with past resort and recreation
                                                                                                                 demands and trends likely recovering as well.

  22.   November   RMOW     GAS must show how overnight stays are affiliated with the skier visit MTCA has indicated that GAS’ market analysis must                       GAS commits to work with MTCA to
        20, 2007            projections, and how they would reach sustainable room nights for the resort. specifically assess the potential positive and                  monitor and address, as required,
                                                                                                          negative impacts to Whistler Blackcomb and the                  impacts    to skier   visits  and
                                                                                                          potential impact to the regional overnight                      accommodation rates in the Sea to
                                                                                                          accommodation market.                                           Sky Corridor.

        January                                                                                                  GAS as a result retained Lynnpeaks Consulting to
        20, 2010            The Lynnpeak report states that “If Whistler does not achieve any growth in          update the current resort and hotel trends and
                            accommodation demand after the 2010 Olympics, Whistler will have to                  complete a preliminary accommodation analysis of
                            address bigger issues than the Garibaldi Resort.” In fact, Whistler and other        GAS, and to estimate the risk of impact to other BC
                            mountain resorts in B.C. are currently grappling with significant issues that are    ski and golf resorts of the GAS developments, based
                            compromising resort community success. Whistler is predicting average                on current base area phasing and scheduling for
                            occupancies for the 2009/10 winter and summer season to fall below 50%.              development.. This report will be submitted to
                            Factors contributing to this phenomenon include the loophole in provincial           MTCA in February 2009 as part of the Master Plan
                            regulations that enables multiple property managers in a property to escape          update Addendum 1 materials.
                            being classsified commercial, creating poor customer service due to multiple
                            management schemes. These properties also escape paying toward resort                SE Group also submitted an updated “Resort
                            marketing and operations.                                                            Competitive Analysis” report to MTCA in February
                                                                                                                 2009 as part of the Master Plan update Addendum
                            Whistler’s net promoter score has fallen below 50% on an annual basis.               1: Volume 13 Financial and Market Analysis
                            These are structural issues that require changes to provincial regulations.          information requirements which addressed potential
                            GAS would exacerbate these issues. [EAO Note: RMOW also provided a                   skier/accommodation impacts to
                            report on Accommodations Sector Performance Review by Design Workshop,               Whistler/Blackcomb.
                            Inc.]


  23.   November   RMOW     Statistics should be provided in the report that relate to the “year round” aspect   GAS provided a breakdown of skier visits, summer
        20, 2007            of the proposal. GAS should breakdown visitation to BC by season.                    lift rides, and golf visits for each year in Volume 13
                            Additionally, information related to golf as part of summer visitation should be     of the submission, which has been assessed by
                            provided in their market assessment.                                                 MTCA’s consultant in the Technical Review.

                                                                                                                 GAS has revised the April 2003 Master Plan based
                                                                                                                 on additional information requirements outlined in a
                                                                                                                 letter dated October 2008 from MTCA and has
                                                                                                                 submitted this information to MTCA in February
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                                                                                                                  2009 in the Master Plan update Addendum 1
                                                                                                                  materials.

  24.   November   RMOW     Whistler requests that expert third party assurance be provided that the GAS A third party review of the Garibaldi project was                  GAS commits to work with MTCA to
        20, 2007            mountain master plan is appropriate for and caters to the destination visitor performed by PWC and Stantec Consulting, Inc.                     monitor and address, as required,
                            market.                                                                       under contract to MTCA and confirmed the project                  impacts    to skier   visits  and
                                                                                                          viability and destination visitor market.                         accommodation rates in the Sea to
        July 8,                                                                                                                                                             Sky Corridor.
        2009                                                                                             Response to the July 8th comment: The third party
                                  th
                            July 8 RMOW requests that GAS disclose the results of the third party review review was completed under contract to MTCA, by
                            to provide assurance that the GAS mountain master plan is appropriate and MTCA – not by GAS. MTCA is satisfied with this
                            caters to the destination visitor market.                                    review of the GAS plans, and the review concluded
                                                                                                         that the project as planned is “economically viable”.
        January
        20, 2010
                            Is the third party review available for review? Whistler consultants have
                            asserted that the GAS mountain master plan is too dense for a destination
                            resort.

  25.   November   RMOW     Quality attractions and activities such as conference facilities, spas, trails,       The revised Master Plan Addendum 1 materials              GAS commits to complying with the
        20, 2007            skating, etc. are fundamental to becoming a successful destination resort.            identify locations/size of conference facilities, spas,   Master Development Agreement and
                            Without these facilities early in the projects development, GAS will remain a         trails and other non-skier recreation activities. GAS     provisions for covenants to construct
                            regional facility. These additional quality destination activities/attractions must   submitted this information to MTCA in February            such improvements (day lodges, lifts,
                            be mandated through both covenants and a perform/reward formula. Further              2009 in the update Addendum 1: Volume 3 Resort            runs, maintenance facilities, parking
                            information is requested.                                                             Base Master Plan materials.                               lots etc.) as a process for earning out
                                                                                                                  .                                                         Bed Units, and to continue to work
                                                                                                                                                                            with MTCA to determine the terms of
                                                                                                                                                                            the Master Development Agreement,
                                                                                                                                                                            which       will    govern     phasing
                                                                                                                                                                            commitments.

                                                                                                                                                                            GAS also commits to the development
                                                                                                                                                                            of non skier resort and recreation
                                                                                                                                                                            facilities as outlined in the master plan
                                                                                                                                                                            to provide the non skier destination
                                                                                                                                                                            activities and attractions.

  26.   November   RMOW     Macro-trends are invaluable indicators, but are only one of many indicators The SE Group Resort Competitive Analysis (January                   GAS commits to work with MTCA to
        20, 2007            that must be closely examined before it can be determined if there is a 2009) addresses this issue on more than a macro                         monitor and address, as required,
                            “complementary” effect on existing resort operations.                       basis. There is ample evidence to suggest that                      impacts to skier visits and
                                                                                                        complementary benefit of the clustering of ski                      accommodation rates in the Sea to
        January                                                                                         resorts. Case in point, the opening of Blackcomb                    Sky Corridor
        20, 2010            Whistler has asked that a socio-economic impact study be prepared for the Mountain in 1981 was a major factor as the impetus
                            region, including Whistler. To date, no such study has been prepared.       for Whistler Mountain to build new lifts and
                                                                                                        infrastructure, which collectively lead to the area
                                                                                                        becoming a very successful, world-renowned
                                                                                                        destination all-season resort. Whistler / Blackcomb
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                                                                                                              are a “cluster” in itself. The addition of other world-
                                                                                                              class resorts to the area such as GAS, and WOP at
                                                                                                              Callaghan Valley will add to the attractiveness of the
                                                                                                              area. This phenomenon is not new to the industry,
                                                                                                              but rather the standard for such areas as Lake
                                                                                                              Tahoe with 7 ski areas, the Arapahoe Basin in
                                                                                                              Colorado, and the numerous ski areas located in
                                                                                                              close proximity to Salt Lake City.

  27.   November    RMOW     GAS should “drill down” into the demographics of expected population growth GAS submitted a Master Plan update Addendum 1
        20, 2007             to gain a more accurate picture of participation in the active sports offered. to MTCA in February 2009. GAS believes the SE
                                                                                                            Group Resort Competitive Analysis report as well as
                                                                                                            the SE Group Comparative Analysis of Alpine
                                                                                                            Resort Activities should suffice in this regard.

  28.   November    RMOW     GAS should not be permitted to proceed to a next phase in the development The Master Development Agreement will provide the
                                                                                                                                                                        GAS commits to work with MTCA to
        20, 2007             unless the current phase of the resort is “economically successful and socially terms under which the proponent can proceed with
                                                                                                                                                                        monitor and address, as required,
                             responsible…” There must be a phasing formula in the Master Development the next phase.
                                                                                                                                                                        impacts    to skier   visits  and
                             Agreement that supports the resort operations and also takes into account
                                                                                                                                                                        accommodation rates in the Sea to
                             regional Sustained Prosperity.
                                                                                                                                                                        Sky Corridor


                                                                                                                                                                        GAS commits to complying with the
                                                                                                                                                                        Master Development Agreement and
                                                                                                                                                                        provisions for covenants to construct
                                                                                                                                                                        such improvements (day lodges, lifts,
                                                                                                                                                                        runs, maintenance facilities, parking
                                                                                                                                                                        lots etc.) as a process for earning out
                                                                                                                                                                        Bed Units, and to continue to work
                                                                                                                                                                        with MTCA to determine the terms of
                                                                                                                                                                        the Master Development Agreement,
                                                                                                                                                                        which       will    govern     phasing
                                                                                                                                                                        commitments.

  29.   August 3,   RMOW     The scale of commercial space (500,000 square feet) is well beyond what is       GAS has revised the April 2003 Master Plan based          GAS commits to complying with the
        2007                 required to service an appropriately sized resort at this location. It appears   on additional information requirements outlined in a      Master Development Agreement and
                             that a significant goal of this development is the generation of highway         letter dated October 2008 from MTCA and has               provisions for covenants to construct
                             commercial activity. It is our experience that highway commercial uses detract   submitted this information to MTCA in February            such improvements (day lodges, lifts,
                             from the “Best Place on Earth” experience. Highway commercial is already         2009 in the Master Plan update Addendum 1:                runs, maintenance facilities, parking
                             sufficiently offered in Squamish.                                                Volume 3 Resort Base Master Plan materials. The           lots etc.) as a process for earning out
        November                                                                                              revised plan re-assessed the location and size of the     Bed Units, and to continue to work
        20, 2007             The GAS proposal to include approximately 500,000 square feet of commercial      proposed commercial space by deducting the ski            with MTCA to determine the terms of
                             space is well beyond the needs of GAS, resulting in negative impacts to both     related guest services in the villages, and               the Master Development Agreement,
                             Whistler and Squamish from this “highway oriented commercial…” The               convention space, as well as possibly the spa to          which       will    govern     phasing
                             amount of commercial permitted must be justified and in balance with the         better assess the size of the possible impact.            commitments.
                             resort capacity.
                                                                                                              In due course GAS will identify and work with a retail
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                                                                                                         consultant to determine the commercial space to be
                                                                                                         built in each phase, and differentiate it from ski
                                                                                                         related guest services once the master plan is
                                                                                                         finalized and during the rezoning process. Skier
                                                                                                         services, food and beverage, and commercial/retail
                                                                                                         space for Phase I is currently estimated to be more
                                                                                                         than 30,000 square meters, and this will increase by
                                                                                                         the end of Phase II to more than 40,000 square
                                                                                                         meters.

  30.   November   RMOW     Housing for up to 60% of the workforce on-site must be a requirement of the An “Employee Housing Strategy” was submitted to
        20, 2007            Master Development Agreement, along with agreement to participate in a MTCA in February 2009 in the updated Addendum
                            regional solution to be determined.                                         1.                                                   GAS will meet the requirements of the
                                                                                                                                                             ASRG as it relates to employee
                                                                                                        It is intended that approximately 10% of the
                                                                                                                                                             housing and is agreeable to working
                                                                                                        proposed bed units developed at GAS will be used
                                                                                                                                                             with the region and local government
                                                                                                        for employee housing. These units will be by
                                                                                                                                                             to participate in a regional housing
                                                                                                        agreements dedicated and preserved by covenant
                                                                                                                                                             solution, where workable.
                                                                                                        upon the land title. Employee housing types may
                                                                                                        range from dormitories for seasonal employees, to
                                                                                                        affordable fee simple housing for permanent
                                                                                                        employees. They will be carefully integrated into
                                                                                                        the overall layout and structure of the resort and
                                                                                                        take into account support facilities, infrastructure
                                                                                                        requirements and transportation.
                                                                                                         The provision of 10% of the proposed bed units
                                                                                                         should satisfy on site employee housing needs
                                                                                                         based on anticipated employees in similar four-
                                                                                                         season resorts and as shown and discussed in the
                                                                                                         Socio-Economic Impact Analysis section of this
                                                                                                         document (see Volume 7). Concurrent with the
                                                                                                         master developer/operator commitment to employee
                                                                                                         housing, each individual hotel, restaurant, and
                                                                                                         commercial developer will be required to provide his
                                                                                                         own employee housing based on actual employee
                                                                                                         requirements. The employee units may be provided
                                                                                                         within the actual project development site, as an off-
                                                                                                         site location or by way of a contribution to an
                                                                                                         employee-housing fund.          Additional employee
                                                                                                         housing can be generated by allowing and
                                                                                                         encouraging single-family homes to include
                                                                                                         caretaker units as part of the single-family
                                                                                                         component.
                                                                                                         After the initial resort opening, an employee policy
                                                                                                         board will be established comprising the Proponent
                                                                                                         representatives from the DOS and governance
                                                                                                         structure to consciously monitor the region’s
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                                                                                                                      employee housing and to balance employee housing
                                                                                                                      needs between the resort and the District.

  31.   November     Ministry of   With these types of developments, there is often an expectation from               GAS is aware that timber harvesting will continue          GAS commits to prepare a Forestry
        26, 2007     Forests and   proponents and new residences that industrial activity will cease or be modified   throughout the Sea to Sky corridor and will work with      Management Plan for MTCA as part of
                     Range         so as not to impact their living experiences and view sheds. The Sea-to-Sky        the MOFR and MTCA to represent the value of                its MDA requirements which will
                     (MOFR)        Land and Resource Management Plan has recently confirmed that the lands            forest resources within the local area. MTCA will be       identify methods for addressing
                                   surrounding the proposed development are part of the timber harvesting land        responsible for timber administration within the           forestry issue.
                                   base. The proponents must accept and educate themselves and their future           Controlled Recreation Area (CRA).
                                   property owners of the fact that forest harvesting activities will continue to                                                                GAS commits to continue to work with
                                   occur and that some of these activities may impact the view sheds of the area.                                                                the MOFR and MTCA explore
                                                                                                                                                                                 opportunities to reduce impacts to the
                                                                                                                                                                                 Soo Timber Supply Area.

  32.   November     MOFR          The crown has a significant investment in the second growth forests in the         The decision to remove the lands from the provincial       GAS commits to prepare a Forestry
        26, 2007                   area of interest in the form of various silvicultural treatments designed to       forest and reduce the Annual Allowable Cut (AAC),          Management Plan for MTCA as part of
                                   enhance growth. The loss of these stands will result in the loss of these          will be a government decision predicated on the            its MDA requirements which will
                                   investments, the loss of future harvesting opportunities and their downstream      resort development reflecting the public interest in       identify methods for addressing
                                   benefits, and a loss in productive growing hectarage that impacts the annual       the revised land use.                                      forestry issue.
                                   allowable cut of the whole SOO timber supply area. These losses can be
                                   partially mitigated if the proponents fund comparable treatments on crown                                                                     GAS commits to continue to work with
                                   lands elsewhere in the Soo Timber Supply Area (TSA).                                                                                          the MOFR and MTCA to explore
                                                                                                                                                                                 opportunities to reduce impacts to the
                                                                                                                                                                                 Soo Timber Supply Area.

  33.   November     MOFR          The Forest Service remains available to further explore mitigating the above MTCA will be responsible for timber administration GAS commits to prepare a Forestry
        26, 2007                   items, in #39 and #40 including opportunities to continue practicing forest within the CRA.                                     Management Plan for MTCA as part of
                                   management within the area of GAS under a model complementary to the                                                            its MDA requirements which will
                                   development and participation in the Sea to Sky Forest Center at Squamish.                                                      identify methods for addressing
                                                                                                                                                                   forestry issue.

                                                                                                                                                                                 GAS commits to continue to work with
                                                                                                                                                                                 the MOFR and MTCA explore
                                                                                                                                                                                 opportunities to reduce impacts to the
                                                                                                                                                                                 Soo Timber Supply Area.

TOPIC: SMART GROWTH AND REGIONAL GROWTH STRATEGY
  34.   July 9,      SLRD          How does the ratio of single family to multi-family housing reflect the local      Sites available for commercial and residential   GAS commits to working with local
        2007                       pattern of land use, Smart Growth principles, and the goals of adjacent                                                             and regional governments to include
                                                                                                                      components of the project are limited by topography.
                                   municipalities? (Tourist accommodation (hotels and resort condos) accounts                                                          the Regional Growth Strategy, Smart
                                                                                                                      GAS Inc has proposed a significant number of high-
                                   for 45% of the total bed units, of the remaining units, 73% are single family.)                                                     Growth and Sustainability Principles
                                                                                                                      density areas and will refine the ratio of single family
                                                                                                                                                                       into
                                                                                                                      to multi-family housing based on market conditions.    the    Master   Plan,    resort
                                                                                                                                                                       development design, construction and
        January 7,                 SLRD noted that this comment can be addressed at OCP/rezoning stage.               A report that incorporates smart growth and operation, where feasible.
        2010                                                                                                          sustainability principles (SEE Solutions Inc.:
                                                                                                                      February 2009) was submitted to MTCA in February
                                                                                                                      2009 in the Master Plan update Addendum 1
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                                                                                                                materials and to the Environmental Assessment
                                                                                                                Office (EAO) in the Addendum 3 materials.

  35.   August 23,   MCRD      MCRD suggests that the proponent works with and understands the regional         Comment noted. The design of the base area
        2007                   context that has emerged in the last few years. This includes the development    development has been dictated by the topographic
                               of the regional growth strategy (underway) and the effort Whistler has made to   constraints of the site. GAS will follow smart growth
                               adopt and implement a Natural Step approach to development; and the Smart        principles wherever feasible, acknowledging that the
                               Growth on the Ground work that the DOS has invested in. There is an overall      development needs to proceed economically.
                               regional approach that is emerging that is quite positive - would hope future
                               development is consistent.                                                       A report (SEE Solutions Inc.: February 2009) that
                                                                                                                incorporates smart growth and sustainability
                                                                                                                principles was submitted to MTCA in February 2009
                                                                                                                in the Master Plan update Addendum 1 materials
                                                                                                                and to the EAO in the Addendum 3 materials.

  36.   August 23,   MCRD      MCRD agrees with the comments from others that more information is needed        GAS will incorporate sustainability principles into all GAS commits    to    incorporate
        2007                   on how the resort will demonstrate a commitment to sustainability and smart      phases of development taking into account the sustainability        principles      into
                               growth principles. Province is concerned about climate change and reducing       unique terrain constraints. Methods to minimize development design and operation
                               green house gas emissions and is encouraging local governments and the           green house gas emissions include encouraging where feasible.
                               development community to work together to plan and implement local growth        public transit links to Squamish and comprehensive
                               settlement patterns that emphasize mixed-use dense neighbourhoods – not a        trail network linking resort development nodes.
                               pattern of dispersed sprawl development with, for example, large single
                               detached homes as the predominant housing type.                                  A report (SEE Solutions Inc.: February 2009) that
                                                                                                                incorporates smart growth and sustainability
                                                                                                                principles was submitted to MTCA in February 2009
                                                                                                                in the Master Plan update Addendum 1 materials
                                                                                                                and the EAO in the Addendum 3 materials.

  37.   August 23,   MCRD      Proponent is asked to consider the long-term operational costs for               Comment noted. GAS has provided the appropriate         GAS commits to work with the SLRD
        2007                   infrastructure that local governments and resident community will have to        funding to the DOS to conduct the fiscal                and DOS to complete the Fiscal
                               manage in the future. Ministry conditional grants for infrastructure are more    impact/socio-economic study.   The DOS has              Impact/Socio-economic update study
                               directly tied to sustainable land-use decisions to discourage urban sprawl.      contracted MMK Consulting to conduct the study          that is currently underway.
                               Encourage consideration to the issue of ensuring long-term operational costs     that is currently underway.
                               will be sustainable for local government (i.e. road maintenance for the
                               extensive road system that is proposed).

  38.   August 28,   DOS       An interim Memorandum of Understanding was created by the SLRD to guide          The design of the base area development has been GAS commits to incorporate smart
        2007                   land use decisions until the Regional Growth Strategy (RGS) is completed.        dictated by the topographic constraints of the site. growth principles into the resort
                               The project contravenes the essence of the RGS and the Memorandum of             GAS will follow smart growth principles wherever design, where feasible.
                               Understanding, which are founded on smart growth principles. GAS seems           feasible, acknowledging that the development needs
                               oblivious to the issues.                                                         to proceed economically.

                                                                                                                A report (SEE Solutions Inc.: February 2009) that
                                                                                                                incorporates smart growth and sustainability
                                                                                                                principles was submitted in the Master Plan update
                                                                                                                Addendum 1 materials to MTCA in February 2009
                                                                                                                and the EAO Addendum 3 materials.
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  39.   December    SLRD      The principles of Smart Growth are not reflected in the design of the project,       The Holland Barrs Planning Group Sustainable           GAS commits to continue to work with
        4, 2007               particularly respecting compact, mixed-use neighbourhoods and walkable               Development Strategy report prepared for GAS           the SLRD and DOS to incorporate
                              communities. Terrain constraints, the reason given for the proposed layout of        outlines a strategy to achieve sustainable             Smart Growth principles into the
                              the development, may be an indicator of an inappropriate site rather than            development objectives for the proposed Garibaldi      project design, where feasible.
                              cause for constructing non-impact communities. We recommend that the                 at Squamish project. The report outlines core issues
                              applicant reconfigure the project to reflect Smart Growth principles, and            and perspectives on sustainable development and
                              reevaluate the economic feasibility of the project.                                  smart growth, provides a practical sustainable
                                                                                                                   development framework and offers suggestions for
                                                                                                                   addressing sustainability issues in the project.

                                                                                                                   GAS prepared an update to the Holland Barrs report
                                                                                                                   to be more specific on the incorporation of
                                                                                                                   Sustainability and Smart Growth principles. The
                                                                                                                   report (SEE Solutions Inc.) was submitted in the
                                                                                                                   Master Plan update Addendum 1 materials to MTCA
                                                                                                                   in February 2009 and the EAO Addendum 3
                                                                                                                   materials.

  40.   May 9 and   MCRD      While the Environmental Assessment process itself cannot review the                  GAS prepared an update to the Holland Barrs report     GAS commits to continue to work with
        May 26,,              proposed project against “Smart Growth” or “sustainability” principles- and, in      to be more specific on the incorporation of            the SLRD and DOS to incorporate
        2008                  particular, how they relate to climate change –think it is important to state, for   Sustainability and Smart Growth principles. The        Smart Growth principles into the
                              the record, that these issues could be raised later on as part of the necessary      report (SEE Solutions Inc.) was submitted in the       project design, where feasible.
                              local government rezoning process.                                                   Master Plan update Addendum 1 materials to MTCA
                                                                                                                   in February 2009 and the EAO Addendum 3
                                                                                                                   materials.

  41.   May 9 and   MCRD      In the context of developing a new resort area, with the potential for a
                                                                                                                 Comment noted. Resort design is by its nature,
        May 26,               significant residential housing component, the proponent should anticipate the
                                                                                                                 smart design, given the natural environment, limited
        2008                  possibility that local governments may wish the resort to be built out in a way
                                                                                                                 development land, challenging building sites, energy
                              that meaningful addresses “Smart Growth” and sustainability” principles. This
                                                                                                                 costs, dense use and dense development. GAS will
                              could include:
                                                                                                                 further define its commitment to implementing the
                              •   Seeking to see available, stable, commercial resort built prior to undertaking aspects of smart growth as referred to in the draft
                                  any significant residential development;                                       SLRD RGS and as presented in the Holland Barr
                                                                                                                 report by
                              •   Phasing the first residential components in ways that yield dense mixed-use
                                  precincts in close proximity to the resort to promote alternative                  • developing a sustainable resort that is
                                  transportation modes;                                                                  compact in its land-use, with a clear
                                                                                                                         development boundary and a distinct
                              •   Building residential areas with the appropriate densities and site                     development edge, a pedestrian focus and
                                  configurations to support conventional transit;                                        low impact transportation, an energy efficient
                              •   Building a range of housing types and tenures for a diversity of life stages           operation, and a strong sense of place where
                                  and incomes to meet the high need for affordable housing in the region;                wildlife and sensitive areas are protected;
                              •   Ensuring community infrastructure and buildings are environmentally                • building a self sustaining infrastructure for a
                                  sensitive, energy efficient and cost effective. Note: this should not just             complete community that incorporates a mix
                                  consider the capital construction side, but also long-term operations; and             used development based on a commercial
                                                                                                                         tourism core and multi season recreation;
                              •   Paying close attention to the design and build-out of residential areas in         • committing to resort construction and
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                              terms of the efficient provision of other local services including policing,         operations      practices    that    improve
                              schools and solid waste management.                                                  environmental conditions and habitat;
                            Other general guidelines that could be applied could include these additional      •   defining and using best management
                            areas:                                                                                 practices during construction and operations;
                            • Water/Soil: Develop a watershed management plan for the entire project           •   applying “LEED” green building standards to
                              area, and minimize the total developed area taken up by hard/impervious              reduce building footprints and buildings that
                              surfaces, including roads, paved areas and building footprints;                      consume less energy, water and other
                                                                                                                   natural resources, and minimize waste and
                            • Wastewater: Stormwater management approaches which facilitate, or                    air emissions; and
                              ideally utilize natural ecosystem processes;                                     •   operating ‘eco-efficiently’ by minimizing
                            • Habitat: Cluster development in strategic locations to ensure preservation of        consumption of energy, water and materials,
                               natural areas, wildlife corridors, and vegetation (i.e. new provincial goal of      and minimizing waste and emissions
                               promoting no net loss of forests) and;                                         GAS will increase its planning effort with local
                            • Energy: Develop with a high standard of energy efficient site planning and government in determining this implementation
                               building design. This includes such things as maximizing solar gain.           program and in the development of a number of
                                                                                                              management plans addressing issues such as
                            MCRD believes it is important for it to be clear that the Province is encouraging stormwater, sediment and erosion control,
                            local governments to plan towards improved climate change outcomes, vegetation & wildlife, and spill management, while
                            including a significant reduction in green house gas emissions. Thus one formulating strategies to address transportation and
                            should anticipate the possibility that the proponent may be asked by local alternative energy options.
                            government (s) to adapt the development design to more explicitly address
        December            “Smart Growth” and sustainability” principles as part of the local government
        11, 2009            rezoning process.                                                                 McElhanney Consulting Services has provided an
                                                                                                              updated “Stormwater Management Plan Process”
                            Generally, the province is encouraging local governments to look at ways to report (January 2009) that sets out the process to
                            reduce energy use and green house gas emissions. Depending on how they provide further details on stormwater management
                            are designed, water systems can use a lot of energy in terms of water during the detailed design of the project. The report
                            treatment, water distribution etc. I know the proponent is generally aware of was submitted to the EAO in February 2009 as part
                            sustainability and smart growth principles, but it is unclear to me how the of the Addendum 3 materials.
        December            proposed water supply (and accompanying distribution system) would be
        22, 2009            designed and built to minimize energy use. Along with the site design for the
                            resort, I would anticipate that local government would want the proponent to
                            address this to help reduce GHGs.

                            • The proponent commits to addressing smart growth and sustainability
                              principles only “where economically feasible”. It is unclear to MCRD what
                              this means in terms of having any sense of the degree to which the site
                              development/buildings would address to Smart Growth/sustainability
                              principles. Just one example of where MCRD sees a potential conflict is
                              with respect to proponents plans to build a commercial node at the entrance
                              to the highway. As the SLRD has pointed out, this conflicts with the draft
                              Regional Growth Strategy (RGS) and is not consistent with smart growth
                              principles (sprawl development). It would also impact the visual quality of
                              the highway and could impact the flow of traffic (MCRD will be interesting to
                              hear from Ministry of Transportation and Infrastructure on this).
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                               • Related to the point above is the fact that under the Climate Change Action
                                 Charter, combined with provisions in Bill 27 (2008), local governments have
                                 to reduce their corporate and community-wide green house gas emissions.
                                 So I would also anticipate that as part of the OCP/rezoning process that
                                 local governments will want to investigate ways in which GHG’s can be
                                 reduced or mitigated on the development site.
TOPIC: WATER SUPPLY & HYDROLOGY

  42.   July 9,      SLRD      It is recommended that flow records for Brohm River and tributaries be Northwest Hydraulics Consultants has installed flow           GAS commits to continue to work with
        2007                   gathered and integrated into the application. (The Stawamus is currently used monitoring stations at the two diversion locations     government agencies to finalize water
                               as basis for extrapolating Brohm River flow records).                         and at the upper and lower limits of fish. The first   demand and supply requirements, and
                                                                                                             year of flow information from this monitoring          as required to meet the water licensing
        January 7,             SLRD notes that the proposed action adequately addresses the SLRD issue program was provided in early February 2009. The             requirements.
        2010                   regarding water supply.                                                       draft hydrology and modeling reports were submitted
                                                                                                             in Addendum 3 submitted to the EAO in early
                                                                                                             February 2009. These reports were updated and
                                                                                                             submitted in June 2009.

  43.   July 9,      SLRD      Who will fund and manage the education programs for minimizing impacts to GAS will fund education programs for minimizing GAS commits to fund environmental
        2007                   the watershed?                                                            impacts to the watershed.                       education programs for minimizing
                                                                                                                                                         impacts to the watershed.

  44.   August 28,   DOS       Both the water source and the consumption appear to be inadequate to the GAS has provided an updated hydrology report, and GAS commits to continue to work with
        2007                   needs of the development. The proposed 220 liters per person per day is a 20-year model of water demand/supply based on a government agencies to finalize water
                               unlikely to satisfy the requirements of the project.                         water demand of 600 l/person/day.                 demand and supply requirements, and
                                                                                                                                                              as required to meet the water licensing
                                                                                                            The hydrology and modeling reports were submitted requirements.
        December               District water rate has been applied however other concerns expressed by the in the Addendum 3 materials submitted to the EAO
        10, 2009               District, such as average occupancy rates have not been addressed.           in early February 2009.

                                                                                                               GAS subsequently reviewed and revised the water
                                                                                                               demand and water storage needs in a report
                                                                                                               submitted to EAO, dated November 17th, 2009,
                                                                                                               where Urban Systems recalculated water demand
                                                                                                               based on the daily water usage rate of 455 Lpcd,
                                                                                                               which is the rate required for water supply by the
                                                                                                               District of Squamish (DOS) in its subdivision and
                                                                                                               development servicing bylaw. That water demand
                                                                                                               estimate considered water requirements for golf
                                                                                                               course and yard irrigation, fire fighting and
                                                                                                               snowmaking. EAO circulated that report to the
                                                                                                               working group members and GAS provided that
                                                                                                               report to the Squamish Nation November 20, 2009.

  45.   August 10,   SLRD      SLRD requires that the water system be designed to accommodate 600 Northwest Hydraulics Consultants has installed flow
        2007                   L/person/day. GAS is proposing a design standard of 220 L/person/day. If monitoring stations at the two diversion locations GAS commits to continue to work with
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                               water supply to SLRD servicing standards cannot be adequately and at the upper and lower limits of fish. The first                   government agencies to finalize water
                               demonstrated, the project will need to be adjusted to take this into account. year of flow information from this monitoring          demand and supply requirements, and
        January 7,                                                                                           program was provided in early February 2009. The       as required to meet the water licensing
                               SLRD confirmation of adequate water supply issues can adequately be hydrology and modeling reports were submitted in                 requirements.
        2010                   addressed at OCP/rezoning and water licensing stages.                         Addendum 3 submitted to the EAO in early February
                                                                                                             2009.
                                                                                                             The new modeling used the SLRD per capita water
                                                                                                             demands. The modeling results indicate that there is
                                                                                                             sufficient  water    to    provide     the     total
                                                                                                             potable/snowmaking demand at full build-out.

                                                                                                               GAS subsequently reviewed and revised the
                                                                                                               water demand and water storage needs in a
                                                                                                               report submitted to EAO, dated November 17th,
                                                                                                               2009, where Urban Systems recalculated water
                                                                                                               demand based on the daily water usage rate of
                                                                                                               455 Lpcd, which is the rate required for water
                                                                                                               supply by the District of Squamish (DOS) in its
                                                                                                               subdivision and development servicing bylaw.
                                                                                                               That water demand estimate considered water
                                                                                                               requirements for golf course and yard irrigation,
                                                                                                               fire fighting and snowmaking. EAO circulated
                                                                                                               that report to the working group members and
                                                                                                               GAS provided that report to the Squamish
                                                                                                               Nation November 20, 2009.

  46.   August 10,   SLRD      The water supply has not been proven. The flow of Brohm Creek is The hydrology and modeling reports were submitted                   GAS commits to continue to work with
        2007                   extrapolated from other creeks in the region, which does not provide the SLRD in Addendum 3 submitted to the EAO in early            government agencies to finalize water
                               with the certainty of water supply that is required.                          February 2009. Regional flow analysis is standard      demand and supply requirements, and
                                                                                                             practice for evaluating flows in ungauged rivers.      as required to meet the water licensing
        January 7,             SLRD confirmation of adequate water supply issues can adequately be GAS provided additional modeling information of                  requirements.
        2010                   addressed at OCP/rezoning and water licensing stages.                         water supply/demand and collection of one year’s
                                                                                                             flow data from the diversion points and lower Brohm    GAS commits to continue to collect
                                                                                                             River.                                                 stream flow data as long as required.

  47.   July 5,      SLRD      The SLRD raised water as a serious problem because the proponents are           GAS has provided an updated hydrology report, and .
        2007                   modeling their water system on 220 litres per person per day. The DOS share     a 20-year model of water demand/supply based on a
                               the concerns expressed by the SLRD. The SLRD servicing bylaw requires 600       water demand of 650 l/person/day.
        August 28,   DOS       litres per person per day as a design standard and our engineering department
        2007                   advises that our standard is 455 litres with peak demand of 1000 litres. The    The draft hydrology and modeling reports were
                               issue is basically that the SLRD and the DOS do not at this time support a      submitted in the Addendum 3 materials submitted to
                               variance from our standards that would support the level of water supply        the EAO in early February 2009. With the interim
                               described by Garibaldi at Squamish. All made recommendations that for the       hydrology and modeling report was submitted in
                               purposes of the EA process, an established standard must be the                 June 2009.
                               requirement.‘                                                                   GAS subsequently reviewed and revised the water
                                                                                                               demand and water storage needs in a report
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                                   The relevant sections of SLRD or DOS Bylaw pertaining to water and       submitted to EAO, dated November 17th, 2009,
                     DOS           wastewater flows should be used for assessing the adequacy of the water  where Urban Systems recalculated water demand
        December                   supply. District water rate has been applied however other concerns expressed
                                                                                                            based on the daily water usage rate of 455 Lpcd,
        10, 2009                   by the District, such as average occupancy rates have not been addressed which is the rate required for water supply by the
                                                                                                            District of Squamish (DOS) in its subdivision and
        January 7,   SLRD                                                                                   development servicing bylaw. That water demand
        2009                       A commitment from GAS to comply with DOS subdivision and development estimate considered water requirements for golf
                                   servicing bylaw adequately addresses the concern of SLRD with respect to course and yard irrigation, fire fighting and
                                   water system design criteria. If the project is developed under SLRD snowmaking. EAO circulated that report to the
                                   jurisdiction SLRD standards would apply.                                 working group members and GAS provided that
                                                                                                            report to the Squamish Nation November 20, 2009.



  48.   August 30,   Ministry of   The assumption is made that a water license on the Cheekye River is inactive,         At the time of the report, fees for this license had not GAS commits to notify all Cheekeye
        2007         Environmen    but WSD’s Water License Information System (WLIS) shows it as current. If a           been paid in six years. However, the current River water licensees, if GAS applies
                     t, Water      water license is shown as current according to WSD records such as WLIS or            licensee will be notified along with any other for a license on the Cheekeye River.
                     Stewardship   the BC Water Resources Atlas, then it must be treated as active; all                  licensees.
                     Division      downstream licensees will need to be notified and all management plans for
                     (MOE –        the area considered.
                     WSD)

  49.   August 30,   MOE –         The proponent should be aware of the contents of the Sea-to-Sky Land and The Sea-to-Sky LRMP was reviewed during
        2007         WSD           Resource Management Plan as it contains planning direction for resource use, preparation of the Draft Master Plan/EAO Additional
                                   water, wildlife and recreation in the project application area.              Information     Requirements,     and    applicable
                                                                                                                recommendations were incorporated into the
                                                                                                                mitigation measures.

  50.   August 30,   MOE –         Insufficient information has been provided to meet WSD’s application                  Thurber Engineering provided updated information        GAS commits to providing detailed
        2007         WSD           requirements for a dam or fully evaluate their environmental impacts, at this         on all dam structures and locations.             This   information on dam structures as
                                   time. The information that should be provided for a water license application         information was forwarded to MOE and DFO.               required during the Water Licensing
                                   (i.e., including a dam) and to complete a full review is outlined in the Ministry’s   Detailed information on dam structures will be          process.
                                   guidebook on Plan Submission Requirements for the Construction and                    provided to the approving government agencies
                                   Rehabilitation of Dams.                                                               during the final water licensing review process.

        December                   Application information requirements for review of major dams (> 9-metres)
        18, 2010                   can be found at MOE website:
                                   http://www.env.gov.bc.ca/wsd/public_safety/dam_safety/index.html

  51.   September    MOE –         Need reference to documented proof of water use (volumes and timing) in Each resort’s needs are unique and thus it is difficult
        12, 2007     Environmen    local resort communities similar to that proposed for the Garibaldi to document volumes and timing from “similar”
        and          tal           development.                                                            resorts. Nonetheless, the updated interim report
        February     Stewardship                                                                           “Brohm River Watershed Long-Term Hydrologic
        25, 2009     Division                                                                              Analysis (May 2009)” includes reference to a study
                     (ESD)                                                                                 by Alpine Water Management of water use at Sun
                                                                                                           Peaks Resort near Kamloops.
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                                                                                                               The justification for using 220 L/person/day + 40
                                                                                                               L/person/day is based on implementing an
                                                                                                               aggressive water conservation program, which
        July 3,                                                                                                affects every home, business and lot in the
        2009                    MOE-ESD agreed with GAS Inc. response.                                         development.      These low per capita rates have
                                                                                                               been demonstrated at Sun Peaks Resort, where
                                                                                                               they have had control since the start of development
                                                                                                               over their water conservation program. Sun Peaks
                                                                                                               has undertaken detailed water audits of their hotels,
                                                                                                               townhomes, single-family homes and commercial
                                                                                                               properties over the past number of years. These
                                                                                                               audits (e.g., Alpine Water Management (2003))
                                                                                                               confirm the use of 216 L/BU/d with water the
                                                                                                               conservation fixtures planned for GAS.            The
                                                                                                               Comptroller of Water Rights has accepted Sun
                                                                                                               Peaks' water modeling on the basis of 216 L/BU/d
                                                                                                               for water use. This value of 216 L/BU/d includes the
                                                                                                               contribution from day skiers and day users which
                                                                                                               they have estimated to be 5 Lpcd. It is also inclusive
                                                                                                               of all commercial (restaurants, stores, etc.) and
                                                                                                               requirements at the water treatment and sewage
                                                                                                               treatment plants.

  52.   September   MOE – ESD   Need analysis of hydrologic data on a finer temporal scale (e.g. daily) and for The hydrology and modeling reports were submitted       GAS commits to continue to collect
        12, 2007                more extreme events (e.g. droughts), rather than mean monthly flow and in Addendum 3, in draft, submitted to the EAO in                 stream flow data as long as required
                                average conditions                                                              early February 2009. The flow data collected by         and GAS commits to continue to work
                                                                                                                Northwest Hydraulics and the 20 year modeling           with government agencies to finalize
                                                                                                                results from Urban Systems including information on     water      demand       and     supply
                                                                                                                water demand were provided to the EAO in                requirements, and as required to meet
                                                                                                                February 2009 as part of the Addendum 3. The 20         the water licensing requirements.
                                                                                                                year flow modeling includes daily hydrological data
                                                                                                                and extreme events.

                                                                                                              Upon verification of the hydrologic model in fall
                                                                                                              2009, additional analysis of instream flow conditions
        February                                                                                              will be provided. [EAO Note: This information has
        25, 2009                                                                                              not been submitted at this time] GAS Inc. has
                                Need expression of water use on a finer temporal scale (e.g. daily or weekly) committed to a “flow, ecological and geomorphic
                                and for more extreme events (e.g. droughts), rather than as a proportion of data collection program as part of the on-going
                                Mean Annual Discharge (MAD), Mean Monthly Discharge (MMD) or other review in the water licensing approval process. The
                                average conditions.                                                           proposed program has been designed considering
                                                                                                              recommendations for proposals to withdraw or divert
                                                                                                              water as discussed in Lewis et al. (2004) and
                                                                                                              Hatfield et al. (2007).
        July 3,
        2009
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                                MOE reiterated the opinion that the information submitted to date by the
                                applicant has not been adequate to meet the Project Specifications for the
                                purpose of Certification.

  53.   February    MOE – ESD   Comments on Addendum #3 material:                                                 Additional error analysis for the hydrologic model is    GAS commits to continue to collect
        25, 2009                MOE-ESD notes that Issue#52 above sought “analysis of hydrologic data on a        now included in the Updated USL Interim Report           stream flow data as long as required
                                finer temporal scale (e.g. daily) and for more extreme events (e.g. droughts)     (May 2009); further analysis and reporting will be       and GAS commits to continue to work
                                rather than mean monthly flow and average conditions”. Work completed for         added to the Final Report, upon verification of the      with government agencies to finalize
                                NHCL (2009) & USL (2009) could have generated and presented such data,            model in fall 2009 [EAO Note: This information has       water      demand       and     supply
                                but did not do so. USL (2009) simply presents averaged daily flows (Figure        not been submitted at this time]                         requirements, and as required to meet
                                5.8) with no consideration of low flows. Flow duration curves (from daily                                                                  the water licensing requirements.
                                synthetic records) could have allowed 2007-08 stream flow data (from NHCL,        Finer temporal scale flow data exists (at a 15-min
                                2009) to be put into longer-term context. Likewise, error analyses which could    interval) for each station, and flow duration curves
                                have quantified the uncertainty of stream flow estimates provided in USL          and analysis for the finer temporal scale can be
                                (2009) & NHCL (2009) are absent. As such, MOE-ESD cannot assess the               provided. Error analysis to quantify the uncertainty
                                effect of NHCL (2009) basing its rating curves on relatively few discharge        of stream flow estimates was partially addressed
                                measurements (four rather than the ten advised in hydrometric guidelines such     through indication of the levels at which flows have
                                as LWBC, 2005). Likewise, the effect of a 35% measurement error in low flow       been extrapolated outside of the measured range;
                                discharge measurements (e.g. Sept. 17 2008 data in Tables 3&4 of NHCL,            however, a more detailed error analysis may be
                                2009) or critical model inputs (e.g. precipitation) is not quantified in any      provided. A total of 4-6 discharge measurements
                                analysis of modeling uncertainty in USL (2009). Graphs of predicted vs.           have been made at each station and more flows will
                                observed stream flows or outlier plots (%error as a function of discharge)        be obtained during a higher flow period. It must be
                                would supplement model assessment.                                                noted that freshet flows for this year (2009) are
                                                                                                                  below average and adequately high flows could not
                                                                                                                  be obtained. [EAO note: see also #121 below for
                                                                                                                  responses to DOS comments on hydrologic data].
        July 3,
        2009
                                MOE-ESD commented that it is understood that additional hydrometric data is
                                being collected and ongoing analyses will be submitted. The EAO must
                                determine the adequacy of information submitted to date for the purposes of
                                certification.

  54.   September   MOE – ESD   Need to use guidelines for the collection and analysis of fish and fish habitat As described in Volume 7, page 3-15, ENKON                 GAS commits to collecting additional
        12, 2007                data specific to consideration of impacts associated with flow withdrawal in followed the procedures outlined in the Fish Habitat          biological and hydrological data as
                                steep cobble and boulder-laden streams such as Hatfield et al., 2007.             Assessment Procedures (Ministry of Environment,          required as part of the water licensing
                                                                                                                  Lands and Parks and Ministry of Forests, 1996), the      process.
        February                                                                                                  parameters listed on the DFO/MOE stream survey
                                             th
        25, 2009                February 25 comment: MOE-ESD concurred with application’s proposed forms, and the recommendations included in the
                                actions. Issue sufficiently addressed for purpose of EA based on information Fish Stream Identification Guidebook (FPC/MELP,
                                provided in Addendum 3 but additional information may be provided at a later 1995) and Reconnaissance (1:20,000) Fish and Fish
                                date – “additional biological & hydrological data will be provided as part of the Habitat Inventory: Standards and Procedures
                                water licensing process, if required.                                             (MELP, 1997) to assess fish habitat in the study
                                                                                                                  area, including Brohm River and the two diversion
                                                                                                                  tributaries. These procedures are recommended in
                                                                                                                  Hatfield et al. (2007). In addition, potential impacts
                                                                                                                  to Brohm River fish populations were assessed
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                                                                                                                according to the requirements of the BC Instream
                                                                                                                Flow Guidelines.

                                                                                                                The flow data collected by Northwest Hydraulics and
                                                                                                                the 20-year modeling results from Urban Systems
                                                                                                                were provided to the EAO in February 2009 as part
                                                                                                                of the Addendum 3 materials. The 20-year flow
                                                                                                                modeling includes daily hydrological data and
                                                                                                                extreme events.

                                                                                                                The 20-year modeling results indicate that there is
                                                                                                                sufficient     water    to     provide     the     total
                                                                                                                potable/snowmaking demand at full build-out and
                                                                                                                still provide more than sufficient flows to protect fish
                                                                                                                populations according to the BC Instream Flow
                                                                                                                Guidelines requirements. The new modeling also
                                                                                                                used the higher SLRD per capita water demands to
                                                                                                                assess potential impacts on Brohm River fish
                                                                                                                populations.

  55.   September   MOE – ESD   Need a minimum of one year (preferably more) onsite collection of discharge     The hydrology and modeling reports were submitted          GAS commits to continue to collect
        12, 2007                data for streams to be impacted by proposed flow withdrawal, including the      in Addendum 3 submitted to the EAO in early                stream flow data as long as required
                                proposed sites of flow withdrawal and receiving streams downstream such as      February 2009 and the final NHC report was                 and to collecting additional biological
                                Brohm and Brook Creeks. Such onsite data is also requisite input for Issues     submitted in June 2009.                                    data as required as part of the water
                                #12 to #19 (refers to Project Report Specifications).                                                                                      licensing process.
        February                                                                                                Northwest Hydraulics Consultants installed flow
        25, 2009                February 25th comment: Issue sufficiently addressed for purpose of EA based     monitoring stations at the two diversion locations
                                on information provided in Addendum 3 but additional information may be         and at the upper and lower limits of fish in Brohm
                                provided at a later date – “additional biological & hydrological data will be   River in August/September 2007.          Northwest
                                provided as part of the water licensing process, if required.                   Hydraulics provided the one-year stream flow data
                                                                                                                to the Water Supply Working Group in November
                                                                                                                2008.

  56.   September   MOE – ESD   Need a more careful consideration of potential effects to the stream systems in GAS has provided an updated hydrology report that          GAS commits to continue to collect
        12, 2007                the watershed where withdrawal of surface water is proposed; Section 4.1.5.3 analyzed potential fish habitat impacts based on              stream flow data as long as required
                                of Volume 4 ENKON (2003) is cursory, and includes little detail.                water conservation use demand (260 L/person/day)           by government agencies to protect
        February                                                                                                and DOS’s and the SLRD bylaw volume of 455-650             water quality, fisheries or fisheries
        25, 2009                MOE-ESD does not concur with applicants’ proposal that outstanding items L/person/day. The study followed BC Instream Flow                 habitat, or in accordance with the
                                related to the issue be deferred to a post-EA certificate stage; this is not Guidelines and showed no impacts to fish habitat              water license requirements.
                                congruent with the information requirements explicitly described in the EAO’s from withdrawing either volume of water.
        July 3,                 Project Specifications.                                                                                                                    GAS commits to collecting additional
        2009                                                                                                                                                               biological data as required as part of
                                MOE reiterated the opinion that the information submitted to date by the                                                                   the water licensing process.
                                applicant has not been adequate to meet the Project Specifications for the
                                purpose of Certification.

                                [EAO note: MOE-WSD commented that it is not clear if the “no impact” is
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                                based on a controlled timing of flow diversion (calendar dates) or a flow
                                threshold diversion rule (flow volume). These diversion rules have been
                                proposed, but they have not been reviewed and approved. Before the
                                issuance of a water license GAS needs to decide on diversion rule to use.]

  57.   September   MOE – ESD   The instream flow assessment and associated data used to support the See GAS response to #56 above.                                         GAS commits to continue to collect
        12, 2007                proposed instream flow requirements (IFR) is not of sufficient site-specific                                                                stream flow data as long as required
                                detail to support the ENKON (2003) conclusion that downstream impacts to                                                                    by government agencies to protect
                                fish and fish habitat will be negligible. Most information requested in the MOE                                                             water quality, fisheries or fisheries
                                instream flow guidelines (e.g. Hatfield et al., 2003 & 2007; Lewis et al., 2004) is                                                         habitat, or in accordance with the
                                not provided in ENKON (2003). Some information may be generated via                                                                         water license requirements.
                                analysis of data described in ENKON (2003), but many unresolved aspects will
        February                require additional data collection and analysis.
        25, 2009
                                February 25th comment: MOE noted that the GAS believes that the issue
                                raised here was sufficiently addressed for purpose of EA based on information
                                provided in Addendum 3 but additional information may be provided at a later
                                date – “additional biological & hydrological data will be provided as part of the
                                water licensing process, if required. MOE reiterated that there needs to be an
                                assessment of baseline conditions and effects of project on stream flow
                                periods (e.g. duration and magnitude) during low flow periods within fish-
                                bearing portions of streams and their effects on water temperature and this
                                applies to the comment in the paragraph above.

                                MOE-ESD does not concur with applicants’ proposal that outstanding items
        July 3,                 related to the issue be deferred to a post-EA certificate stage; this is not
        2009                    congruent with the information requirements explicitly described in the EAO’s
                                Project Specifications.

                                MOE reiterated the opinion that the information submitted to date by the
                                applicant has not been adequate to meet the Project Specifications for the
                                purpose of Certification.


  58.   September   MOE – ESD   Section 10, Volume 7 of ENKON (2003) includes general consideration of              There will be very little development in the Culliton
        12, 2007                culvert sizing (‘increase diameter by a factor of four’) in light of debris flow    Creek watershed. Hence, flooding and/or debris
                                conditions, but no detailed consideration of increased downstream risk of           torrents are not expected to increase over baseline
                                flooding or debris torrents in Culliton and Brohm Creek resulting from upstream     conditions. Mitigation measures will prevent flooding
        February                development-related impacts.                                                        and debris torrents as a result of development in the
        25, 2009                                                                                                    Brohm River watershed. (See GASresponse to #59
                                MOE noted that no further action was required for this comment.                     for details on the mitigation measures).

  59.   September   MOE – ESD   Changes to the natural hydrology and sediment transport of the streams              Volume 7 Environmental Impact Assessment
                                                                                                                                                                            GAS commits to developing a
        12, 2007                potentially impacted by the proposed development, in terms of peak flows for        Sections 8.0 Hydrology Impacts and Mitigation
                                                                                                                                                                            stormwater management plan and
                                drainage design and development (e.g. timber clearing & changes to surface          provides an assessment of impacts on hydrology
                                                                                                                                                                            Watershed Protection Plan during the
                                permeability), are considered in a general sense, but with little specific          from site development and recommends mitigation
                                                                                                                                                                            detailed design phase of the Project,
        February                consideration of onsite conditions.                                                 measures to reduce/minimize impacts including
                                                                                                                                                                            which will be provided to provincial
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        25, 2009                                                                                           impacts from tree clearing.                      and federal agencies for review and
                             MOE-ESD does not concur with applicants’ proposal that outstanding items                                                       comment, prior to construction.
                             related to the issue be deferred to a post-EA certificate stage; this is not In addition, the supplemental information GAS
        July 3, ,            congruent with the information requirements explicitly described in the EAO’s (2003) Section 19.0 Watershed Protection Plan
        2009                 Project Specifications.                                                       addresses development above the diversion points
                                                                                                           and protection of the potable water supply.
                             MOE reiterated the opinion that the information submitted to date by the
                             applicant has not been adequate to meet the Project Specifications for the GAS provided an addendum stormwater report
                             purpose of Certification.                                                     (McElhanney October 2008: revised January 2009)
                                                                                                           that outlined global performance targets and the
                                                                                                           water balance modeling process, as per the new
                                                                                                           approach described as “Beyond the Guidebook.”
                                                                                                           This report was submitted to the EAO in February
                                                                                                           2009 as part of the Addendum 3 materials.

                                                                                                        In addition, Sections 18.0 Water Management Plan,
                                                                                                        Section 19.0 Watershed Protection Plan GAS’s
                                                                                                        original stormwater management planning (April
                                                                                                        2003) indicated that future systems would comply
                                                                                                        with the Stormwater Guidebook for the Province of
                                                                                                        British Columbia. However, subsequent to the
                                                                                                        submission of the initial documents a new approach
                                                                                                        has been developed and endorsed by several
                                                                                                        reviewing agencies. The new approach has been
                                                                                                        labelled “Beyond the Guidebook. The new approach
                                                                                                        described as “Beyond the Guidebook” is founded
                                                                                                        upon the principal of avoiding adverse impacts to
                                                                                                        aquatic environments through an analytical process
                                                                                                        that is based upon the best available scientific
                                                                                                        principles.
                                                                                                        GAS’s proposed 2008 stormwater planning process
                                                                                                        incorporated the new approach to stormwater
                                                                                                        management as described in “Beyond the
                                                                                                        Guidebook” and involves establishing targets that
                                                                                                        would be implemented during the detailed design
                                                                                                        process. Targets include matching:
                                                                                                        1. Pre and post development runoff volumes,
                                                                                                        2. Pre and post flow durations,
                                                                                                        3. Pre and post discharges for a range of return
                                                                                                           periods or flood frequency,
                                                                                                        4. Pre and post stream habitat availability,
                                                                                                        5. Pre and post water quality; and
                                                                                                        6. Pre and Post stream erosion potential.
                                                                                                        The effects upon the streams caused by the
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                                                                                                                     alteration of each of these areas, individually and
                                                                                                                     cumulatively, will be assessed and documented.
                                                                                                                     The identified impacts will then be reduced and
                                                                                                                     wherever possibly eliminated with the application of
                                                                                                                     Low Impact Development and construction
                                                                                                                     techniques.     The initial stormwater/watershed
                                                                                                                     management planning will identify:
                                                                                                                         •   Pre-existing conditions
                                                                                                                         •   Potential impacts,
                                                                                                                         •   Mitigation measures,
                                                                                                                         •   Sizing and operational requirements of
                                                                                                                             proposed      Low    Impact   Development
                                                                                                                             techniques.
                                                                                                                         •   Detailed design would follow with the
                                                                                                                             inclusion of the works necessary to mitigate
                                                                                                                             potential impacts.

  60.   February    MOE - ESD   Comments on Addendum #3 documents:                                                   Sediment source and transport will be assessed as      GAS Inc. commits to assess sediment
        25, 2009                There is a degree of subjectivity involved with assessing the adequacy of            part of the detailed geomorphologic field surveys      source and transport as part of the
                                information provided in an application when Project Specifications direct the        during the on-going water license approval process     detailed geomorphologic field surveys
                                applicant to „examine the impact of… without explicit reference to dependent         review.                                                during the on-going water license
                                variables (to define the impact) or associated guidelines (for data collection &                                                            approval process review.
                                analysis). For example, one may conclude that a „future conditions’ model
                                (described in Appendix A of USL, 2009) which considers stream routing
                                (including surface permeability and infiltration, etc. as per Issues #56 & 59) and
                                develops water yield estimates would adequately address impact assessment
                                from a hydrological perspective. However, the absence of specific information
                                requested in the Project Specifications (e.g. sediment transport data) requires
                                professional opinion regarding the significance of such information
                                deficiencies. EEL (2009a) includes such opinion: “It is recommended that a
                                watershed level assessment of road deactivation and sediment sources be
                                undertaken to assess potential risks to landslide and debris flow initiation”
                                (p.24). Such risk assessment was not undertaken by NHCL (2009), USL
        July 3,                 (2009) or EEL (2009a).
        2009
                                MOE reiterated the opinion that the information submitted to date by the
                                applicant has not been adequate to meet the Project Specifications for the
                                purpose of Certification.

  61.   September               Need 200-year peak stream flow estimates, and an assessment of related               100-year flood flows were estimated, as this is the    GAS commits to continue to collect
        12, 2007                impacts. Similarly, analysis of watercourses impacted by the proposed project        standard for drainage design, but the road engineers   stream flow data as long as required
                                (i.e. floodplain and flood issues both at the site and downstream) using existing    recommended increasing these flows by a factor of      by government agencies to protect
                                hydrological and meteorological information is absent.                               four to simulate debris flow conditions and to         water quality, fisheries or fisheries
                                                                                                                     estimate the hydraulic capacity of the stream          habitat, or in accordance with the
                                                                                                                     crossings. Information on larger volume, longer        water license requirements.
                                                                                                                     return period floods was not necessary for the
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                                                                                                                       impact assessment because with the proposed
                                                                                                                       mitigation flood plain and flood issues are not
                                                                                                                       expected. The hydrology and modeling reports were
                                                                                                                       submitted in Addendum 3 submitted to the EAO in
                                                                                                                       early February 2009.

  62.   September   MOE – ESD   Need baseline geomorphic conditions, and the effects of altered peak flows on GAS provided an addendum stormwater report                        GAS commits to developing a
        12, 2007                fluvial geomorphological processes, sediment deposition and channel stability.(McElhanney October 2008: revised January 2009)                  stormwater management plan during
                                ENKON (2003) includes some geomorphic data in the fish habitat assessment     that outlined global performance targets and the                 the detailed design phase of the
                                (Section 3.4, Volume 7), and general statements of development-related        water balance modeling process, as per the new                   Project, which will be provided to
                                                                                                              approach described as “Beyond the Guidebook.”
                                impacts to channel properties (e.g. Section 8 of Volume 7), but not of sufficient                                                              provincial and federal agencies for
                                                                                                              GAS also provided a preliminary Geomorphological
                                detail to address the project report specification: “Assess baseline conditions                                                                review and comment, prior to
                                and effects of altered peak flows on channel-shaping fluvial geomorphological Impact Assessment of the reservoirs, water intakes,              construction.
                                processes, sediment deposition and channel stability.”                        stream crossings and forest harvest. These reports
        February                                                                                              were submitted to the EAO in February 2009 as part
        25, 2009                MOE-ESD does not concur with applicants’ proposal that outstanding items of the Addendum 3 materials.
                                related to the issue be deferred to a post-EA certificate stage; this is not
                                congruent with the information requirements explicitly described in the EAO’s See GAS response to #old 65 above on stormwater
        July 3,                 Project Specifications.                                                       management.
        2009
                                MOE reiterated the opinion that the information submitted to date by the
                                applicant has not been adequate to meet the Project Specifications for the
                                purpose of Certification.


  63.   February    MOE - ESD   Comments on Addendum #3 material:                                                      GAS Inc. has committed to a “flow, ecological and   GAS Inc. commits to a “flow,
        25, 2009                EEL (2009a) provides opinion on potential project-related impacts to                   geomorphic data collection program as part of the   ecological and geomorphic data
                                geomorphic and ecological processes, but this opinion is limited to desktop            on-going review in the water licensing approval     collection program as part of the on-
                                interpretation of existing terrain information and air photos, digital terrain model   process. In addition, GAS Inc. has committed to a   going review in the water licensing
                                analysis and ‘review of limited biophysical habitat information’. EEL (2009a)          long term monitoring program that would allow       approval process.        The proposed
                                provides full disclosure that “detailed assessment of the risk or direct evidence      statistically meaningful post diversion cause and   program      has      been   designed
                                of significant/catastrophic geomorphic processes have not been completed” (p.          effect relations to be established with ongoing     considering recommendations for
                                16) and “with the exception of overview habitat assessments completed for              development and flow withdrawal.                    proposals to withdraw or divert water
                                Brohm River, reach 5, below the proposed location of Reservoir No.5, no field                                                              as discussed in Lewis et al. (2004)
                                                                                                                       Both programs, include data collection and analysis
                                assessments in support of detailed descriptions of channel morphology and                                                                  and Hatfield et al. (2007).
                                                                                                                       specific to the following components:
                                assessment of geomorphic process have been completed” (p. 24 of EEL,
                                2009a). Information required to assess the significance of flow diversions on                 •   hydrology;
                                the morphology and ecological processes downstream from the points of                         •   geomorphology;
                                diversion are clearly described on p.15 of EEL (2009a) [Enkon Environmental                   •   water quality;
        July 3,                 Ltd. “Preliminary Overview-Level Geomorphological Impact Assessment;                          •   fish and fish habitat; and
        2009                    Reservoirs, Water Intakes, Stream Crossings & Forest Harvest” February                        •   benthic invertebrates.
                                2009].
                                                                                                                       The proposed programs have been designed
                                MOE-ESD commented that it is understood that additional hydrometric data is            considering recommendations for proposals to
                                being collected and ongoing analyses will be submitted. The EAO must                   withdraw or divert water as discussed in Lewis et al.
                                determine the adequacy of information submitted to date for the purposes of            (2004) and Hatfield et al. (2007).
                                certification.
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                                                                                                                   Sediment source and transport will be assessed as
                                                                                                                   part of the detailed geomorphologic field surveys
                                                                                                                   during the on-going water license approval process
                                                                                                                   review.

                                                                                                                   [EAO note: comments from EEL (2009a) p. 15:
                                                                                                                   “Modeling results completed by USL (2009) suggest
                                                                                                                   that water withdrawals typically will only be
                                                                                                                   conducted during freshet (May and June) when
                                                                                                                   flows are high.        Assessment of the potential
                                                                                                                   significance of flow diversions on the morphology
                                                                                                                   and ecological processes downstream from the
                                                                                                                   points of diversion will require detailed analysis of
                                                                                                                   the post-development instream flows downstream
                                                                                                                   from the points of diversion. Key questions to be
                                                                                                                   addressed include the return interval of effective
                                                                                                                   discharge, the antecedent conditions within the
                                                                                                                   channel, stability/mobility of channel substrate,
                                                                                                                   stability/mobility and function of debris jams, and the
                                                                                                                   potential hydrologic change associated with ski
                                                                                                                   resort development.”.
                                                                                                                   EAO note: December 2009 -

  64.   September   MOE – ESD   The potential of project components in the Cheakamus/Squamish River                        See GAS response to #65 and #67 above GAS commits to developing detailed
        12, 2007                drainage to contribute to runoff into streams or to require stream channel                 on stormwater management.             stormwater management plan during
                                modification are not considered rigorously, and do not follow any specific                                                       the detailed design phase of the
                                methodology.                                                                                                                     Project, which will be provided to
                                                                                                                                                                 provincial and federal agencies for
                                                                                                                                                                 review and comment, prior to
                                                                                                                                                                 construction.

  65.   September   MOE – ESD   Some mitigation measures to eliminate or reduce anticipated changes in peak See GAS response to #59 and #62 above on
                                                                                                                                                     GAS commits to developing detailed
        12, 2007                flow frequencies of the receiving waters (and the stream channel and riparian stormwater management.
                                                                                                                                                     stormwater management plans during
                                areas) are considered in several sections (8.3.4, 8.4.2, 10.3.2) of Volume 7 of
                                                                                                                                                     the detailed design phase of the
                                ENKON (2003), but the proposed mitigation is not put into site-specific context.
                                                                                                                                                     Project, which will be provided to
                                                                                                                                                     provincial and federal agencies for
                                                                                                                                                     review and comment, prior to
                                                                                                                                                     construction.

  66.   September   MOE – ESD                                                                             The flow data collected by Northwest Hydraulics and
                                Baseline conditions and effects of the project on stream flow (e.g. duration &                                                               GAS commits to continue to collect
        12, 2007                                                                                          the 20 year modeling results from Urban Systems
                                magnitude) during low flow periods in fish-bearing portions of streams and their                                                             stream flow data as long as required
        and                                                                                               that analyzed potential fish habitat impacts were
                                effect on water temperatures is considered briefly (Section 9.1.2.3, Volume 7                                                                by government agencies to protect
                                of ENKON, 2003) with no onsite data and only consideration of average (notprovided to the EAO in February 2009 as part of the                water quality, fisheries or fisheries
         February               extreme) low flows.                                                       Addendum 3. Prior to this GAS provided an updated                  habitat, or in accordance with the
        25, 2009                                                                                          hydrology report (2008) that analyzed potential fish               water license requirements, and to
                                Absence of objective and consistent consideration of instream flow needs habitat impacts based on water conservation use                     collect additional biological data as
                                downstream of proposed withdrawal sites, integrating reliable stream flow demand (260 L/person/day) and DOS’s and SLRD                       required as part of the water licensing
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                                estimates and documented water use (on a variety of temporal scales) with          bylaw volume of 455-650 L/person/day. The study       process.
                                species and life-stage specific requirements for sufficient water of suitable      followed BC Instream Flow Guidelines and showed       GAS Inc. commits to a “flow,
                                quantity and quality (including water temperature). [EAO note: this comment        no impacts to fish habitat from withdrawing either    ecological and geomorphic data
                                was reiterated in background to February 25, 2009 comments]                        volume of water. Meeting the guidelines should        collection program as part of the on-
                                                                                                                   ensure maintenance of instream temperature within     going review in the water licensing
                                February 25, 2009: MOE reiterated there needs to be an assessment of               an acceptable range. In addition, no water will be    approval process.     The proposed
                                baseline conditions and effects of project on stream flow periods (e.g. duration   withdrawn during the low flow periods, which will     program      has    been    designed
                                and magnitude) during low flow periods within fish-bearing portions of streams     further reduce the potential for effects on stream    considering recommendations for
                                and their effects on water temperature and this applies to the two comments        temperature.                                          proposals to withdraw or divert water
                                listed in the paragraphs above.                                                                                                          as discussed in Lewis et al. (2004)
                                                                                                                   Upon verification of the hydrologic model in fall and Hatfield et al. (2007).
                                February 25, 2009 MOE-ESD does not concur with applicants’ proposal that           2009, additional analysis of instream flow conditions
                                outstanding items related to the issue be deferred to a post-EA certificate        will be provided [EAO Note: This information has not
        July 3,                 stage; this is not congruent with the information requirements explicitly          been submitted at this time].       Also, GAS has
        2009                    described in the EAO’s Project Specifications.                                     committed to a “flow, ecological and geomorphic
                                                                                                                   data collection program as part of the on-going
                                MOE reiterated the opinion that the information submitted to date by the           review in the water licensing approval process. The
                                applicant has not been adequate to meet the Project Specifications for the         proposed program has been designed considering
                                purpose of Certification.                                                          recommendations for proposals to withdraw or divert
                                                                                                                   water as discussed in Lewis et al. (2004) and
                                                                                                                   Hatfield et al. (2007).


  67.   September   MOE – ESD   Development of hydrologic estimates for small steep watersheds such as             GAS finalized the appropriate model (MIKE-SHE) to GAS commits to continue to collect
        12, 2007                those considered by ENKON (2003) would be more appropriately addressed             use with MOE in November 2008.                      stream flow data as long as required
                                using a semi-distributed hydrologic model such as the UBC Watershed Model.                                                             by government agencies to protect
                                Use of areal transfer methods (such as those adopted in ENKON, 2003) may           The flow data collected by Northwest Hydraulics and water quality, fisheries or fisheries
                                be justified if onsite flow data can be used to verify estimates; LWBC (2004)      the 20 year modeling results from Urban Systems habitat, or in accordance with the
                                provides criteria to do so.                                                        that used the MIKE-SHE model were provided to the water license requirements.
                                                                                                                   EAO in February 2009 as part of the Addendum 3
                                                                                                                   documents. The hydrology and modeling reports
                                                                                                                   were submitted in Addendum 3 submitted to the
                                                                                                                   EAO in early February 2009.


  68.   September   MOE – ESD   Many technical decisions do not follow well-documented objective criteria, and
                                                                                                                                                                        GAS commits to continue to collect
        12, 2007                may serve to overestimate water supply:                                          GAS finalized the appropriate model (MIKE-SHE) to
                                                                                                                                                                        stream flow data as long as required
                                                                                                                 use with MOE in November 2008.
                                   • Adoption of asymptotic (not simple linear) relations fitted to date for the                                                        by government agencies to protect
                                       (25-year) low flow analysis (Appendix A of Volume 4 ENKON, 2003);                                                                water quality, fisheries or fisheries
                                                                                                                 The flow data collected by Northwest Hydraulics and
                                                                                                                                                                        habitat, or in accordance with the
                                   • Stream flow estimates from the Stawamus WSC gauge (Appendix A of the 20 year modeling results from Urban Systems                   water license requirements..
                                       Volume 4 ENKON, 2003) must be carefully considered, particularly for that used the MIKE-SHE model were provided to the
                                       low flows;                                                                EAO in February 2009 as part of the Addendum 3
                                                                                                                 documents. The draft hydrology and modeling
                                   • Assumptions regarding negligible losses from demand, evaporation
                                                                                                                 reports were submitted in Addendum 3 submitted to
                                       and leakage (p. 83 of Volume 4 ENKON 2003).
                                                                                                                 the EAO in early February 2009 and the final and
                                                                                                                 interim version were submitted in June 2009.
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  69.   September     MOE – ESD   Withdrawal (or water demand) is considered as a proportion of stream flow in The original Urban Systems report (2003) estimated          GAS commits to continue to collect
        12, 2007                  Brohm River (e.g. Figure 4.6 in Appendix A of Volume 4 ENKON, 2003), rather effects on stream flows in the Brohm River                   stream flow data as long as required
                                  than the stream reach immediately downstream of the withdrawal site.         mainstem and in the two diversion tributaries. The          by government agencies to protect
                                                                                                               flow at the mouth of the Brohm River was used               water quality, fisheries or fisheries
                                                                                                               because the lower river is fish-bearing, whereas the        habitat, or in accordance with the
                                                                                                               reach immediately below the diversions is not. The          water license requirements.
                                                                                                               updated hydrology report estimates Brohm River
                                                                                                               flows at the upper limit of fish distribution in addition
                                                                                                               to the three sites evaluated previously.
                                                                                                                   The flow data collected by Northwest Hydraulics and
                                                                                                                   the 20 year modeling results from Urban Systems
                                                                                                                   were provided to the EAO in draft in February 2009
                                                                                                                   as part of the Addendum 3 documents. The final
                                                                                                                   and interim version of the these reports were
                                                                                                                   submitted in June 2009
                                                                                                                   GAS subsequently reviewed and revised the water
                                                                                                                   demand and water storage needs in a report
                                                                                                                   submitted to EAO, dated November 17th, 2009,
                                                                                                                   where Urban Systems recalculated water demand
                                                                                                                   based on the daily water usage rate of 455 Lpcd,
                                                                                                                   which is the rate required for water supply by the
                                                                                                                   District of Squamish (DOS) in its subdivision and
                                                                                                                   development servicing bylaw. That water demand
                                                                                                                   estimate considered water requirements for golf
                                                                                                                   course and yard irrigation, fire fighting and
                                                                                                                   snowmaking. EAO circulated that report to the
                                                                                                                   working group members and GAS provided that
                                                                                                                   report to the Squamish Nation November 20, 2009.

  70.   September     MOE – ESD   Baseline geomorphic conditions, and effects of altered peak flows on fluvial The channel assessment methodology was
        12, 2007                  geomorphological processes, sediment deposition and channel stability was    appropriate for describing fish habitat. It followed
                                  considered by ENKON (2003) as a component of the fish habitat assessment,    the procedures outlined in the Fish Habitat
                                  but should be specifically addressed using an appropriate methodology such   Assessment Procedures (MELP and MoF, 1996),
                                  as the Channel Assessment Procedure (MOF and MOELP, 1997).                   the parameters listed on the DFO/MOE stream
        February                                                                                               survey forms, and the recommendations included in
        25 and July               MOE reiterated the opinion that the information submitted to date by the the         Fish   Stream    Identification  Guidebook
        3, 2009                   applicant has not been adequate to meet the Project Specifications for the (FPC/MELP, 1995) and Reconnaissance (1:20,000)
                                  purpose of Certification.                                                    Fish and Fish Habitat Inventory: Standards and
                                  [EAO note: MOE noted that deficiencies related to this comment echo Item #62 Procedures (MELP, 1997).
                                  above and expanded upon in #71 below]]
                                                                                                               GAS provided an update on potential impacts to
                                                                                                               fluvial geomorphology in Addendum 3 which was
                                                                                                               submitted to the EAO in February 2009.
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  71.   February    MOE - ESD   Comments on Addendum #3 material:                                                 GAS Inc. has committed to a “flow, ecological and   GAS Inc. commits to a “flow,
        25, 2009                NHCL (2009), USL (2009) & EEL (2009a) and Enkon Environmental Limited             geomorphic data collection program as part of the   ecological and geomorphic data
                                (2009) GAS Project – Water License Monitoring Plan (EEL 2009b) do not             on-going review in the water licensing approval     collection program as part of the on-
                                include impact assessment related to project-related changes in dependent         process. In addition, GAS Inc. has committed to a   going review in the water licensing
                                variables identified in the Project Specifications for Issues #62 and #70 (e.g.   long term monitoring program that would allow       approval process.        The proposed
                                fluvial processes, sediment deposition & channel stability) and #61 (e.g. water   statistically meaningful post diversion cause and   program      has      been   designed
                                temperatures during low flows). Rather, these reports include some data that      effect relations to be established with ongoing     considering recommendations for
                                could be used in a future impact assessment;                                      development and flow withdrawal.                    proposals to withdraw or divert water
                                     • NHCL (2009) provides continuous data on stream flow and water              Both programs, include data collection and analysis
                                                                                                                                                                      as discussed in Lewis et al. (2004)
                                         temperature (for four stations within the watershed) for September                                                           and Hatfield et al. (2007).
                                                                                                                  specific to the following components:
                                         2007 to October 2009, and uses regional data to develop estimates of
                                         mean annual discharge for these stations. Regional data was also                • hydrology;
                                         used by NHCL (2009) to develop flood flows (at a variety of return              • geomorphology;
                                         periods) and 7-day low flows for the Brohm watershed.                           • water quality;
                                     • USL (2009) provides long-term hydrologic simulations of the Brohm                 • fish and fish habitat; and
                                         Riever Watershed, and uses the continuous stream flow data from
                                                                                                                         • benthic invertebrates.
                                         NHCL 92009) to calibrate its model. USL (2009) also develops
                                                                                                                  The proposed programs have been designed
                                         proposed instream flows based on the synthetic stream flow records
                                                                                                                  considering recommendations for proposals to
                                         using the ‘historic flow method’ described in Hatfield et al. (2003).
                                                                                                                  withdraw or divert water as discussed in Lewis et al.
                                                                                                                  (2004) and Hatfield et al. (2007).
        July 3,                 MOE-ESD commented that it is understood that additional hydrometric data is
        2009                    being collected and ongoing analyses will be submitted. The EAO must
                                determine the adequacy of information submitted to date for the purposes of
                                certification.

  72.   September   MOE – ESD   ENKON (2003) considers a series of instream flow methods that consider            The flow data collected by Northwest Hydraulics and     GAS commits to continue to collect
        12, 2007                proportions of flow metrics such as proportions of mean annual discharge          the 20 year modeling results from Urban Systems         stream flow data as long as required
        and                     (MAD) or mean monthly discharge (MMD) in Section 10.6.1 of Volume 4, but          that analyzed potential fish habitat impacts were       by government agencies to protect
        February                do not include a rigorous and detailed consideration of an instream flow regime   provided to the EAO in February 2009 as part of the     water quality, fisheries or fisheries
        25, 2009                sufficient to protect instream species and maintenance of ecological and          Addendum 3 documents. Prior to this GAS provided        habitat, or in accordance with the
                                physical processes.                                                               an updated hydrology report (2008) that analyzed        water license requirements, and to
                                                                                                                  potential fish habitat impacts based on water           collect additional biological data as
                                MOE 2009 comment: Regarding instream flows, MOE- ESD in 2007 concluded            conservation use demand (260 L/person/day) and          required as part of the water licensing
                                that the “natural flow regime‟ methodology (from Hatfield et al., 2003) used in   DOS’s and SLRD bylaw volume of 455-650                  process..
                                ENKON (2003) was not properly followed.              Although it is a “specific   L/person/day. The study followed BC Instream Flow
                                methodology to consistently estimate appropriate instream flows”, MOE (2007)      Guidelines and showed no impacts to fish habitat
                                warns that “no specific method will be ideal for every stream”.                   from withdrawing either volume of water. Meeting
                                                                                                                  the guidelines should ensure maintenance of
                                                                                                                  instream temperature within an acceptable range. In
                                                                                                                  addition, no water will be withdrawn during the low
                                                                                                                  flow periods, which will further reduce the potential
                                                                                                                  for effects on stream temperature.

        July 3,                                                                                         The updated interim report “Brohm River Watershed
        2009                    MOE-ESD agreed that the model has been calibrated, but not validated or Long-Term Hydrologic Analysis (May 2009)”
                                verified.                                                               provides data that does follow the Hatfield
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                                                                                                                     methodology, including computation of 20 years of
                                                                                                                     average daily stream flows using a calibrated
                                                                                                                     hydrologic model (MIKE SHE) (in lieu of 20 years of
                                                                                                                     instream measured flow data).


  73.   September   MOE – ESD   MOE promotes use of Lewis et al. (2004) Section 4.1.10.1, which describes a The flow data collected by Northwest Hydraulics and              GAS commits to continue to collect
        12, 2007                series of steps guiding proponents through the process of developing an     the 20 year modeling results from Urban Systems                  stream flow data as long as required
        and                     instream flow regime, regardless of the method adopted. The ten steps       that analyzed potential fish habitat impacts were                by government agencies to protect
        February                described in Section 4.1.10.1 of Lewis et al. (2004) ensures that review    provided to the EAO in February 2009 as part of the              water quality, fisheries or fisheries
        25, 2009                                                                                            Addendum 3. Prior to this GAS provided an updated
                                agencies get the basic requisite data, but leaves technical decisions on data                                                                habitat, or in accordance with the
                                                                                                            hydrology report (2008) that analyzed potential fish
                                interpretation up to the relevant professionals. Data necessary to completely                                                                water license requirements, and to
                                address these steps are not provided in ENKON (2003). Without such data, it habitat impacts based on water conserve*ation use                collect additional biological data as
                                is not possible to reasonably and reliably assess likely impacts from the   demand (260 L/person/day) and DOS’s and SLRD                     required as part of the water licensing
                                proposed flow regime, and estimate the likelihood that such impacts may be  bylaw volume of 455-650 L/person/day. The study                  process. GAS Inc. commits to a “flow,
                                mitigatible.                                                                followed BC Instream Flow Guidelines and showed                  ecological and geomorphic data
                                                                                                            no impacts to fish habitat from withdrawing either               collection program as part of the on-
        July 3,                                                                                             volume of water. Meeting the guidelines should                   going review in the water licensing
        2009                    MOE-ESD commented that it is understood that additional hydrometric data is ensure maintenance of instream temperature within                approval process.        The proposed
                                being collected and ongoing analyses will be submitted. The EAO must an acceptable range. In addition, no water will be                      program      has      been    designed
                                determine the adequacy of information submitted to date for the purposes of withdrawn during the low flow periods, which will                considering recommendations for
                                certification. .                                                            further reduce the potential for effects on stream               proposals to withdraw or divert water
                                                                                                            temperature.                                                     as discussed in Lewis et al. (2004)
                                                                                                                                                                             and Hatfield et al. (2007).
                                                                                                                     GAS has committed to a “flow, ecological and
                                                                                                                     geomorphic data collection program as part of the
                                                                                                                     on-going review in the water licensing approval
                                                                                                                     process. The proposed program has been designed
                                                                                                                     considering recommendations for proposals to
                                                                                                                     withdraw or divert water as discussed in Lewis et al.
                                                                                                                     (2004) and Hatfield et al. (2007).

  74.   February    MOE-ESD     Comments on Addendum #3 material:                                                    GAS has committed to a “flow, ecological and        GAS commits to a “flow, ecological
        25, 2009                MOE-WSD notes that Issue #73 above recommended development of an                     geomorphic data collection program as part of the   and geomorphic data collection
                                instream flow regime via the ten-step process described in Section 4.1.10.1 of       on-going review in the water licensing approval     program as part of the on-going review
                                Lewis et al. (2004). This general process was recommended over a specific            process. In addition, GAS Inc. has committed to a   in the water licensing approval
                                instream flow methodology (i.e. the Hatfield et al. (2003) method used in            long term monitoring program that would allow       process. The proposed program has
                                ENKON, 2003 and repeated in USL (2009)) since the proposed use of water in           statistically meaningful post diversion cause and   been        designed       considering
                                ENKON (2003) was not identical to the use implied in Hatfield et al. (2003):         effect relations to be established with ongoing     recommendations for proposals to
                                run-of-river (hydro) electricity generation. There are some similarities between     development and flow withdrawal.                    withdraw or divert water as discussed
                                an impact assessment that may be undertaken for a run-of-river electricity                                                               in Lewis et al. (2004) and Hatfield et
                                                                                                                     Both programs, include data collection and analysis
                                generation facility and the application considered by MOE-ESD in commenting                                                              al. (2007).
                                                                                                                     specific to the following components:
                                on the approaches: specific points of diversion are proposed, and one could
                                define a ‘diversion reach’ as the channel lengths from these diversion points to            •   hydrology;
                                some point downstream where project-related effects are negligible. As with                 •   geomorphology;
                                impact assessments associated with a run-of-river electricity generation facility,          •   water quality;
                                one could consider the likelihood and significance of changes in instream                   •   fish and fish habitat; and
                                physical habitat (e.g. using traditional metrics like riffle wetted-ness or
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                                weighted usable area), water „quality (e.g. temperature, pH, nutrients, etc.) or        • benthic invertebrates.
                                delivery of sediment, LWD & waterborne biota (e.g. fish food, such as
                                                                                                                 The proposed programs have been designed
                                invertebrates).
                                                                                                                 considering recommendations for proposals to
                                                                                                                 withdraw or divert water as discussed in Lewis et al.
                                However, there are additional complexities associated with water use as
                                                                                                                 (2004) and Hatfield et al. (2007).
                                proposed in the Application that are not typically considered in reviews of
                                proposed run-of-river electricity generation facilities (and are thus not
                                addressed by the instream flow methodology adopted in USL, 2009):
                                     • Diverted water will be stored in large (500,000-1,000,000 m3)
                                         reservoirs, and used for various purposes at various times of the year:
                                         The instream flow methodology should consider the significance of
                                         changes in stream flow timing (not just magnitude);
                                     • Some water may be returned to the „diversion reach‟ after use: the No water is to be returned to Brohm River as the
                                         instream flow methodology should consider the significance of treated wastewater will be discharged to the
                                         changes in specific water quality components (e.g. water temperature, Cheekye River as the preferred option, or the other
        July 3,                          pH, nutrients) associated with water storage & use.                     two options identified in the Application and
        2009                                                                                                     confirmed in GAS’letter correspondence to EAO
                                MOE-ESD commented that it is understood that additional hydrometric data is      dated July 20, 2009.
                                being collected and ongoing analyses will be submitted. The EAO must
                                determine the adequacy of information submitted to date for the purposes of
                                certification.

  75.   September   MOE – ESD   No specific post-development monitoring program is proposed; monitoring GAS provided a “draft” monitoring program for Water              GAS commits to continue to collect
        12, 2007                strategies are very general (e.g. Principle 8 of Section 10.3.2) and relatively Licensing as part of the Addendum 3 submitted to         stream flow data as long as required
        and                     vague. The operational program developed should include pre-diversion the EAO in February 2009.                                          by government agencies to protect
                                (‘baseline’) biological data such as fish abundance and benthic invertebrate                                                             water quality, fisheries or fisheries
                                (e.g. drift) that may be incorporated into an effectiveness monitoring plan that                                                         habitat, or in accordance with the
                                would allow statistically-meaningful post-diversion cause & effect relations to                                                          water license requirements, and to
                                be established with ongoing development and flow withdrawal.                                                                             collect additional biological data as
                                                                                                                                                                         required as part of the water licensing
        February                Issue sufficiently addressed for purpose of EA based on information provided                                                             process.
        25, 2009                in Addendum 3 but additional information may be provided at a later date –
                                “additional biological & hydrological data will be provided as part of the water
                                licensing process, if required”.

  76.   February    MOE-ESD     Comments on the Application and Addendum #3:                                                                                  GAS Inc. commits to a “flow,
                                                                                                                   GAS Inc. has committed to a “flow, ecological and
        25, 2009                MOE-ESD is of the opinion that clear differences exist between information                                                    ecological and geomorphic data
                                                                                                                   geomorphic data collection program as part of the
                                provided in the Application (ENKON, (2003) including Addendum 3) and the                                                      collection program as part of the on-
                                                                                                                   on-going review in the water licensing approval
                                project specifications listed in the Application. MOE-ESD suggests that Issue                                                 going review in the water licensing
                                                                                                                   process. In addition, GAS Inc. has committed to a
                                #66 provides the most obvious deficiency. For example, EEL (2009a) provides                                                   approval process.
                                                                                                                   long term monitoring program that would allow                       The proposed
                                professional opinion regarding the absence of work integrating proposed water                                                 program
                                                                                                                   statistically meaningful post diversion cause and       has      been   designed
                                use and onsite stream flow data with geomorphological and ecological                                                          considering recommendations for
                                                                                                                   effect relations to be established with ongoing
                                responses (as per Project Specifications listed in Section 4.1.1.1 (Volume 4) &    development and flow withdrawal.           proposals to withdraw or divert water
                                Section 8.0 (Volume 7) of ENKON, 2003).                                                                                       as discussed in Lewis et al. (2004)
                                                                                                          Both programs, include data collection and analysis and Hatfield et al. (2007).
                                MOE-ESD recommends that the EAO must resolve whether these deficiencies specific to the following components:
                                are considered within the scope of their EA certification review (MOE-ESD        • hydrology;
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                                 conclusion) (outstanding items relating to Issues #56, 57, 59, 62), or if they can          •   geomorphology;
                                 be deferred to a post-EA certificate stage as proposed by GAS.                              •   water quality;
                                                                                                                             •   fish and fish habitat; and
        July 3,                                                                                                              •   benthic invertebrates.
        2009                     MOE-ESD commented that it is understood that additional hydrometric data is
                                 being collected and ongoing analyses will be submitted. The EAO must                 The proposed programs have been designed
                                 determine the adequacy of information submitted to date for the purposes of          considering recommendations for proposals to
                                 certification.                                                                       withdraw or divert water as discussed in Lewis et al.
                                                                                                                      (2004) and Hatfield et al. (2007).

                                                                                                                      GAS is of the understanding that the adequacy of
                                                                                                                      the information provided by GAS including
                                                                                                                      addressing the “Project Specifications” sections in
                                                                                                                      the Application and the additional information
                                                                                                                      required by the EAO, is decided A by the EAO in
                                                                                                                      conjunction with input from the government
                                                                                                                      agencies.

  77.   February    MOE-ESD      Comments on Addendum #3 and the comments MOE-ESD raised on the                                                                  GAS Inc. commits to a “flow,
                                                                                                                      GAS Inc. has committed to a “flow, ecological and
        25, 2009                 Application:                                                                                                                    ecological and geomorphic data
                                                                                                                      geomorphic data collection program as part of the
                                 GAS Addendum report assessments that Issues #52 & #73 above have been                                                           collection program as part of the on-
                                                                                                                      on-going review in the water licensing approval
                                 adequately addressed in NHCL (2009), USL (2009) & EEL (2009a) is not                                                            going review in the water licensing
                                                                                                                      process. In addition, GAS Inc. has committed to a
                                 supported by information presented. Stream flow data and instream flow                                                          approval process.
                                                                                                                      long term monitoring program that would allow                       The proposed
                                 analyses do not consider the specific proposed water use (specifically the                                                      program
                                                                                                                      statistically meaningful post diversion cause and       has      been   designed
                                 effect of seasonal water storage on instream temperature & nutrients) and do                                                    considering recommendations for
                                                                                                                      effect relations to be established with ongoing
                                 not include effects of drought or estimates of uncertainty. In the absence of        development and flow withdrawal.           proposals to withdraw or divert water
                                 such information, MOE-ESD staff is unable to assess the likelihood of                                                           as discussed in Lewis et al. (2004)
                                                                                                             Both programs, include data collection and analysis
                                 significant adverse effects on fish & fish habitat related to the application.                                                  and Hatfield et al. (2007).
                                                                                                             specific to the following components:
                                 However, MOE-ESD reviewer remains unconvinced that application-related
        July 3,                  impacts to instream biota are negligible.                                           • hydrology;
        2009                                                                                                         • geomorphology;
                                 MOE-ESD commented that it is understood that additional hydrometric data is         • water quality;
                                 being collected and ongoing analyses will be submitted. The EAO must                • fish and fish habitat; and
                                 determine the adequacy of information submitted to date for the purposes of         • benthic invertebrates.
                                 certification.                                                              The proposed programs have been designed
                                                                                                                      considering recommendations for proposals to
                                                                                                                      withdraw or divert water as discussed in Lewis et al.
                                                                                                                      (2004) and Hatfield et al. (2007).

  78.   September   MOE – ESD    Various provincial and federal regulatory agencies (e.g. MOE -WSD and DFO) Comment noted.                                                    GAS commits to providing additional
        12, 2007                 are likely to have additional information requirements to meet their respective                                                              information, as required for the
                                 legislative responsibilities (i.e. water licensing under the Water Act, and HADD                                                             necessary permits, authorization and
                                 authorizations under the Fisheries Act).                                                                                                     approvals for the proposed Project.

  79.   November    Fisheries    DFO is of the opinion that the previously referenced methods should be used In August/September 2007, GAS initiated surface GAS commits to continue to collect
        27, 2007    and Oceans   with streamflow data from the proposed withdrawal sites (at least one year of flow monitoring at the two proposed water stream flow data as long as required
                    Canada       data). DFO will need this information/analysis in order to determine whether withdrawal diversion points and at the upper and by government agencies to protect
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                   (DFO)     these may require authorization under s.35(2) of the Fisheries Act, whether lower limits of fish in Lower Brohm River. The flow           water quality, fisheries or fisheries
                             DFO may be required to conduct an environmental assessment under CEAA, data collected by Northwest Hydraulics and the 20-                 habitat, or in accordance with the
                             and to determine the significance of any residual effects.                  year modeling results from Urban Systems were                 water license requirements, and to
                                                                                                         provided to the EAO in draft in February 2009 as              collect additional biological data as
                                                                                                         part of the Addendum 3 and the final and interim              required as part of the water licensing
                                                                                                         reports were submitted in June 2009.                          process.

  80.   December   MOE –     MOE-WSD disagrees with Urban Systems/GAS conclusions for the following GAS will meet the requirements of the “BC Instream                 GAS commits to continue to collect
        3, 2007    WSD       reasons:                                                                            Flow Threshold for Fish and Fish Habitat as           stream flow data as long as required
                                                                                                                 Guidelines for Reviewing Proposed Water Uses”         by government agencies to protect
                                  •      Inferred impacts were determined by comparing proposed (2004).                                                                water quality, fisheries or fisheries
                                         withdrawals with estimated flows at the upper limit of anadromous                                                             habitat, or in accordance with the
                                         fish (i.e., significantly downstream of the points of diversion) rather In August/September 2007, GAS initiated surface       water license requirements. .
                                         than at the points of diversion.                                        flow monitoring at the two proposed water
                                  •      The thresholds calculated were those for non-fish bearing streams withdrawal diversion points and at the upper and
                                         rather than fish-bearing, as might be more appropriate.                 lower limits of fish in Lower Brohm River. The flow
                                                                                                                 data collected by Northwest Hydraulics and the 20-
                                  •      The difference in annual hydrographs derived from both analysis
                                                                                                                 year modeling results from Urban Systems were
                                         methods suggests a significant uncertainty in understanding of the
                                                                                                                 provided to the EAO in draft in February 2009 as
                                         flow regime.
                                                                                                                 part of the Addendum 3 documents and the final and
                             MOE-WSD would suggest that the approach taken might be more reasonable interim reports were submitted in June 2009.
                             if the appropriate thresholds were determined at the appropriate locations, and See GAS response in old #80 above.
                             there was less uncertainty about the flow regime (e.g., if there at least one year
                             of on-site data to verify flow estimates). As such, MOE-WSD infer that the
                             information provided is currently inadequate to allow a reasonable assessment
                             of the environmental impacts of the proposed withdrawals.
                             MOE-WSD conclude that WSD’s concerns regarding the provision of
        December             representative hydrological data, and a suitable water supply – demand
        18, 2009             analyses (i.e., incorporating appropriate in-stream flow requirements) have not
                             been adequately addressed.

                             MOE-WSD comments on the additional November 2009 Water Supply Issues:
                             The November 2009 Plan can be broken into two systems: Brohm River (900-
                             097600-12900-03600-1780) and the East Brohm (900-097600-12900-03600-
                             1780-4830). The Brohm River consisting of Secondary Storage, Supplemental
                             Storage #2 and Snowmaking Storage #2. The East Brohm consisting of
                             Primary Storage and Supplemental Storage #1.

                             The supporting analyses should show at each point of diversion in the two
                             systems, Brohm River and the East Brohm, there is sufficient water, given the
                             timing of flows and the demands on water supply.

                             The existing hydrometric program was design for supporting the water licence
                             application for the Primary and Secondary Storage points of diversion. The
                             November 2009 Plan did not discussed if the hydrometric program would be
                             revised, or that the program would be expanded. The expansion review should
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                             be done with input from the Water Working Group, Department Fisheries and
                             Oceans, First Nations, MOE-Environmental Stewardship Division, and MOE-
                             Water Stewardship Division.

                             At all points of diversion or storage, the Instream Flow Requirements will
                             require review and approval by MOE-WSD, MOE-ESD, and DFO.

  81.   December   MOE –     GAS indicates that details on 'changes in and about streams' (e.g., crossings)       Assessment of crossing structures impacts was           GAS commits to providing additional
        3, 2007    WSD       will be provided as required for notification or approvals. WSD recommends          provided in Volume 7 Section 10.0 Fish Habitat           information, as required for the
                             that all design information be provided prior to EAO certification (and             Impacts and Proposed Mitigation Measures.                necessary permits, authorization and
                             subsequent MOE licensing/notification/approvals) to ensure that all potential       Additional information on dam structures and             approvals for the proposed Project
                             environmental impacts may be considered.                                            potential impacts to vegetation and wildlife was         and GAS commits to provide detailed
                                                                                                                 included in Addendums 1 and 2 which were                 design information for each phase of
                             Change in and about a Stream applications will need to clearly identify the         submitted to the EAO in October 2007 and January         development for review and approval
        December             stream crossings that are being submitting under a Water Act Notification,          2008. Addendum 3 contained a Preliminary Stream          by the regulatory agencies, prior to
        18, 2009             versus those requiring a Water Act Approval.           Plans will need to clearly   Crossing Impact Analysis of Garibaldi at Squamish        construction.
                             identify those streams that are within the debris flow criteria, and have been      Resort Project Ski Runs/Lifts and Golf Course
                             designed with a “factor of four” applied to the culvert diameter.                   Fairways.      On November 17, 2009 GAS Inc.
                                                                                                                 provided two supplemental reports on dam
                                                                                                                 structures and potential impacts to vegetation and
                                                                                                                 wildlife for water storage and reservoir options.
                                                                                                                 It is not possible to provide any further detailed
                                                                                                                 information on dam structures or road/ski trail
                                                                                                                 crossings as detailed topography and detailed
                                                                                                                 ground truthing/surveying of project facilities cannot
                                                                                                                 be completed at this level of assessment. Detailed
                                                                                                                 design information will be provided to the
                                                                                                                 appropriate regulatory agencies for each phase of
                                                                                                                 development prior to construction for review and
                                                                                                                 approval from these agencies.

  82.   December   MOE –     GAS’ has indicated that Water Quality Monitoring and Source Protection Plans        Volume 7 Sections 16-30 provide details on 12
                                                                                                                                                                       GAS commits to developing a Water
        3, 2007    WSD       will be developed and implemented as required for operating permits. At a           environmental management plans including water
                                                                                                                                                                      Quality   Monitoring and    Source
                             minimum, the proponent should provide more detail on the scopes of the plans        quality monitoring and source protection plans. GAS
                                                                                                                                                                      Protection Plans as required for
                             and specify when further development of the plans can be expected. WSD              provided a “draft” monitoring program as part of the
                                                                                                                                                                      permits.
                             reiterates that monitoring plans are fundamental to ensuring that environmental     Addendum 3 documents. This plan was developed
                             impacts are quantified and meet prescribed criteria.                                as a draft for review and comment by the regulatory
                                                                                                                 agencies and will supplement the existing
        December                                                                                                 management plans outlined in Section 16-30 of
        18, 2009             MOE-WSD further commented that this is a multi MOE division issue;                  Volume 7. GAS provided an addendum stormwater
                             monitoring plans are to be submitted to MOE-EPD/WSD/ESD for review and              report that outlined global performance targets and
                             approval. Water Quality issues are raised by MOE-EPD, while environmental           the water balance modeling process, as per the new
                             impacts associated with water diversions are issues raised by MOE-                  approach described as “Beyond the Guidebook.”
                             WSD/ESD.                                                                            This report (McElhanney October 2008: revised
                                                                                                                 January 2009) was submitted to the EAO in draft in
                                                                                                                 February 2009 as part of the Addendum 3
                                                                                                                 documents.
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  83.   December   MOE –     With regard to the GAS commitments pertaining to water, MOE-WSD note the GAS will meet the requirements of the “BC Instream                     GAS commits to meeting the
        3, 2007    WSD       following:                                                                           Flow Threshold for Fish and Fish Habitat as                requirements of the “BC Instream Flow
                                                                                                                  Guidelines for Reviewing Proposed Water Uses”              Threshold for Fish and Fish Habitat as
                                  • If GAS chooses to adopt minimum flow thresholds (i.e., calculated BC (2004).            If at any time GAS determines that               Guidelines for reviewing proposed
                                     In-stream Flow Thresholds), those thresholds should be calculated additional surface water is required to support the                   Water Uses”.
                                     appropriately and approved by the appropriate fisheries agencies (e.g., full build-out of the project, GAS will conduct an
                                     MOE’s Environmental Stewardship Division (ESD));                             environmental impact assessment as required by             GAS commits to continue to collect
                                  • If GAS determines that additional surface water is required, there will the appropriate regulatory agencies.                             stream flow data as long as required
                                     be a need to apply for additional water license(s) and undergo                                                                          by government agencies to protect
                                     associated (additional) environmental reviews; and,                                                                                     water quality, fisheries or fisheries
                                  • All monitoring plans (e.g., Water Quality, flow, etc.) must be initiated GAS provided a “draft” monitoring program as part               habitat, or in accordance with the
                                     prior to construction to ensure collection of adequate/representative of the Addendum 3 documents submitted to the                      water license requirements, and to
                                     baseline data. The baseline data and monitoring plans must be EAO in February 2009.                                                     collect additional biological data as
                                     appropriate to allow statistically valid quantification of post-construction                                                            required as part of the water licensing
                                     and operation impacts.                                                                                                                  process.
        December
                             MOE-WSD further commented that this is a multi MOE division issue;                                                                              GAS will continue to work with MOE to
        18, 2009
                             monitoring plans are to be submitted to MOE-EPD/WSD/ESD for review and                                                                          meet the Water License requirements.
                             approval. Water Quality issues are raised by MOE-EPD, while environmental
                             impacts associated with water diversions are issues raised by MOE-
                             WSD/ESD.

  84.   February   MOE –     Comments on Addendum #3 material – Appendix A (NHCL 2009)
                                                                                                                On August 11, for example, flows were measured on
        27, 2009   WSD       MOE – WSD commented that in Section 6 – “same day measurements, flows
                                                                                                                a steep receding limb of the hydrograph, and flow
                             are larger in the smaller watershed”. For Tables 2 and 3, when same day
                                                                                                                was measured at Brohm 2 two and a half hours later
                             measurements (August 11, 2008; September 17, 2008) on Brohm 1 and 2 are
                                                                                                                than at Brohm 1. While this may partially explain
                             compared, Brohm 2 the larger watershed at 4.0 km2 has smaller flows than
                                                                                                                observed higher flows in the smaller catchment on
                             Brohm 1 at 1.4 km2.
                                                                                                                the same day, other sources of variability may
                                                                                                                include:
                             This issue was discussed on February 18, 2009. The NHC reply was that could
                             be the case.                                                                            • Brohm 1: higher elevation catchment with
                                                                                                                         more precipitation input and possibly less
                             If a flow relationship between Brohm 1 and Brohm 2 were to be developed for                 infiltration (i.e. less storage), and higher
                             managing flows, it would be necessary to account for such an inverse. A flow                runoff per unit area.
                             management rule might be discussed and reviewed during the review of the                • Brohm 2: larger catchment with possibly
                             water license application; as this EAO application is not concurrent permitting.            more infiltration and storage capacity.
                             The flows on August 11, 2008 and September 17, 2008 could be part of a                  • The greatest differences between runoff at
                             quality review, to explain the similarities or differences of these two                     the two catchments may be due to the
                             watersheds.                                                                                 typically highly variable spatial distribution of
                                                                                                                         precipitation      inputs   in    mountainous
                                                                                                                         catchments. This will be difficult to account
                                                                                                                         for in model simulations since precipitation
                                                                                                                         gauges are not present in each sub-
                                                                                                                         watershed, and while one could be installed
                                                                                                                         in upper elevations of the entire watershed
                                                                                                                         to      adequately      assess     precipitation
                                                                                                                         gradients, monitoring the spatial distribution
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                                                                                                                        of precipitation inputs is beyond the project
                                                                                                                        scope.
                                                                                                                    •   Differences in runoff can also be expected
                                                                                                                        to be greater between the two catchments
                                                                                                                        during the freshet season due to the
                                                                                                                        desynchronization of snowmelt inputs. A
                                                                                                                        greater proportion of the Brohm 2
                                                                                                                        catchment is south-facing than Brohm 1,
                                                                                                                        and depending on meteorological inputs,
                   July 3, 2009                                                                                         Brohm 2 may be expected to peak earlier.
                                  MOE – WSD noted: If GAS proposes flow relationships or objectives that
                                  involve Brohm 1 and Brohm 2, it will be necessary to review this issue of      GAS consultants are updating the watershed model
                                  spatial differences.                                                           with Year 2 information report and GAS Inc. has
                                                                                                                 commenced a “flow, ecological and geomorphic
                                                                                                                 data collection program as part of the on-going
                                                                                                                 review in the water licensing approval process, to
                   December                                                                                      be completed after EA decision.
                   18, 2009
                                  MOE-WSD reiteratied - If flow relationships are proposed between the
                                  Brohm 1 and Brohm 2 hydrometric stations, the analysis is to include a
                                  review of any same-day temporal flow differences between the stations.

  85.   February   MOE - WSD      Comments on Addendum #3 material –NHCL (2009) and USL (2009)
                                                                                                             Comment noted.
        27, 2009                  NHCL report Figures 6 and 7 daily hydrographs, and the USL Figure 5.8, 20-
                                  year watershed modeling always have the Brohm 1 watershed with a lower
                                  discharge than Brohm 2.

        July 3,                   The issue is that over the 20-year run, the MIKE-SHE watershed model did not GAS consultants are updating the watershed model
        2009                      identify that there are times when the smaller 1.4-km2 Brohm 1 watershed had with Year 2 information report.
                                  greater flow than a 4-km2 Brohm 2 watershed; further follow-up will be
                                  required.
        December
        18, 2009                  The updating of the MIKE-SHE model with the Year 2 information is to
                                  compare the flow relationships between the Brohm 1 and Brohm 2 watersheds;
                                  1.4 km2 versus 4-km2.

  86.   February   MOE - WSD      Comments on Addendum #3 material –NHCL (2009)
                                                                                                                   Comment noted.
        27, 2009                  If a flow relationship between Brohm 1 and Brohm 2 were to be developed for
                                  managing flows, it would be necessary to account for such an inverse. A flow
                                  management rule might be discussed and reviewed during the review of the
                                  water license application; as this EAO application is not concurrent permitting.
                                  The flows on August 11, 2008 and September 17, 2008 could be part of a
                                  quality review, to explain the similarities or differences of these two
                                  watersheds.
        July 3,                                                                                                    GAS consultants are updating the watershed model
        2009                      If GAS proposes flow relationships or objectives that involve Brohm 1 and with Year 2 information report.
                                  Brohm 2, it will be necessary to review this issue of spatial differences. The
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                                  measured daily flows of these two stations could be plotted, and the number of
                                  times that the smaller 1.4-km2 watershed has greater flow than a 4-km2can be
        December                  noted.
        18, 2009
                                  MOE-WSD reiteratied - If flow relationships are proposed between the
                                  Brohm 1 and Brohm 2 hydrometric stations, the analysis is to include a
                                  review of any same-day temporal flow differences between the stations.

  87.   February      MOE - WSD   Comments on Addendum #3 material –NHCL (2009)                                       Physical water levels are measured to verify that
        27, 2009                  Rating curve shift issue - On September 17, 2008, two measurements are              sensors are functioning, but all measurements are
                                  taken on Brohm 2, 21.8 litres/s and 14.5 litres/s, but are only 0.0001 metres       tied into a benchmark. Refer to “Note on Method to
                                  apart (0.1886 to 0.1887 metres). This appears that the water level is from the      Establish Base Flows” above for NHC’s flow gauging
                                  pressure transducer, rather than being measured to a benchmark. This                QA/QC protocol.
                                  appears that the water level is from the pressure transducer, rather than being
                                  measured to a benchmark. Would not a lower water elevation of 0.1886                The two flow measurements (21.8 L/s and 14.5 L/s)
                                  metres for the 21.8 litres/s flow suggest a shift in the rating curve? But the      do not indicate a rating curve shift as these were
                                  NHC report only shows one rating curve for Brohm 2.                                 measured half an hour apart, but are rather an
                                                                                                                      indication of measurement error. While regular
                                                                                                                      testing and maintenance of sensors and
                                                                                                                      instrumentation reduces such sources of error,
                                                                                                                      measurement of very low flows with velocity-area
                                                                                                                      techniques may result in greater error resulting from
                                                                                                                      interpolations used in the estimation of flow. In
                                                                                                                      addition, the two flows were measured at two
                                                                                                                      separate channel cross-sections a distance apart to
                                                                                                                      quantify flow differences within the channel. In
                                                                                                                      addition to measurement error, such differences
                                                                                                                      could also partially be attributed to flows lost to the
                                                                                                                      hyporheic zone between the two measurement
                                                                                                                      sections. The hyporheic zone can play a relatively
                                                                                                                      greater role during low flow periods. In the future,
                                                                                                                      measurement of low flows will be verified with other
                                                                                                                      techniques such as the constant rate injection salt
                                                                                                                      dilution method. NHC documents sources of error
        July 3,2009                                                                                                   and these will be presented and discussed in
                                  The difference between 14.5 litres/sec and 21.8 litres/sec is 50%. This may         subsequent draft reports.
                                  indicate that a review of hydrometric techniques is required at Brohm 1 and
                                  Brohm 2 in order to reduce flow measurement error – and - the rating curve is       GAS consultants are updating the watershed model
                                  used to transform water level to flow. Additional practices for developing rating   with Year 2 information report.
                                  curves can be found in Chapter 5, Manual of British Columbia Hydrometric
                                  Standards, Version 1.0, dated March 12, 2009.
                                  http://ilmbwww.gov.bc.ca/risc/pubs/aquatic/hydrometric/man_BC_hydrometric_
        December                  stand_V1.0.pdf.]
        18, 2009
                                  If flow measurement error, gauging, or rating curve issues persistent at the
                                  Brohm River hydrometric stations, MOE-WSD may request that a Qualified
                                  Hydrometric Data Reviewer examine the datasets and to assign a data grade.
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                               See Manual of British Columbia Hydrometric Standards, Version 1.0, dated
                               March 12, 2009.

  88.   February   MOE –       Comments on Addendum #3 material –NHCL (2009)                                     Additional error analysis for the hydrologic model is
        27, 2009   WSD         The issue raised in #86 above was discussed on February 18, 2009 at the           now included in the Updated USL (2009) Interim
                               GAS Working Group meeting. MOE-WSD understood that NHC will be                    Report; further analysis and reporting will be added
                               reviewing the hydrometric data to discuss data quality, or establish error bars   to the Final Report, upon verification of the model in
                               for flows.                                                                        fall 2009. [EAO Note: This information has not been
                                                                                                                 submitted at this time]

                                                                                                                 Finer temporal scale flow data exists (at a 15-min
                                                                                                                 interval) for each station, and flow duration curves
                                                                                                                 and analysis for the finer temporal scale can be
                                                                                                                 provided. Error analysis to quantify the uncertainty
                                                                                                                 of stream flow estimates was partially addressed
                                                                                                                 through indication of the levels at which flows have
                                                                                                                 been extrapolated outside of the measured range;
                                                                                                                 however, a more detailed error analysis may be
                                                                                                                 provided. A total of 4-6 discharge measurements
                                                                                                                 have been made at each station and more flows will
                                                                                                                 be obtained during a higher flow period.           As
                                                                                                                 mentioned previously, freshet flows for this year are
                                                                                                                 below average and adequately high flows could not
        July 3,                                                                                                  be obtained.
        2009                   MOE – WSD noted - If flow measurement error, gauging, or rating curve issues
                               persistent at the Brohm River hydrometric stations, we may request that a
                               Qualified Hydrometric Data Reviewer examine the datasets and to assign a GAS consultants are updating the water model for
                               data grade. See Manual of British Columbia Hydrometric Standards, Version 2009, and if such further analysis is warranted as
                               1.0, dated March 12, 2009.                                                   part of the water licensing approval process, to be
        December                                                                                            completed after EA decision, GAS will discuss this
        18, 2009               MOE – WSD reiterated its July 3, 2009 comment.                               request with MOE in that process.

  89.   February   MOE - WSD   Comments on Addendum #3 material – NHCL (2009)                                    Monthly flows can be provided for the period of Provide monthly flows in Year 2 report
        27, 2009               Provide the monthly flows on what has been collected to date; do not wait for a   record; however, flow estimates at Brohm 4 will be
                               complete year. This information is needed to compare against the monthly          less reliable until higher flows are measured. Flow
                               flows calculated in the watershed modeling, draft USL (2009) Table 6.1            estimates at Brohm 1-3 are based on a relatively
                                                                                                                 wide range of measured flows and are currently
                                                                                                                 more reliable for such purposes.
                               MOE - WSD discussed this issue on February 18, 2009 at the GAS Working
                               Group meeting. MOE - WSD understood that NHC will provide this information, Monthly flows will be provided when data collection
                               as to allow the comparison of modeled monthly flows versus measured has provided a full January to January calendar year
                               monthly flows.                                                              and the rating curves are completed on all the gauge
                                                                                                           locations. The annual water year start and end
                                                                                                           dates used in the analyses are October 1 to
                                                                                                           September 30.
        July 3,
        2009                   MOE – WSD noted - The monthly flows were requested as part of the Monthly flow information will be provided in the
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                               Addendum 3 review, in order to allow comparison between the measured flows updated 2009 water modeling report with Year 2
                               and the modeled flows. If there are concerns the rating curves are not information.
                               completed, the monthly flows can be provided with a note that these flows are
        December               preliminary and subject to final review.
        18, 2009
                               Presentation of monthly flows will be needed at the permitting stage. In
                               addition, reducing the hydrometric records to daily and monthly flows will assist
                               in the review and discussion of IFRs, flow regulation rules, and flow or water
                               level objectives.

  90.   February   MOE - WSD   Comments on Addendum #3 material –USL (2009)                                    Concur; additional commentary and graphics, as Provide additional commentary and
        27, 2009               Section 4.1 Source - It is not clear which point of diversion supplies water to needed, will be provided in the final report.           graphics in final report
                               what part of the resort. To prepare the water technical report, we will need to
                               list the source that will provide the water.                                    Both diversion points will be able to provide water for
                                                                                                               all uses at the resort, including snow-making, but
                                                                                                               this design information will be provided during the
                                                                                                               water licensing process and when the water
                                                                                                               technical report is required
        December               MOE – WSD comment on GAS November 2009 letter report on Water
        18, 2009               Supply Issues for the proposed Garibaldi at Squamish Project: If the
                               November 2009 Plan is approved as the water supply plan, the demand
                               and supply analysis must address all points of diversion in the two
                               systems: Brohm River and the East Brohm. The permitting stage
                               reviews the water supply at a point, and the water demand at that point.
                               The demand is the water diverted for immediate use in the resort, and
                               water diverted into storage.

  91.   February   MOE –       Comments on Addendum #3 material –USL (2009)                                    The secondary diversion is located in the secondary
        27, 2009   WSD         Section 4.2.2 - The description of the Secondary Diversion is not consistent storage facility, thus there is a single (combined)
                               with the description of the Secondary Storage in Section 4.2.3. The Secondary facility.
                               Diversion is being described as a separate intake. Is this the correct
                               interpretation? Are there two separate works at the Secondary Storage Facility,
                               or one combined works?
        December
        18, 2009               MOE – WSD comment on GAS November 2009 letter report on Water
                               Supply Issues for the proposed Garibaldi at Squamish Project: In their
                               November 2009 report, Urban System figures continue to show two
                               works or points of diversion in the area of the Secondary Diversion;
                               rather than one. At the permitting stage, it will be necessary to provide a
                               plan at a suitable scale that shows details of the proposed works and
                               points of diversion.

  92.   February   MOE –       Comments on Addendum #3 material –USL (2009)                                     Both diversion points can provide water for all uses
        27, 2009   WSD         Section 4.2.3 - It is not clear which point of diversion supplies water to which at the resort, including snow-making.
                               snow-making reservoir. To prepare the water technical report, MOE-WSD will
                               need to list the source that will provide the water.
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        July 3,                MOE noted - Even through one application by GAS was made, this may result            If MOE decides in its water license application
        2009                   in two water licences – one on each tributary. The development of water              review that 2 licences are required, GAS will comply
                               supply analyses, water demand, diversion rules, flow objectives should be            with the needed information for 2 water licencses on
                               prepared to support the application for a water licence at each point of             that basis.
                               diversion.
        December
        18, 2009               MOE – WSD reiterated its July 3rd comment and comment on GAS November
                               2009 letter report on Water Supply Issues for the proposed Garibaldi at
                               Squamish Project: For a project, the number of water licences that may be
                               issued is dependent on the number of point of diversions used to divert or to
                               store water. As well, when a project is built in stages or phases, this can result
                               in one or more water licences being issued for the project.

  93.   February   MOE –       Comments on Addendum #3 material –USL (2009)                              An updated decision on storage facility sizing must Design of all storage facilities will
        27, 2009   WSD                                                                                   await verification of the hydrologic model, but occur after the hydrologic model is
                               Have volumes of the Primary Storage Facility been changed? Have volumes generally, yes, the sizes will likely be revised. The verified
                               of the Secondary Storage Facility been changed?                           Updated Interim Report does include preliminary
                               Also see comments for Section 4.4.1 in Issue #XX below on reservoir size, revised volumes.

        July 3,                MOE noted - If changes do occur, an amendment to the water licence If MOE decides an amendment to the application is
        2009                   application will be required.                                                  required GAS will respond as required to that
                                                                                                              request.
        December               MOE reiterated, if changes do occur to the points of diversion or storage, the
        18, 2009               water licence application will need to be amended.

  94.   February   MOE - WSD   Comments on Addendum #3 material –USL (2009)                                         At this time no changes have been made to the
        27, 2009               Figure 4.1 and Figure 3.2 and Figure 2 in Preliminary Overview-Level                 Snow-making reservoirs; the graphical presentation
                               Geomorphological Impact Assessment of Reservoirs, Water Intakes, Stream              may make it appear so, but that is not the case.
                               Crossings and Forest Harvest (2009) - Have the volumes of Snow-making I
                               and Snow-making II been changed? The footprint of these snow-making
                               reservoirs appears different in the three figures.

                               If these volumes have been changed, the water licence application will need to
                               be amended. The discussion on these changes should start in the EAO
                               review, this is to avoid having to re-visited decisions or commitments made
                               during the EAO review.
        July 3,                                                                                                     If MOE decides an amendment to the application is
        2009                   MOE noted - If changes do occur, an amendment to the water licence                   required GAS will respond as required to that
                               application will be required. (see also December 18, 2009 comment above).            request.

  95.   February   MOE - WSD   Both the Secondary Storage Facility and the Primary Storage Facility on Agreed.                                                             GAS Inc. commits to doing a review
        27, 2009               Brooks Creek will need to have a review for Downstream Consequence                                                                          for     Downstream     Consequence
                               Classification; see BC Dam Safety Regulation.                                                                                               Classification; under the BC Dam
                                                                                                                                                                           Safety Regulation for both the
        December               Application information requirements for review of major dams (> 9-metres)                                                                  Secondary Storage Facility and the
        18, 2009               can be found at MOE website:                                                                                                                Primary Storage Facility on Brooks
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                               http://www.env.gov.bc.ca/wsd/public_safety/dam_safety/index.html                                                                        Creek

  96.   February   MOE - WSD   Comments on Addendum #3 material –USL (2009)                                       Golf course irrigation will have its own system,
        27, 2009               Sections 4.3.3 and 4.4.2 - It is not clear which point of diversion would supply   separate from the potable water system. As noted
                               water for the golf course irrigation system. To prepare the water technical        in Section 4.4.3, it will be supplied by treated
                               report, MOE - WSD will need to list the source that will provide the water.        wastewater from the resort. [GAS Note: Section
                                                                                                                  4.4.2 was mis-labeled in the USL (February 2009)
                                                                                                                  Interim Report; it should have been 4.4.3, this
                                                                                                                  correction has been made for the May 2009
                                                                                                                  Updated Interim Report]
        July 3,                MOE noted - If the water supply for the golf course is changed to surface
        2009                   water, this will require a new application for a water licence; as the golf course If additional design and assessment results in the
                               is not part of 2007 water licence application.                                     need for these preliminary designs to change, and
                                                                                                                  an amendment to the application is required, GAS
        December               MOE reiterated - If the golf course will use surface waters for irrigation in the will comply with the amendment needs, necessary to
        18, 2009               interim phase, until the resort can provide sufficient quantities of treated obtain a water licence
                               wastewater, the source of this surface water is to be identified.

  97.   February   MOE - WSD   Comments on Addendum #3 material –USL (2009)                                   As GAS intends to apply water conservation
        27, 2009               Section 4.4.1 - The selection of the per capita demand has a direct connection measures to the resort, two per capita demand
                               to the reservoir size (Urban Systems December 8, 2008 memorandum).             scenarios will continue to be carried forward in the
                                                                                                              analyses, one based on Squamish Lillooet Regional
                               It is understood that the MIKE-SHE watershed modeling had been done with
                                                                                                              District guidelines (600 Lpcd) and one based on the
                               the larger of the two per capita demand. This issue was discussed on
                                                                                                              experience at Sun Peaks Resort (220 Lpcd).
                               February 18, 2009 at the GAS Working Group meeting. To prepare the water
                               technical report for the Secondary and Primary storage volumes, MOE-WSD
                               will need to be provided with the conclusion of the per capital demand issue.

        July 3,                MOE noted - As the per capita demand has an influence on reservoir sizing          GAS will update its per capita demand on the basis
        2009                   and flow diversions, the water application review (permitting stage) would         of the middle value, the DOS per capita rating of
                               require that the final value for the per capita demand is clearly defined. [EAO    455, and will go forward with that number for EA,
                               note: GAS Inc. provided a report from Urban Systems Ltd. on November 17,           master plan review and also the water licence.
                               2009 that used the 455 per capita demand.]

        December               MOE – WSD commented that the EAO directed GAS to prepare a water
        18, 2009               supply plan for the 455 litre per capita day demand, or the November 2009
                               Plan. The November 2009 Plan resulted in major changes to the project,
                               resulting in two Supplement Storage reservoirs being added to the project, and
                               two Snowmaking Storage reservoirs being dropped from the project.

  98.   February   MOE - WSD   Comments on Addendum #3 material –USL (2009)                                  The confusion comes from the way Excel labels time
        27, 2009               Figure 5.8 - The x-axis labels are confusing, some divisions have 1-month, 2- series, based on a consistent number of days
                               months, 3-months but all have the same width.                                 between points (typically 30 or 90 days), rather than
                                                                                                             a consistent day of the month.

        July 3,                At the water licence application review (permitting stage), additional graphs
        2009                   may be required to facilitate review and discussion of issues.
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  99.   February   MOE - WSD   Comments on Addendum #3 material –USL (2009)                                      Urban Systems did not set a minimum daily flow
        27, 2009               Concern that the watershed model appears to have a minimum value set such         value, though it may not be apparent at the scale of
                               that Secondary Division (Brohm 1) does not have a daily flow less than 30         the graphs. It is noted that the plotted values are
                               litres/sec, and that Primary Division (Brohm 2) does not have a daily flow less   20-year averages.
                               than 40 litres/sec. While 30-40 litres/sec may appear to be low, they are high
                               when compared with measured minimum flows, 0.0 to 3 litres/sec, Table 6,
                               NHC Brohm River Hydrometric Program.

        July 3,                At the water licence application review (permitting stage), the presentation of
        2009                   information should include a comparison of measured low flows and modeled At the water license application review (permitting
                               low flows.                                                                      stage), a comparison of measured low flows and
                                                                                                               modeled low flows will be provided.
        December               In reviews, the MIKE-SHE minimum daily flows are to be compared against
        18, 2009               measured minimum daily flows.

  100. February    MOE - WSD   Comments on Addendum #3 material –USL (2009)                                   The results will be reviewed in light of these GAS Inc. commits to further review the
       27, 2009                The issue is that the modelled average flow from a 20-year simulation, appears comments after using the additional years worth of model results after an additional year
                               to be consistently high during a time period.                                  hydrometric data to verify the model.              of flow data is acquired.

                               This could be reviewed by comparing with daily flows from the NHC Further discussion with MOE and Urban Systems
                               hydrometric program (Figures 6 and 7) during the same time period. during the water licensing approval process

                               The issues raised her and in the comment above were discussed on February
                               18, 2009 at the GAS Working Group meeting. The review of the 30-40
                               litres/sec issue may indicate that the MIKE-SHE watershed model requires
                               additional work or discussion.
        July 3,                                                                                                At the water license application review (permitting
        2009                   At the water licence application review (permitting stage), the presentation of stage), a comparison of measured low flows and
                               information should include a comparison of measured low flows and modeled modeled low flows will be provided.
                               low flows.
        December
        18, 2009               In response to GAS comments MOE noted that the comparison between
                               modeled minimum daily flows and measured daily flows for a specified time
                               period may be requested at the permitting stage.

  101. February    MOE - WSD   Comments on Addendum #3 material –USL (2009)                                      The combined withdrawal from Primary and
       27, 2009                Table 6.1 – Estimated Allowable Flow Withdrawls - Is this the correct             Secondary diversion points must not exceed value
                               interpretation? A monthly allowable withdraw for May shows 0.665, 0.583,          at the Limit of Fish Access. The table has been
                               0.272 cms for the Limit of Fish Access, Primary Diversion, Secondary              revised to clarify this in the Updated Interim USL
                               Diversion respectively. Or that 0.855 cms (0.583 + 0.272) could be divert out     (May 2009) Report.
                               by the Primary and Secondary Diversions, even through 0.665 cms is the
                               monthly allowable at the Limit of Fish Access? Consider adding an information
                               note to Table 6.1, to explain how the flows at the Limit of Fish Access are the
                               limiting or controlling for flows at the upper points of diversion.

        July 3,                At the water licence application review (permitting stage), the Limit of Fish
        2009                   Access and other points of interest that are used to assess effects of flow
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                               diversions should have been selected in consultation with the Water Working
                               Group, MOE-ESD, DFO, and Squamish First Nations.

                               Diversion rules such as controlled timing of flow diversion, or a flow threshold
                               diversion rule have been discussed, but they have not been reviewed and
                               approved. It is expected that further discussion of diversion rules will occur at
                               the water licence application review (permitting stage).

        December               The selection of points of interest or control points is to be done in consultation
        18, 2009               with Water Working Group, MOE_ESD, MOE-EPD, DFO, and Squamish First
                               Nations.

  102. February    MOE - WSD   Comments on Addendum #3 material –USL (2009)                                      An outlet structure will be designed to allow passage
       27, 2009                Section 6.2 - The Secondary Diversion is an in-line storage reservoir. As no of flows during periods of no withdrawal for the
                               diversion is show for the fall period, how is possible to prevent the fall runoff resort.
                               from refilling the Secondary reservoir? This issue was discussed on February
                               18, 2009 at the GAS Working Group meeting. From Urban Systems response,
                               it was understood that providing for the IFR would prevent the Secondary
                               Reservoir from re-filling.
        July 3,
        2009                   At the water licence application review (permitting stage), the time period of
                               flow diversions from the Brohm River will need to be clearly defined. Also, A
                               water licence may have a clause for the preparation of an Operating
                               Parameters and Procedure report. This report would explain how the works
                               would be operated to meet various objectives. Depending on the complexity of
                               a diversion rule for works, it may be recommended that an Operating
                               Parameters and Procedure report be required for a water licence.
        December
        18, 2009               At the permitting stage, it will be necessary to provide a report that explains the
                               operating rule at the works, and how this rule satisfies flow or water level
                               objectives. This report is to include a plan at a suitable scale that shows details
                               of the proposed storage or diversion works.

  103. February    MOE - WSD   Comments on Addendum #3 material –USL (2009)                                          The figures are based on 20-year average A discussion on flow based rules will
       27, 2009                Figures 6.1, 6.2a, 6.3a, 6.2b, and 6.4 - Period of flow diversion, monthly or rule    conditions and thus withdrawal on average must be be addressed in the final modeling
                               based - This issue was discussed on February 18, 2009 at the GAS Working              limited to the two month period. Pending verification report.
                               Group meeting. The figures imply that withdraws would start May 1 and go to           of the hydrologic model, flow based rules (rather
                               June 30, or two months; the proposed withdraw line is otherwise zero. The             than calendar date rules) may be proposed.
                               Urban System reply was that the period of diversion may depend on the start           Discussion will be included in the final report [EAO
                               of freshet, rather than a calendar date.                                              Note: this information has not been submitted at this
        July 3,                                                                                                      time].
        2009                   At the water licence application review (permitting stage), the time period of
                               flow diversions from the Brohm River will need to be clearly defined. The A discussion on flow based rules will be addressed
                               development of flow diversion rules should include consultation with the Water in the final modeling report. Comment noted - The
                               Working Group, MOE-ESD, DFO, and Squamish First Nations.                       development of flow diversion rules will include
        December                                                                                              consultation with the Water Working Group, MOE-
        18, 2009               MOE reiterated water licences can authorize the diversion of water the whole ESD, DFO, and Squamish First Nations.
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                               year, or for a specified period of time, or at a specified flow or water level. Each
                               type of diversion rule has a corresponding level of supporting information
                               requirements.

  104. February    MOE - WSD   Comments on Addendum #3 material –USL (2009)                                        Comments noted.
       27, 2009                The Primary Storage on Brooks Creek is an off-line reservoir, in that it is
                               physically separated from the Brohm River tributary. A water licence can
                               specify the period the flow is diverted, i.e. Village of Ladysmith water licence to
                               draw water from Banon Creek, to store in Holland Lake (Reservoir), November
                               1st to May 31st.
        July 3,
        2009                   MOE note (July 2009) - At the water licence application review (permitting
                               stage), the flow diversion (time period or flow threshold) from the Brohm River
                               to the Brooks Creek Reservoir will need to be clearly defined. [EAO note: see
                               also December 18, 2009 comment above.]

  105. February    MOE - WSD   If GAS is considering a different diversion rule based on IFR or water levels at Comment noted. A discussion on flow based rules
       27, 2009                the point of diversion, the discussion on this should start in the EAO review. will be addressed in the final modeling report.
                               This is to avoid having to re-visited decisions or commitments made during the
                               EAO review.
        July 3,                                                                                                 The development of flow diversion rules will include
        2009                   The development of flow diversion rules should include consultation with the consultation with the Water Working Group, MOE-
                               Water Working Group, MOE-ESD, DFO, and Squamish First Nations.                   ESD, DFO, and Squamish First Nations.

        December
        18, 2009               MOE – WSD comment on GAS November 2009 letter report on Water Supply
                               Issues for the proposed Garibaldi at Squamish Project: If approved, the
                               November 2009 involves the construction of two large reservoirs. Reservoirs
                               are managed by accounting inflows, outflows, and changes in storage, or the
                               “operating rule.” More detailed information on the “operating rule” would be
                               needed at the permitting review. MOE reiterated water licences can authorize
                               the diversion of water the whole year, or for a specified period of time, or at a
                               specified flow or water level. Each type of diversion rule has a corresponding
                               level of supporting information requirements.

  106. February    MOE - WSD   In the water technical report, we would discuss the diversion rule in more depth Comment noted. A discussion on flow based rules
       27, 2009                and detail. Typically, water licences specify the calendar period that water can will be addressed in the final modeling report.
                               be diverted, and the bypass instream flow. The calendar period is usually
                               specified on a monthly time step. The 2007-2008 hydrometric flows and the
                               20-year flow simulation could be used to show how the proposed diversion rule
                               would work, and the downstream effects on flows or water levels.

        July 3,                The development of flow diversion rules should include consultation with the The development of flow diversion rules will include
        2009                   Water Working Group, MOE-ESD, DFO, and Squamish First Nations.                       consultation with the Water Working Group, MOE-
                                                                                                                    ESD, DFO, and Squamish First Nations.
        December               MOE reiterated water licences can authorize the diversion of water the whole
        18, 2009               year, or for a specified period of time, or at a specified flow or water level. Each
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                            type of diversion rule has a corresponding level of supporting information
                            requirements.

  107. February   MOE-EPD   Comments on Addendum #3 materials – draft Table of Commitments and                GAS agrees to have the final sediment and erosion       GAS commits to have the final
       27, 2009             Assurances                                                                        control plan reviewed by a Certified Professional in    sediment and erosion control plan
                            Item #8 – Supplemental Information Requirements for the Application (2003),       Erosion and Sediment Control (CPESC) during             reviewed developed by a Certified
                            Volume 7, Section 9.0 (Water Quality), Section 9.1.1 (Construction) and Item      construction of all road base and ski/lift areas.       Professional in Erosion and Sediment
                            #9 – Supplemental Information Requirements for the Application (2003)                                                                     Control (CPESC) during construction
                            Volume 7, Section 11.0 (Vegetation), Section 11.2.3 (Erosion and Mass                                                                     of all road base and ski/lift areas.
                            Wasting). Changes are requested for both commitments – add – “completed
                            by a Certified Professional in Erosion and Sediment Control (CPESC)” into the
                            text of the commitment.

                            Review of an existing erosion and sediment control (ESC) Plan by a CPESC
                            may also be acceptable, if there was adequate consultation prior to, and during
                            construction (for adaptive management).

  108. February   MOE-EPD   Several statements made in the Supplemental Information Requirements for Comment noted.
       27, 2009             the Application (2003) in Volume 7, Section 9.0 – Water Quality Impacts and
                            Mitigation indicate that a higher level of expertise in ESC would be beneficial,
                            as significant impacts to streams during the construction phase of the project
                            could occur if an ESC plan is not adequate and/or not adequately or adapted.
                            More information on CPESCs is available on www.cpesc.org. Some examples
                            of these concerns include in Issue Tracking #108, #109 and #110 below.


  109. February   MOE-EPD   Section 9.1.1.1 (Roads and Base Area):                                            GAS will change the wording to emphasize the
       27, 2009                •      The increased solids can also introduce sediment-associated             importance of erosion (source) control. GAS will
                                      metals to receiving waterbodies which can impact aquatic                monitor water quality (e.g. turbidity, TSS) up- and
                                      organisms at elevated levels. (p. 9-5), and                             downstream of construction.
                               •      Wording of “sediment control measures” and “sediment control
                                      plan” should be changed to “erosion and sediment control (ESC)
                                      measures” and “erosion and sediment control (ESC) plans” to
                                      reflect the importance of erosion (source) control as the basis
                                      of an ESC plan. (p. 9-5 & 9-7), and
                               •      A point is missing from the conceptual ESC Plan that should be
                                      added: 11. Monitor water quality (e.g. turbidity, TSS) up- and
                                      downstream of construction. (p. 9-5)

  110. February   MOE-EPD   Section 9.1.1.1 (Ski Runs):                                                       GAS’s erosion and sediment control plan will            GAS commits to have the final
       27, 2009                •      ESC on steep slopes should not be assumed to be “similar to that        address construction activities on steep slopes         sediment and erosion control plan
                                      for other development areas” as the available windows for               through the use of BMP’s such as water                  reviewed by a Certified Professional in
                                      earthworks and construction are shorter (May-Aug) and the steep         management of run-off (i.e. rock lined interceptor      Erosion    and    Sediment     Control
                                      nature of the terrain poses a significant risk of sediment impacts      ditches) and source control (i.e. erosion control       (CPESC) during construction of all
                                      to watercourses if not properly implemented and adapted. (p. 9-7)       blankets for exposed soils, etc.). Exposed soil areas   road, base and ski/lift areas.
                               •      Timing of construction can be an important erosion control              will be re-vegetated with a tackifier mulch (i.e.
                                      measure for steep slope construction that was not mentioned, e.g.       Terrasol SedimentLok) where appropriate based on        GAS commits to using erosion and
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                                       construction leading to soil exposure would not occur later than supplier recommendations to ensure that vegetation sediment control BMP’s and/or to
                                       August and exposed soil would be re-vegetated well before the becomes established before fall rains/snow.           having established plant cover on
                                       onset of fall rainy periods. (p. 9-7)                                                                               disturbed sites before the onset of fall
                                                                                                                                                           precipitation and revegetating high
                                                                                                                                                           elevations sites annually to allow
                                                                                                                                                           adequate time for vegetation growth
                                                                                                                                                           prior to winter, as outlined in the ESC
                                                                                                                                                           to be developed to the satisfaction of
                                                                                                                                                           the Regional Manager, Environmental
                                                                                                                                                           Protection    Division,    Ministry   of
                                                                                                                                                           Environment (Surrey).

  111. February   MOE-EPD   Section 9.1.2.6 (Summary of Residual Impacts):                                    GAS agrees to have the final sediment and erosion      GAS commits to have the final
       27, 2009             Table 9-11 – MOE - EPD would be more willing to support the conclusion that       control plan reviewed by a Certified Professional in   sediment and erosion control plan
                            “Significance with Mitigation” is Low for Erosion and sedimentation during        Erosion and Sediment Control (CPESC) during            reviewed by a Certified Professional in
                            construction if an ESC Plan is developed by a CPESC and adapted as                construction of all road base and ski/lift areas.      Erosion   and     Sediment     Control
                            necessary.                                                                                                                               (CPESC) during construction of all
                                                                                                                                                                     road base and ski/lift areas.

  112. February   MOE-EPD   Comments on Addendum #3 materials – draft Table of Commitments and                GAS Inc. agrees to have the final sediment and         Need to review commitments
       27, 2009             Assurances: Item #9: Supplemental Information Requirements for the                erosion control plan reviewed by a Certified
                            Application (2003) Volume 7, Section 11.0 (Vegetation), Section 11.3.7 (Hikers    Professional in Erosion and Sediment Control         GAS commits to have the final
                            and Mountain Bikers). MOE -EPD would like two more commitments added to           (CPESC) during bike park trail construction and      sediment and erosion control plan
                            the “environmental guidelines for trail development”:                             operation.                                           reviewed developed by a Certified
                                •      Erosion and sediment control (ESC) plans for bike park trail                                                                Professional in Erosion and Sediment
                                       construction and operation, developed by a Certified Professional in   GAS will avoid stream crossings in bike park Control (CPESC) during bike park trail
                                       Erosion and Sediment Control (CPESC), to mitigate erosion and          development wherever possible and maintain construction and operation.
                                       sediment impacts to affected watercourses.                             riparian buffers, and where stream crossings are
                                •      Avoid stream crossings in bike park development and maintain           required, design bike trail stream crossings in GAS will follow the Fish Stream
                                       riparian buffers.                                                      accordance with the protection measures outlined in Crossing Guidebook for all trail
                                                                                                              the Forest Practices Code - Fish Stream Crossing crossings of streams.
                            Rationale: Improper ESC in steep slope bike parks during operation can lead       Guidebook, the Fisheries and Oceans Canada, GAS commits to avoid stream
                            to ongoing sediment inputs during rain events to watercourses running through     Pacific Region Operational Statement for Clear crossings in bike park development
                            the bike park which can impact aquatic life. Review of an existing erosion and    Span Bridges and Ministry of Environment’s wherever possible and maintain
                            sediment control (ESC) Plan for the bike park and recreational trails by a        Standards and Best Practices for Instream Works, riparian buffers, and where stream
                            CPESC may also be acceptable, if there was adequate consultation prior to,        as applicable, for approval under the B.C. Water Act crossings are required, design bike
                            and during construction (for adaptive management).                                and Regulations, and apply as required, appropriate trail stream crossings in accordance
                                                                                                              ski area BMP’s for any stream crossings in keeping with the protection measures outlined
                                                                                                              with ski run development BMP’s.                      in the Forest Practices Code - Fish
                                                                                                                                                                   Stream Crossing Guidebook, the
                                                                                                                                                                   Fisheries and Oceans Canada, Pacific
                                                                                                                                                                   Region Operational Statement for
                                                                                                                                                                   Clear Span Bridges and Ministry of
                                                                                                                                                                   Environment’s Standards and Best
                                                                                                                                                                   Practices for Instream Works, as
                                                                                                                                                                   applicable, for approval under the B.C.
                                                                                                                                                                   Water Act and Regulations, and apply
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                                                                                                                                                                            as required, appropriate ski area
                                                                                                                                                                            BMP’s for any stream crossings in
                                                                                                                                                                            keeping with ski run development
                                                                                                                                                                            BMP’s.

  113. February   MOE-EPD     Comments on Addendum #3 materials – draft Table of Commitments and                 GAS has committed to environmental monitoring                GAS commits to the developing and
       27, 2009               Assurances: Item #13: Supplemental Information Requirements for the                during construction. The Environmental Monitor will          implementing     a     Water   Quality
                              Application (2003) Volume 7, Section 30.0 (Water Quality Monitoring Plan).         take turbidity readings at locations upstream and            Monitoring Plan (WQMP) prior to the
                              MOE - EPD would like the wording changed in the 2nd sentence to state: The         downstream of cleared areas and active                       start of any construction. The WQMP
                              WQMP will address both the collection of additional baseline data (when            construction. The monitoring will include turbidity          will address both the collection of
                              required) and real-time monitoring effects of construction and resort operation,   measurements during storm events. GAS does not               additional    baseline data     (when
                              which will be linked to adaptive and mitigative management actions if impacts      plan to install real-time turbidity loggers during           required) and real-time monitoring of
                              exceed performance targets (e.g. BC Approved Water Quality Guidelines).            construction.                                                the effects of construction and resort
                                                                                                                                                                              operation, which will be linked to
                              MOE - EPD requests that one more objective added to the Water Quality              The        environmental        monitoring        (turbidity adaptive and mitigative management
                              Monitoring Plan (WQMP):                                                            measurements plus observations of construction actions if impacts exceed performance
                                •        Monitoring related to stormwater runoff during construction,            activities and the site itself) will be linked to adaptive targets in BC Approved Water Quality
                                         including real-time turbidity monitoring.                               and mitigative management actions.                     The Guidelines.
                                                                                                                 Environmental Monitor will inform the construction
                              Rationale: Monitoring of water quality impacts must be linked to adaptive and      superintendent about any areas where silt-laden
                              mitigative management actions to be effective and to prevent ongoing impacts,      runoff is a concern and provide advice on adaptive
                              should they occur. These changes should be reflected in the Table of               management as appropriate. The Environmental
                              Commitments and Assurances to reinforce the proponent’s commitment to              Monitor will have the authority to halt construction
                              minimize environmental impacts and ultimately prevent pollution during             should the construction crews fail to take corrective
                              construction and operation.                                                        action or if the action taken is not effective.
        July 3,
        2009                  EPD note - If real-time monitoring is not to be used, magnitude and duration of    GAS will provide environmental monitoring during
                              turbidity events should be appropriately monitored to determine extent of the      construction. Observations of the environmental monitor,
                              impact. Cumulative impacts of events from multiple construction site locations     including but not limited to the results of turbidity
                                                                                                                 measurements, will be linked to adaptive and mitigative
                              should also be monitored at downstream receiving locations and addressed
                                                                                                                 management actions.
                              adequately.

  114. February   MOE - EPD   Comments on Addendum #3 materials - Environmental Protection Plans –               GAS Inc. will include an assessment of the %               GAS commits to include an assessment of
       27, 2009               Stormwater Management Plan Development Process                                     effective impermeable surface area in the lower            the % effective impermeable surface area
                                 • MOE appreciates the proponent’s efforts to keep impermeable surface           portions of the development area and has committed         in the lower portions of the development
                                                                                                                 to implement Low Impact Development (LID)                  area and has committed to implement Low
                                    area (ISA) to <10% of the whole Brohm River watershed, however,
                                                                                                                                                                            Impact Development (LID) techniques and
                                    MOE - EPD have significant concerns regarding the amount of ISA in           techniques and Best Management Practices
                                                                                                                                                                            Best Management Practices (BMPs)
                                    the lower watershed, near fish-bearing streams, unless potential             (BMP’s) wherever feasible to minimize impacts from         wherever feasible to minimize impacts
                                    impacts can be mitigated satisfactorily.                                     stormwater.                                                from stormwater runoff.
                                 • Please include an assessment of % effective impermeable surface area
                                    (EISA) in lower portions of the watershed where development is
                                    occurring, which if high (>10%), should inform appropriate mitigation
                                    measures, starting from lot-level to end-of-pipe BMP’s.

        July 3,                  EPD note - If BMP’s are ‘not feasible’, there must still be an adequate plan
        2009                     for treatment of stormwater runoff from these areas to prevent Agreed
                                 unacceptable impacts to receiving waterbodies due to sedimentation
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                                 and/or turbidity.

  115. February   MOE - EPD   Comments on Addendum #3 materials - Appendix E – Water License                    Yes, there should be a water quality station
       27, 2009               Monitoring Plan (Water Quality Section only)                                      downstream of the second diversion. Need to
                              Please confirm that there should be a downstream water quality monitoring at      correct Figure 1 in the Water License Monitoring
                              the 2nd point of diversion, which is not shown in Figure 1.                       Plan.

  116. December   SLRD        The SLRD has previously raised the issue of the applicant’s water system          The flow data collected by Northwest Hydraulics and    GAS commits to continue to collect
       4, 2007                design standard being far below that which is recommended by the SLRD.            the 20 year modeling results from Urban Systems        stream flow data as long as required
                              SLRD staff are supportive of the conservation programs proposed, but do not       that analyzed potential fish habitat impacts were      by government agencies to protect
                              support engineering the water system to rely on these programs. If these          provided to the EAO in February 2009 as part of the    water quality, fisheries or fisheries
                              programs prove unsuccessful the low water system design standard could            Addendum 3 and the final Northwest Hydraulics          habitat, or in accordance with the
                              result in an inadequate water supply. Additionally, it is unclear from the        report and the May 2009 Urban interim report in        water license requirements, and to
                              materials provided how water for fire suppression is addressed.                   June 2009. Prior to this GAS provided an updated       collect additional biological data as
                                                                                                                hydrology report (2008) that analyzed potential fish   required as part of the water licensing
                              The update on Water Supply Analysis prepared by Urban Systems provided            habitat impacts based on water conservation use        process, to design and construct the
                              little reassurance that the modeling systems are accurately estimating that       demand (260 L/person/day) and DOS’s and SLRD           potable water distribution system in
                              available water supply. The report stated that the two modeling systems           bylaw volume of 455-650 L/person/day. The study        accordance with good engineering
                              yielded significantly different annual hydrographs. SLRD staff recommended        followed BC Instream Flow Guidelines and showed        practice and all applicable guidelines
                              longer term monitoring of Brohm Creek. This monitoring should take place          no impacts to fish habitat from withdrawing either     and regulations.
                              prior to the EA certificate being issued to ensure an adequate water supply and   volume of water. Meeting the guidelines should
                              an effective environmental impact assessment.                                                                                            .
                                                                                                                ensure maintenance of instream temperature within
                                                                                                                an acceptable range. In addition, no water will be
                                                                                                                withdrawn during the low flow periods, which will
                                                                                                                further reduce the potential for effects on stream
                                                                                                                temperature.

                                                                                                                GAS will design and construct the potable water
                                                                                                                distribution system in accordance with good
                                                                                                                engineering practice and all applicable guidelines
                                                                                                                and regulations including those of:
                                                                                                                •   Vancouver Coastal Health Authority;
                                                                                                                •   BC Safe Drinking Water Regulations;
                                                                                                                •   Fire Underwriters Survey; and
                                                                                                                •   DOS and/or the SLRD (as applicable).
                                                                                                                In August/September 2007, GAS initiated surface
                                                                                                                flow monitoring at the two proposed water
                                                                                                                withdrawal diversion points and at the upper and
                                                                                                                lower limits of fish in Lower Brohm River. GAS also
                                                                                                                committed to additional modeling of water
                                                                                                                supply/demand to be used to further assess
                                                                                                                potential impacts to fish habitat. The SLRD per
                                                                                                                capita demand of 600 litres/per/day was used to
                                                                                                                evaluate supply/demand in the Interim Urban
                                                                                                                Systems modeling report dated May 2009.
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                                                                                                                      GAS participated in the Water Supply Working
                                                                                                                      Group for discussions of the issues including
                                                                                                                      monitoring or reviewing progress in data gathering,
                                                                                                                      modeling and meeting the requirements for
                                                                                                                      subsequent authorizations/licenses.

  117. August 19,   DFO         1.2.2 Collection of Hydrologic Flow Data                                              Comment noted.
       2008
                                DFO would like to clarify that impacts to fish habitat include habitat for resident   GAS agrees that impacts to fish habitat include both
                                fish species as well as anadromous fish species. Harmful alteration, disruption       anadromous and resident fish species, which in this
                                or destruction of any fish habitat (i.e. including freshwater resident or             case have the same limits of upstream movement in
                                anadromous fish species) is prohibited unless authorized under subsection             Brohm River.
                                35(2) of the Fisheries Act.

  118. December     DFO         DFO is not sure why GAS has chosen the upper limit of anadromous fish in the          GAS agrees with DFO that the upper limit of fish       GAS commits to continue to collect
       10, 2008                 Brohm River as the point of interest. Non-anadromous fish have water flow             access is the same for anadromous and resident        stream flow data as long as required
                                needs too. Perhaps the upper limit of anadromous fish aligns with the upper           fish which is a falls/cascade located immediately     by government agencies to protect
                                limit of any kind of fish? If this is the case, DFO suggests calling the point the    above the forest service road bridge over the Lower   water quality, fisheries or fisheries
                                upper limit of fish access so there are no misunderstandings that instream            Brohm River. Future reference to this barrier will be habitat, or in accordance with the
                                flow requirements may be required for all fish not just for salmon.                   for all fish access and instream flow requirements    water license requirements, and to
                                                                                                                      will be required for all fish.                        collect additional biological data as
                                Does GAS plan on doing any flow analysis for the locations on
                                                                                                                                                                            required as part of the water licensing
                                the tributary streams where the water withdrawals are located? Although there         However, the Urban Systems report assessed
                                                                                                                                                                            process.
                                may not be fish at these locations, flows (when present) in these streams             instream flow requirements at the two diversion
                                would deliver aquatic bugs and organic debris downstream and provide food             points (fishless sections of the upper Brohm
                                and nutrients to the fish and aquatic ecosystem that supports fish.                   watershed), for the upper limit of fish access (falls
                                                                                                                      above the logging bridge) and immediately upstream
                                                                                                                      of the Cheekye and Brohm River confluence.
                                                                                                                      The flow data collected by Northwest Hydraulics and
                                                                                                                      the 20-year modeling results from Urban Systems
                                                                                                                      were provided to the EAO as drafts in February
                                                                                                                      2009 as part of the Addendum 3 documents. The
                                                                                                                      final Northwest Hydraulics and the interim Urban
                                                                                                                      Systems report were submitted in June 2009.

  119. February     Vancouver   Rather, the main concern related to the quantity of water available (including        GAS Inc. has assessed the potential supply vs/          GAS is committed to meet the District
       12, 2009     Coastal     timing of flows, etc). Following my previous discussion with staff within the         demand for the Garibaldi Resort project based on        of Squamish (DOS) consumption rates
                    Health      DOS I believe they are following this issue closely. From VCH perspective if          the one year of flow data collected by Northwest        and work with the Ministry of
                    (VCH)       the DOS is the most likely governance structure for this project, then DOS            Hydraulic Consultants (NHC) and detailed modeling       Environment to finalize data collection
                                should be given the discretionary authority to determine if the supply side can       prepared by Urban Systems, and determined from          requirements through the water
                                meet or exceed the demand side (in terms of water quantity).                          that assessment there is sufficient water to supply     licensing process prior to a final
                                                                                                                      the resort at full build-out and protect the fish       decision on the resort water supply.
                                                                                                                      populations of Brohm River.        In addition, the
                                                                                                                      modeling used the higher consumption rate of the
                                                                                                                      SLRD of 600 l/person per day compared to the
                                                                                                                      District of Squamish requirements of 455 l/person
                                                                                                                      per day.
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                                                                                                               Over time GAS expects to prove that water
                                                                                                               conservation techniques can reduce the per capita
                                                                                                               consumption rates to well below the DOS bylaw
                                                                                                               requirements.

  120. December   MOE - WSD   The following MOE comments are in response to the Brohm Watershed study, The following are Urban Systems Responses to GAS commits to continue to collect
       15, 2008               revised preliminary assessment of first year flow data -  USL#2271.0004.01 – X MOE’s comments.                                         stream flow data as long as required
                              Memorandum                                                                                                                             by government agencies to protect
                                                                                                               Only the Primary and Secondary Diversion Points water quality, fisheries or fisheries
                              It is not clear which upper, lower diversion is being discussed: Primary are mentioned in the memorandum, not upper and habitat, or in accordance with the
                              Diversion or Secondary Diversion.                                                lower diversions. These points are located as per water license requirements, and to
                                                                                                               documentation      prepared     as    part   of   the collect additional biological data as
                                                                                                               Environmental Assessment process (“Volume 4, required as part of the water licensing
                                                                                                               Garibaldi At Squamish Project, CASP Master Plan, process.
                                                                                                               EAO Additional Information Requirements, Waste
                              MOE-WSD December 18, 2009 comment response:                                      Management, Energy & Water Supply,” April 2003;
                              The Primary Diversion is located at 975 metres, or this is the lower intake. The hereinafter referred to as the “Master Plan”). Two of
                              Secondary Diversion is located at 1150 metres, or this is the upper intake.      the four hydrometric stations installed and operated
                                                                                                               by Northwest Hydraulics Consultants (NHC) are
                              If the GAS November 2009 Plan in the GAS November 17, 2009 letter report         located at these two diversion points. The other two
                              on Water Supply Issues for the proposed Garibaldi at Squamish Project is         are on the mainstem of the Brohm River, one at the
                              approved, at full build-out, the Supplement Storage #1 or #2 would become the upper limit of fish access on the river and one
                              main points of diversion, as these works would have the appropriate volume of immediately upstream of the confluence with the
                              water to satisfy the projected monthly volumes.                                  Cheakamus River. It is the former location that is
                                                                                                               highlighted in the memorandum, primarily because
                                                                                                               in this preliminary analysis the allowable withdrawal
                                                                                                               rates are more restrictive at this point than at the
                                                                                                               Primary and Secondary Diversion Points.

                              Figure a, b, c; The Maximum Allowable Diversion Rate was calculated for the      GAS understands this is the case and the license
                              Upper Limit of Anadromous Fish in Brohm River. The maximum diversion rate        application will be so structured. Are we to read this
                              should be calculated for the point of diversion. The hydrology should be         comment to suggest that if the withdrawal limits are
                              calculated for the point of diversion; this is the point of interest for water   met at the Primary and Secondary Diversion Points
                              licensing.                                                                       that GAS need not worry about the implications to
                                                                                                               the stream at the upper limit of fish access? As the
                                                                                                               memorandum pointed out, it appears that using the
                              MOE-WSD December 18, 2009 comment response:                                      fish access limit as the analysis point yields more
                              The selection of the Limit of Fish Access as a point of interest needs to be     restrictive withdrawal requirements than using the
                              confirmed by the Water Working Group, MOE-Environmental Stewardship              limits estimated at the two diversion points.
                              Division, Department of Fisheries and Oceans, and Squamish First Nations.

                              MOE has seen a presentation on the hydrometric studies, but not the report. None needed. GAS notes that Urban Systems has
                              MOE has not seen the NHC hydrometric report for the Sept 2007 – August received the 2007/2008 flow data from NHC. NHC
                              2008 period.                                                                full report was discussed at the February 2008
                                                                                                          Working Group meeting and a final version - Brohm
                              MOE-WSD December 18, 2009 comment response:                                 River Hydrometric Program Report (April 25, 2009)
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                        MOE- WSD provided comments on the draft NHC February 1, 2009 Brohm                 was submitted by GAS in June 2009.
                        River Hydrometric Program report in Addendum 3. [EAO note: these are
                        addressed in other parts of this Issue Tracking Table].

                        MOE has not seen a discussion on why NHC believes that Sept 2007 – August The NHC explained their reasoning to the Water
                        2008 was a dry period; this classification needs to be confirmed.              Working Group during its November 2008 meeting,
                                                                                                       which is described in their Brohm River Hydrometric
                        MOE-WSD December 18, 2009 comment response:                                    Program Report (April 25, 2009).
                        In Addendum 3, the April 25, 2009 Brohm River Hydrometric Program report,
                        page 16, states: Additional analyses that utilized fourteen (14) basins in the
                        area and land cover factors estimate a long term MAD of 2.4 m3/s for the
                        Brohm River, which suggests that 2007 annual runoff was 25% higher than the
                        long-term average.
                        The 2007 runoff would be referring to the Oct 1, 2007 to September 30, 2008
                        water year. This suggests that NHC had reviewed the dry year classification
                        that they presented in November 2008, and based on additional analyses,
                        NHC have determined that the 2007 annual runoff was 25% above the long
                        term average.

                        When Sept 2007 – August 2008 is confirmed as a dry period, then it can be        The point of the analysis is not to support a water
                        used for modeling purposes. The issue is correctly calling the wet-average-dry   license application, but simply to test in a preliminary
                        year so the modeling can be set up correctly. If an average year was             fashion whether it is more than less likely that there
                        misclassified as a dry year, this would shift the rankings.                      will be sufficient water available to support GAS
                                                                                                         Resort. The hydrometric data collected by NHC will
                        MOE-WSD December 18, 2009 comment response:                                      instead be used to calibrate a process-based,
                        The issue in identifying an annual runoff as dry-average-wet, is for calibrating distributed parameter hydrologic model; a second
                        the watershed model and for comparison purposes with other watersheds. As year of data (being collected currently) will be used
                        well, when the proposed diversion rules are applied to the measured runoff, to verify the model.
                        this would show the effects on a higher than average annual runoff.

                        The Dec 1, 2008 Urban System letter appears to disagree with the NHC This is a difference without real meaning. The term
                        discussion that the period was dry, Urban System’s use “somewhat lower than dry can mean any condition less wet than normal,
                        normal flow year”.                                                          which is what Urban Systems have stated in our
                                                                                                    memorandum. In any case, this preliminary analysis
                        MOE-WSD December 18, 2009 comment response:                                 was premised on assuming the data represented a
                        The 2007 annual runoff has been estimated by nhc to be 2.4 m3/s MAD, or long-term average, simply to provide a preliminary
                        25% above the long term average.                                            analysis as to whether we could meet instream flow
                                                                                                    guidelines to protect fish habitat while meeting resort
                                                                                                    water demand. As the memorandum indicated, the
                                                                                                    analysis still leads Urban Systems to believe it is
                                                                                                    possible to meet these instream flow guidelines at
                                                                                                    full build-out even using the very conservative SLRD
                                                                                                    per capita demand rates (plus snow-making
                                                                                                    demand).

                        MOE has not seen a Demand-Supply Plan. This is not the analysis, but the The demand-supply plan was outlined in detail in the
                        plan as where the water is come from, where it is going to go, the timing of water license application submitted to Front Counter
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                        these withdraws, and what purpose it will be used for. At this point, only two      BC in May 2007, which GAS presume MOE has a
                        points of diversion are proposed on the Brohm River. This plan would confirm        copy for their review. The information was also
                        that the water licensing is for two points of diversion, and that other points of   provided in the Master Plan (see citation above),
                        diversion are not being proposed. MOE will need this information to write up        dated April 2003. In both documents, the demand
                        the water technical report; the what-where-when of the proposed diversions on       scenarios include snow-making demand.
                        the Brohm River.

                        MOE-WSD December 18, 2009 comment response:
                        If the November 2009 Plan in the GAS November 17, 2009 letter report on
                        Water Supply Issues for the proposed Garibaldi at Squamish Project is
                        approved as the water supply plan, the demand and supply analysis must
                        address all points of diversion in the two systems: Brohm River and the East
                        Brohm. The permitting stage reviews the water supply at a point, and the water
                        demand at that point. The demand is the water diverted for immediate use in
                        the resort, and water diverted into storage.

                        The storage analysis shows that the resort needs to develop storage, 440,000        Correct. One point of this preliminary analysis was
                        m3 to 1,000,000 m3. The question is how large of a reservoir, which is              to highlight one of the potential values of
                        dependent on which per capita demand curve used: Sun Peaks, DOS, or                 implementing a water conservation program at GAS,
                        Squamish. This may raise an issue of whether the proposed reservoirs are            namely a reduction in reservoir size.
                        large enough depending on the per capita criteria.
                                                                                                      GAS has provided supplementary information on
                        MOE-WSD December 18, 2009 comment response:                                   water storage on November 17, 2009.
                        The November 2009 Plan resulted in major changes to the project, resulting in
                        two Supplement Storage reservoirs being added to the project, and two
                        Snowmaking Storage reservoirs being dropped from the project. If the
                        November 2009 Plan becomes the approved plan for the resort, the water
                        licence application will need to be amended.

                        The demand per capita flows applied to building, townhouses, and hotels. The The demand scenarios used in this preliminary
                        analysis does not appear to include snowmaking flows; this should be analysis were those used in the Master Plan;
                        confirmed by the proponent.                                                  snowmaking demand was included.

                        MOE-WSD December 18, 2009 comment response:                                         GAS provided information on water supply and
                        The November 2009 Plan dropped Snowmaking Storage #1 and #3 from the                storage in its November 17, 2009 letter report on
                        project. This change means that the snowmaking demand would be supplied             Water Supply Issues for the proposed Garibaldi at
                        by Snowmaking Storage #2 and the remainder from the other reservoirs (in            Squamish Project
                        their order of construction). At the permitting stage, it is likely that MOE-WSD
                        will request information to explain how the snowmaking demand would be
                        balanced against the water supply for the resort.

                        To date, little or no discussion on snowmaking, this could be discussed in the As noted in a previous response, snowmaking
                        Demand-Supply Plan. The plan had some reservoirs on the ridges, MOE is not demand was included in this preliminary analysis. It
                        sure if those proposed reservoirs are still in the plan.                       was not the intent of this analysis to explore all the
                                                                                                       issues relating to water demand and supply. The
                        MOE-WSD December 18, 2009 comment response:                                    five reservoirs outlined in the Master Plan and Water
                        The November 2009 Plan dropped Snowmaking Storage #1 and #3 from the License application are still being considered.
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                        project. This change means that the snowmaking demand would be supplied
                        by Snowmaking Storage #2 and the remainder from the other reservoirs (in             GAS provided information on water supply and
                        their order of construction). At the permitting stage, it is likely that MOE-WSD     storage in its November 17, 2009 letter report on
                        will request information to explain how the snowmaking demand would be               Water Supply Issues for the proposed Garibaldi at
                        balanced against the water supply for the resort.                                    Squamish Project. [EAO Note: In this report GAS
                                                                                                             revised the GAS storage options – storage options
                                                                                                             include some previously identified and two new
                                                                                                             storage reservoirs]

                        It is not clear in the reservoir sizing analysis, where the withdrawals are coming Concur; this may not have been clear in the
                        out of the watershed? They have two points of diversion, but there is only one memorandum. The preliminary analysis shown in
                        storage analysis.                                                                  Figures d through f is based on allowable withdrawal
                                                                                                           rates determined from the upper limit of fish access
                        MOE-WSD December 18, 2009 comment response:                                        point. As noted in the memorandum, it appears that
                        The November 2009 Plan proposes at least 6 points of diversion. The the allowable withdrawal rates determined at this
                        permitting stage reviews the water supply at a point, and the water demand at point are more restrictive than those estimated at the
                        that point. The demand is the water diverted for immediate use in the resort, Primary and Secondary Diversion Points, thus
                        and water diverted into storage.                                                   Urban System’s used this for purposes of the
                                                                                                           discussion. Also as noted in the memorandum, the
                                                                                                           withdrawal rates were not optimized.

                        The Dec 1, 2008 Urban Systems letter shows that the proposed resort has to Correct. This has always been the assumption; see
                        develop storage, or the flows in the Brohm River are at times not sufficient for for example the Master Plan.
                        the resort. To fill up the reservoir, this could be done in the spring freshet, and
                        topped up in the fall rain period.

                        MOE-WSD December 18, 2009 comment response:
                        Reservoirs are managed by accounting inflows, outflows, and changes in
                        storage, or the “operating rule.” On the Brohm River, water could be withdrawn
                        during the spring snow melt period. More detailed information on the “operating
                        rule” would be needed at the permitting stage.

                        [EAO Note: In letter correspondence dated July 20, 2009 GAS advised the
                        EAO that the spring freshet and other times of the year in which high volume
                        flow occur would be used for water withdrawal. On December 17, 2009 EAO
                        in a letter asked for clarification from GAS on the July 20th letter since the GAS
                        November 17, 2009 letter report on Water Supply Issues for the proposed
                        Garibaldi at Squamish Project Urban Systems Ltd. Letter mentioned that
                        “…water can oly be withdrawn during the spring snow melt period”.]

                        Need to confirm that the MIKE-SHE watershed modeling is still under                  GAS and MOE agreed in November 2008 to use the
                        development, and that it would use a long term dataset. The expectation of           MIKE-SHE model for modeling flows in the Brohm
                        the Water Working Group was that a watershed model would be developed to             River. The model is in development. Preliminary
                        answer the question of sufficient flows on the Brohm River.                          results were presented at the meeting on 20 January
                                                                                                             2009. The flow data collected by NHC and the 20
                        MOE-WSD December 18, 2009 comment response:                                          year modeling results from Urban Systems were
                        It is understood that the MIKE-SHE watershed model is being updated by               provided to the EAO in draft in February 2009 as
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                        Urban Systems, and may be available for review in late 2009, early 2010.          part of the Addendum 3 materials.
                        [EAO Note: In letter correspondence dated December 17, 2009, EAO asked
                        GAS for clarification on what additional studies or reports GAS Inc. intends to
                        submit to EAO for consideration in drafting the assessment report and when
                        any such information will be submitted to EAO.

                        The MIKE-SHE model was developed to provide information on the feasibility
                        of the Brohm River watershed as a water supply for the ski resort. A water
                        supply feasibility analysis is based on available information, regional
                        hydrology, 1-year hydrometric flows, 2-year hydrometric flows, and so on. At
                        each level of analysis, it is expected that the analyst re-confirms that the
                        Brohm River can provide a long term water supply for the proposed resort.



                        The flows for the filling up the reservoir can be modeled in MIKE-SHE, and        Concur. Urban Systems do note that, in order to
                        GAS would be able to predict the downstream flow changes. The watershed           determine allowable withdrawal rates, the model
                        model or analysis would also show that the reservoirs will be topped up on an     must be run without demands applied in order to
                        annual basis, and there is water for environmental flows.                         determine flow rates in the streams at the analysis
                                                                                                          points.
                        MOE-WSD December 18, 2009 comment response:
                        Proposed diversion rules or reservoir “operation rules,” should be presented to
                        agency reviewers, for discussion and feedback. The issue is running the MIKE-
                        SHE watershed model for diversion rules, when reviewers may have
                        outstanding concerns on certain parameters or procedures.

                        The 20-year run for the watershed model was to show that the proposed resort      Concur. It was not the intent of the memorandum to
                        could be supplied by the Brohm River. It is MOE’s understanding this is what      replace the full analysis that is required to support
                        the Water Working Group wanted to see, an analysis that shows that over the       the water license application or to respond to all the
                        long term the Brohm River can supply the proposed resort.                         Water Working Group’s concerns, only to lay a basis
                                                                                                          for proceeding with analysis. That is, if the results of
                                                                                                          this analysis had suggested there was insufficient
                        MOE-WSD December 18, 2009 comment response:                                       water available for withdrawal, then other avenues
                        The 20-year run for the watershed model is to include a basis for proceeding      (such as groundwater withdrawal) would need to be
                        with the Brohm River system and with the East Brohm system as a long term         pursued. Instead, our interpretation of the results
                        water supply for the ski resort. Rather than reporting the merged capacity of     leads Urban Systems to believe that it is possible to
                        the two systems, the analysis should present separate demand-supply               obtain sufficient surface water for GAS Resort from
                        analyses for the Brohm and East Brohm.                                            the Brohm (or, more correctly, its small tributaries)
                                                                                                          and therefore it is worthwhile to continue developing
                                                                                                          more rigorous analysis (that is, the long-term
                                                                                                          hydrologic modeling) to confirm or revise this belief.

                                                                                                          GAS and MOE agreed in November 2008 to use the
                                                                                                          MIKE-SHE model for modeling flows in the Brohm
                                                                                                          River.
                                                                                                          The flow data collected by NHC and the 20 year
                                                                                                          modeling results from Urban Systems were provided
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                                                                                                              to the EAO in February 2009 as part of the
                                                                                                              Addendum 3 materials.

  121. February   DOS       The following comments refer to Addendum 3 – Water Supply (Brohm River Comment noted
       26, 2009             Hydrometric Program Report (February 2009) and Brohm River Watershed
       and                  Long-Term Hydrologic Analysis Interim Report(February 2009) and GAS
       December             November 17, 2009 letter report on Water Supply Issues:
       10, 2009             The assumption that favourable conditions for water extraction will occur,
                            without fail, during the annual freshet appears to be a risk laden proposition.
                            From a governance perspective any instance of not being able to meet the
                            water supply requirements of the resort would be unacceptable, no matter how
                            infrequent. In our opinion this inherently risky approach is exacerbated by the
                            following elements of the water supply strategy and the current level of
                            understanding of the issues.

                            The streamflow monitoring conducted by NHC represents only one year of            Northwest Hydraulic Consultants Ltd. (NHC)
                            data. This data has been used by Urban Systems to calibrate the water model       installed four hydrometric stations for streamflow
                            that identifies the delivery capacity of the watercourses. DOS understands that   monitoring along Brohm River and its tributaries
                            a second year of data collection will be available in August and this will be     within the proposed Garibaldi at Squamish Resort
                            used to confirm the predictive ability of the model.                              site in August 2007. The objective of the network of
                                                                                                              stations is to assess the water supply potential for
                                                                                                              the development and potential impacts of water
                                                                                                              withdrawal on aquatic habitat.
                                                                                                              Primary Diversion and Secondary Diversion points
                                                                                                              were previously determined by Urban Systems
                                                                                                              (2003) and accordingly, two stations are situated on
                                                                                                              the corresponding tributaries of Brohm River. As
                                                                                                              anadromous fish habitat is known to extend from the
                                                                                                              confluence with the Cheekeye River upstream to the
                                                                                                              Brohm River FSR bridge crossing immediately off
                                                                                                              Hwy 99, two stations were installed in that reach of
                                                                                                              the river: one located at the bridge itself, and the
                                                                                                              other approximately 100 m upstream of the
                                                                                                              confluence.

                                                                                                              In August of 2009, two years of data will be available
                                                                                                              for model calibration and testing. To date, NHC has
                                                                                                              developed rating curves that satisfy the original
                                                                                                              scope of defining low and average flows for the
                                                                                                              period of record at all four sites. Rating curves are
                                                                                                              well defined for low- and mid-flows (for the period of
                                                                                                              record) as multiple measurements have been made
                                                                                                              for this range. Higher flows have been requested to
                                                                                                              better define flow hydrographs for model calibration,
                                                                                                              but unfortunately freshet flows for this year are
                                                                                                              below average and adequately high flows could not
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                        •   December 10th comment – The water model should be reconciled with          be obtained; higher flows may be expected to occur
                            the 2008-2009 streamflow monitoring data and any adjustments               in June/July.
                            necessary to the supply side calculations should be made. The
                            sensitivity of supply to return periods in excess of 25 years should be    The updated water Model for 2009 – GAS
                            investigated; Not addressed. We understood that the 2009 hydrometric       acknowledges this is not yet available but it is
                            data would be available in August 2009. The comment in the Urban           underway. However this update with the second
                            Systems November 16 report is that the model will be updated before        year of data is not required for the EAO assessment
                            the end of the year                                                        report to be finalized. It will be required as part of
                                                                                                       MOE’s water license requirements.

                        •   The modeling input has included the NHC data as well as                    While it is true that the hydrologic model has used
                            historical (18 year) precipitation records. Runoff and soil                limited data, it is also true that the model is
                            permeability factors have been estimated based on limited on site          calibrated. Further the model is a process, or
                            investigations. Given the limited amount of data DOS believes              physically-based model as opposed to an empirical
                                                                                                       model. One of the advantages of such a model is
                            that only a probabilistic approach can be applied to assessing the
                                                                                                       that it results can be reasonably obtained from
                            certainty of a surface water based supply. Therefore the                   conditions differing from the calibration period with
                            confidence levels of the model results should be clearly identified        greater certainty than with an empirical model.
                            as well as the sensitivity of the model output to the variability of
                            the input parameters. The conservative assumptions regarding               Model uncertainty in the present state may also be
                            water consumption (650lpcd) can then be put into perspective.              addressed by established model uncertainty
                                                                                                       estimations (e.g. Generalized Likelihood Uncertainty
                        •   December 10th comment: see comments above on conservative
                                                                                                       Estimation -GLUE), which can utilize Monte Carlo
                            demand.                                                                    simulations to produce an ensemble of model
                                                                                                       outputs based on the range of possible model
                                                                                                       parameter combinations.        Uncertainty stemming
                                                                                                       from model calibration can then be estimated from
                                                                                                       these ensembles. Model uncertainty may further be
                                                                                                       reduced with measurement of high elevation
                                                                                                       precipitation, since geographic effects in the
                                                                                                       watershed cannot be accurately estimated from
                                                                                                       existing low elevation climate stations.

                        •   No data has been collected on sediment transport associated with the       Sediment source and transport will be assessed as
                            watercourses. This may only be a design issue for the water extraction     part of the detailed geomorphologic field surveys
                            infrastructure however it is important to understand whether the           and a determination made as to impacts on
                            sediment load will bear on extraction rates. There is also a governance    operating costs.
                            concern that there might be a significant embedded operating cost
                            associated with sediment removal or erosion control.
                        •   December 10th comment:: Not addressed                                      Janaury 26, 2010 - GAS filed a Preliminary
                                                                                                       Overview-Level       Geomorphological      Impact
                                                                                                       Assessment - Reservoirs, Water Intakes, Stream
                                                                                                       Crossings & Forest Harvest - Prepared by: Enkon
                                                                                                       environmental Ltd. in Addendum 3 to the Garibaldi
                                                                                                       at    Squamish    EAO     Additional  Information
                                                                                                       Requirements

                        •   In a typical water system, water for fighting fires is replenishable. It is Firefighting needs can be met with only a fraction of
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                            unclear how much storage will be embedded for these purposes before       the volume required for a typical year at the resort.
                            water reserved for consumption is affected. The resort will also create   Additional discussion has been added to the
                            a Forest Fire Interface Hazard which raises further concerns regarding    Updated Interim Report to address this issue. GAS
                            adequate water for fire fighting purposes. Likely wells will be needed.   Inc. has committed to prepare an overall
                                                                                                      contingency plan and a fire prevention plan for
                                                                                                      accidents, malfunctions and other emergencies at
                                                                                                      the detailed design phase of the project or prior to
                                                                                                      construction. The plan will be consistent with the
                                                                                                      requirements of Canada Standards Association
                                                                                                      Standard        Practice        CAN/CSA-Z731-M91:
                                                                                                      Emergency Planning for Industry and the
                                                                                                      international Incident Command System (ICS) as
                                                                                                      per the standard for site (Command Post) level of
                                                                                                      the BC Emergency Response Management System.
                                                                                                      GAS Inc. has also committed to preparing an
                                                                                                      independent fire protection assessment that will be
                                                                                                      prepared before any service provision agreement
                                                                                                      could be made (in the case of non-annexation) or
                                                                                                      before establishing on-site services (in the case of
                                                                                                      annexation).      The assessment will document
                                                                                                      information pertaining to development features (e.g.,
                                                                                                      building heights, prevalence of sprinklers), water
                                                                                                      storage capabilities, access road snow removal
                                                                                                      equipment/ practices, commercial square footage,
                                                                                                      population levels, and wildland-urban interface
                                                                                                      issues. While there is no set formula for determining
                                                                                                      equipment and staffing requirements, the results of
                                                                                                      the above assessment would be used to determine
                                                                                                      appropriate resources. For example, the maximum
                                                                                                      heights of buildings would be used to determine
                                                                                                      whether an aerial truck is required.

                        •   At the February 18 Working Group meeting doubt was cast on whether        Each hydrometric station consists of a pressure
                            the method used to establish base flows in Brohm River will stand up to   transducer installed in a stable, deep part of the
                            DFO scrutiny / approval. Again this must be understood in order           channel, which records and logs water level (stage)
                            support the capacity of the watercourses to deliver sufficient water.     and temperature data at specified intervals.
                        •   December 10th comment: DOS reiterated that the amended demand/            Discharge measurements are made at the site under
                            supply values should be vetted with Brohm River and tributary             various flow conditions throughout the range of
                            watercourse base flow requirements. Again DOS noted that they             stage to capture as much of the available data as
                            understand that this work is ongoing.                                     possible. NHC utilizes a range of techniques, which
                                                                                                      include: current metering, salt and dye dilution, or an
                                                                                                      Acoustic Doppler Current Profiler (ADCP).
                                                                                                      With manual measurements, discharge is assessed
                                                                                                      by measuring depth and velocity at a minimum of 20
                                                                                                      points across the channel cross-section, typically
                                                                                                      with a Price® AA or Swoffer® propeller-type current
                                                                                                      meter to measure velocity along the transect. With
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                                       dilution or ADCP measurements, multiple measures
                                       are assessed at a single station. Dilution and ADCP
                                       measurements require thorough post-processing,
                                       and post-measurement stream water calibrations
                                       (titrations) are also required for dilution methods to
                                       determine concentration curves for mass balance
                                       calculations used in the estimation of flow. Stations
                                       are operated to meet Class A/B standards
                                       according to the BCMOE RIC Hydrometric
                                       Standards (1998). Stage and water level recorders
                                       and flow metering are undertaken with calibrated
                                       standardized equipment to limit measurement error
                                       to ± 10%.        Stage-discharge rating curves are
                                       developed for each site by plotting individual
                                       discharge values against the corresponding stage at
                                       the time of each discharge measurement. The rating
                                       curve can then be used to transform the continuous
                                       stage record from the pressure transducer into a
                                       continuous record of discharge. Changes in channel
                                       geometry can cause the relation between stage and
                                       discharge to change over time. For example,
                                       channel erosion or deposition during storms events,
                                       or the placement of bank protection works, can
                                       affect the stage-discharge relation. To check the
                                       accuracy of the stage measurements, the offset
                                       distances from the sensor and water level back to a
                                       site benchmark is recorded. This allows for vertical
                                       adjustments in the channel section to be recorded
                                       with offset measures applied to the data to correct
                                       the record, or for alternate stage-discharge curves to
                                       be developed. Once the discharge measurements
                                       are recorded, calibrated, and verified, the data can
                                       be corroborated through examining other regional
                                       streamflow data, precipitation data within the basin,
                                       and internal gauged areas to validate flow records at
                                       a site.
                                       NHC tests all data loggers in-house prior to field
                                       deployment to ensure functionality and manufacturer
                                       specified maximum and typical accuracies. This
                                       consists of testing each pressure transducer in a
                                       testing tank and verifying physical water levels to
                                       sensor readings for rapid short term water level
                                       fluctuations and longer term stable water levels. All
                                       flow measurement equipment is regularly tested and
                                       calibrated to minimize data errors resulting from flow
                                       measurement, and involves velocity calibrations with
                                       a known flow orifice for velocity meters, and
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                                                                                                             concentration calibrations for dilution equipment.
                                                                                                             Each hydrometric station consists of a Solinst®
                                                                                                             Levelogger which records and stores stage (water-
                                                                                                             level) and water temperature values at a 15-minute
                                                                                                             interval.    Stage     sensors  record    combined
                                                                                                             atmospheric and hydrostatic pressure. Two Solinst®
                                                                                                             Barologgers have been installed at an upper
                                                                                                             elevation and lower elevation site and compensate
                                                                                                             for the atmospheric pressure component.
                                                                                                             The data loggers are housed in 2-inch steel pipes
                                                                                                             with standard lockable well caps. At each site, three
                                                                                                             benchmarks were established and surveyed to
                                                                                                             provide vertical reference points. The pipes are
                                                                                                             mounted on galvanized steel angle-iron and bolted
                                                                                                             into large, stable boulders.

                           •   DOS is unclear as to what extent treated wastewater effluent may              The surplus will not get into the reservoirs or storage
                               impact surface waters. It is understood that this effluent will be used for   areas as the discharge points are downstream of the
                               on-site irrigation; however, DOS expectation is that the volume to be         withdrawal (diversion) points. GAS has committed
                               disposed of would be far in excess of those needs and would vary              to undertake an environmental impact study on the
                               seasonally. Ensuring that any such surplus would have no access to            river that is ultimately selected to receive treated
                               the watercourses and reservoirs or that the impact would be well below        effluent to confirm the necessary effluent criteria to
                               acceptable assimilation rates from both an ecological and potable water       protect the environment and public health. This is a
                               perspective is critical.                                                      necessary part of registering under the Municipal
                                                                                                             Sewage Regulation and is therefore, deemed to be
                                                                                                             part of the detailed design phase of the project.

                           •   Groundwater source development has been identified as the                     GAS Inc. has assessed groundwater supply as a
                               supplementary or contingency water supply option.                From the     backup source only for any potential shortfall from
                               preliminary findings of the Piteau report it appears that the Cheakamus       surface water supplies. If a shortfall is identified
                               River provides the only viable groundwater source.                  Piteau    from the surface water supply through the water
                               recommends that a test well program be undertaken to prove out the            licensing process, GAS Inc. will conduct detailed
                               capacity of Site B and to definitively ascertain whether it is a GUDI site.   assessments of groundwater supplies both on and
                               The potential natural hazards associated with this water source need to       off-site to determine the most practical and cost-
                               be understood as well.                                                        effective supply solution
                           •   December 10th Comment: The Urban Systems November 16 report
                               indicates that supplementary groundwater sources need not be
                               investigated further in advance of the EA Certificate or Water Licence
                               being issued. Given the uncertainty expressed in the original Piteau
                               report the District must disagree.


                        It does not appear that the certainty of a sustainable water supply has been         GAS Inc. has committed to meet the requirements of
                        proven at this point. DOS understanding is that the water licencing process          the “BC Instream Flow Threshold for Fish and Fish
                        that would follow the EA certification would ensure that the amount of water         Habitat as Guidelines for Reviewing Proposed Water
                        extracted from the watercourses would not exceed acceptable levels. It would         Uses” (2004). Preliminary results have indicated
                        not necessarily ensure that the amount of water needed to meet the resort’s          that the first tier scoping level assessment that
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                              demand would be available. If this understanding is correct then it is the          provides thresholds for alterations to natural stream
                              DOS’s view that the environmental assessment process should do what is              flows that are expected to result in low risk to fish,
                              necessary to determine with certainty that the combined capacities of the           fish habitat, and productive capacity has been met
                              various water supplies will meet or exceed GAS’s buildout requirement.              for the full build-out of the resort. If, during the water
                                                                                                                  licensing process GAS Inc. determines that
                              DOS December 10th comment conclusion: Concluding the work on water                  additional surface/groundwater is required to support
                              model should be reconciled with the 2008-2009 streamflow monitoring data            the full build-out of the project, GAS Inc. will conduct
                              and any adjustments necessary to the supply side calculations and the               an environmental impact assessment and seek
                              amended demand/supply values should be vetted with Brohm River and                  approval from the appropriate regulatory agencies.
                              tributary watercourse base flow requirements is necessary to understand the
                              supply side of the water equation and the viability of the water supply proposal
                              for the GAS project. DOS looks forward to receiving this information and
                              providing a fuller comment at that time.


  122. October 1,   EAO       The following comments refer to Addendum 3 –Brohm River Watershed Long-             In the response to the EAO letter of Oct 1st, GAS
       2009                   Term Hydrologic Analysis Interim Report (May 2009): In order to complete the        Inc. had three reports developed that assessed
                              EA for the proposed Project, EAO will need specific information on reservoirs       water demand, storage requirements and updated
                              or alternative supply methods sufficient to supply 100% of the water required to    previous application geotechnical and environmental
                              operate the proposed Project at full build out (including sufficient water supply   impact assessments. The reports and a cover letter
                              for fire-fighting).                                                                 from GAS were provided to EAO November 17,
                                                                                                                  2009.
                              Provide a description of how water will be stored and/or supplied to the
                              proposed Project to meet 100% demand (with minimum demand calculated In the first of those three reports, Urban Systems
                              using the DOS number of 455 litres/person/day) at full build out of the estimated the water demand based on resort
                              proposed Project.                                                        capacity numbers established with MTCA, using the
                                                                                                       daily water demand of 455 lpd adopted by DOS for
                                                                                                       its subdivision and development control bylaw.
                                                                                                       Urban then calculated the storage requirements and
                                                                                                       determined needed reservoir options to meet the
                                                                                                       water demand and storage requirements to full build
                                                                                                       out of the resort. That demand and supply
                                                                                                       addresses water required for potable, snowmaking
                                                                                                       and fire fighting residential irrigation needs.

                              If any reservoirs are to be expanded, provide a conceptual plan for the             Urban located reservoir capacity on a conceptual
                              expanded reservoirs and dam consistent with the requirements for                    plan needed to meet resort requirements, and
                              Geotechnical Assessment of proposed water storage reservoirs and dams               Thurber Engineering assessed the proposed
                              outline in EAO’s October 16, 2007 letter to GAS Inc.                                locations from a geotechnical perspective regarding
                                                                                                                  public safety, addressing the safety and feasibility of
                                                                                                                  constructing and operating the proposed reservoirs.

                              If any new reservoirs are to be constructed, provide a conceptual plan for the      Thurber Engineering assessed the proposed
                              new reservoirs and dam, consistent with the requirements for Geotechnical           locations from a geotechnical perspective regarding
                              Assessment of proposed water storage reservoirs and dams outline in EAO’s           public safety, addressing the safety and feasibility of
                              October 16, 2007 letter to GAS Inc.                                                 constructing and operating the proposed reservoirs.
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                            Provide a quantified assessment of the anticipated impacts from vegetation      Enkon Environmental updated an assessment of the
                            and wildlife habitat removal associated with the expansion or creation of new   existing forest cover, wildlife habitat, and
                            reservoir capacity, consistent with the requirements for Geotechnical           habitat/vegetation impacts – noting the changes
                            Assessment of proposed water storage reservoirs and dams outline in EAO’s       associated with the proposed reservoir locations in
                            October 16, 2007 letter to GAS Inc.                                             the conceptual plan. Enkon quantified the reservoirs
                                                                                                            options by ranking the likely environmental effects.

                            Ensure that any revised proposal for water storage and supply is consistent The reports demonstrate a viable water supply and
                            with all relevant aspects of EAO’s letters dated October 16th and December 10, storage plan, needed to meet the resort’s full
                            2007, and May 14, 2008.                                                        buildout requirements based on the DOS water use
                                                                                                           consumption rate, with manageable effects, meeting
                                                                                                           both public safety and resort layout/design
                                                                                                           objectives.

                            If alternative sources of water supply are proposed, such as use of             The Brohm River remains GAS’ preferred option for
                            groundwater, provide a full description and assessment of this proposal,        water supply, and alternatives such as groundwater
                            consistent with directions provided in EAO’s letters dated October 16th and     are not being proposed at this time. Notwithstanding
                            December 10, 2007, and May 14, 2008.                                            this, GAS might pursue a groundwater supply option
                                                                                                            to supplement the Brohm River water supply.
                                                                                                            Preliminary work by Piteau and Associates
                                                                                                            completed in past years and their ongoing work
                                                                                                            program with GAS, strongly suggests a groundwater
                                                                                                            supplemental supply is a practical and achievable
                                                                                                            option. GAS could further investigate this option
                                                                                                            with more assessment and test well drilling
                                                                                                            programs once the resort project is certified by the
                                                                                                            EAO. GAS has committed in the EA process, to
                                                                                                            conduct an environmental impact assessment and
                                                                                                            seek approval from the appropriate regulatory
                                                                                                            agencies, if at any time during the Development
                                                                                                            Phases, GAS determines that additional surface
                                                                                                            water or groundwater is required to support the
                                                                                                            build-out of the Project. GAS will maintain all other
                                                                                                            EAO commitments and ensure all permit processes
                                                                                                            are followed if the groundwater assessment option is
                                                                                                            undertaken at some time in the future development
                                                                                                            of the resort.

  123. December   EAO       The following is a summary of comments from the EA Working Group on a
       17, 2010             letter report dated November 16, 2009, by Urban Systems Ltd. regarding
                            “Garibaldi at Squamish Resort – Update on Water Supply Issues”:

                               •   Pg 1, 2nd paragraph: Urban Systems Ltd. refers to a conservation GAS can confirm the water consumption
                                   water consumption rate of 200 litres per capita per day, however in the conservation target we have proposed is 220 LPD
                                   past GAS Inc. has referred to this rate as 220 litres per person per day. not 200, this was a typographical error.
                                   While this doesn’t affect subsequent calculations, EAO assumes the
                                   220 number is the conservation water consumption rate that GAS Inc
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                                   believes they can achieve.

                               •   Pg 2, last paragraph: water consumption is based on occupancy rates         This is the number Urban Systems, our professional
                                   that vary between 25% and 59% over the year, with an average of             consultant, used in this report based on similar water
                                   39%. Has any consideration been given to the likelihood of increased        demand studies at another resort and US has not
                                   occupancy rates in the future and how this will affect seasonal and total   yet used other numbers in an effort to further
                                   water requirements for the proposed project?                                understand water demand to date. GAS is working
                                                                                                               with MTCA to determine if this occupancy number is
                                                                                                               reasonable over the long term, recognizing that
                                                                                                               seasonality, accommodation mixes, day skier or
                                                                                                               other day visitor numbers and other factors need to
                                                                                                               be considered in this, but GAS agrees such a
                                                                                                               number for the resort population and bed unit
                                                                                                               occupancy seems reasonable at this time

                               •   Pg 3, 2nd paragraph under Water Storage: the Urban Systems Ltd. Reference to "spring freshette" is to be as GAS
                                   report states “...water can generally only be withdrawn during the spring proposed in the July 20th letter and the US report
                                   snow melt period ...”. A July 20, 2009 letter from GAS Inc. previously does not amend or alter this.
                                   revised this wording to include “...the spring freshet and other times of
                                   the year in which high volume flow occur ...” for purposes of the EA and
                                   the water license application. Please confirm the wording in the July 20
                                   letter remains as the GAS Inc. proposal and it has not been amended
                                   by the Urban Systems Ltd. report.

  124. December   EAO       The following is a summary of comments from the EA Working Group on a
       17, 2009             report dated November 16, 2009, by Thurber Engineering Ltd., regarding
                            “Garibaldi at Squamish – Water Storage Facilities Addendum to October 18,
                            2007 Report”:

                            Impoundment Details - Original Primary Storage: the reservoir dam was
                            originally proposed as 20-24 m high, with a capacity of 200,000 m3, however
                            the dam is now proposed as 30 m high with a capacity of 148,000 m3 ; there is
                            no explanation as to why a higher dam results in a reduced storage capacity.

                            Construction Materials - The report reiterates the Thurber Engineering Ltd.
                            2007 report statement that “We do not expect there will be any difficulty in
                            obtained sufficient, suitable dam fill material.” However, there is no
                            explanation as to where that material will be obtained from. With the greatly
                            expanded volume of dam construction material now required (two new 50 m
                            high dams are now proposed and two original proposals are enlarged) the
                            potential for requiring new borrow pits for either rock fill or impermeable till
                            materials has been raised considerably. More information on the source of
                            dam construction materials is needed.

                            Geotechnical Hazards and Risks
                            The map and description of Terrain Units in the 2003 Application (Volume 6)
                            has been reviewed in concert with the current Thurber Engineering Ltd. report.
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                        The five dams proposed have the following characteristics:
                           • Orig. Primary Storage:        Located in terrain units with High hazard
                               potential and slopes ranging from 30-70%; dam height is 30 m
                           • Orig. Secondary Storage: located in terrain units with Moderate hazard
                               potential and slopes of 15-60%; dam height is 20 m
                           • Supplemental Storage 1: located in terrain units with High hazard
                               potential and slopes of 50-70%; dam height is 50 m
                           • Supplemental Storage 2: located in terrain units with High (?) hazard
                               potential and slopes of 50-70%; dam height is 50 m. The TE report
                               states a debris slide was identified below the dam and should be
                               inspected. However, when comparing the location of this reservoir and
                               dam against the US and Enkon reports, it appears that TE has an
                               incorrect location and the debris slide is adjacent to the reservoir and
                               upstream from the dam site.
                           • Snowmaking Storage 2: located in terrain units with High hazard
                               potential and slopes of 50-70% (units 190 and 184) and in a unit with a
                               None Apparent hazard potential rating and slopes of 5-60%; dam
                               height is 20m.

                        The Thurber Engineering Ltd. report in Volume 6 of the 2003 Application
                        states, under the heading of “Development Constraints” that: “In general, no
                        development should take place in terrain units that Dwg. 19-2914-1-1 and
                        Table 2 identify as high hazard. This guideline is modified in some areas
                        where development is proposed on a slope of less than 50% in a high hazard
                        polygon if we judge that, at a planning level, the hazard intensity is moderate to
                        low, the hazard consequence is moderate to low and thus the derived total risk
                        is judged to be moderate to nil.” Noting that 4 of the 5 proposed dams
                        described above are located in terrain units with high hazard potential and
                        slopes that exceed 50%, no explanation has been provided in TE (2009) as to
                        why these developments are not subject to the development constraint
                        described in the earlier report. This creates considerable uncertainty about the
                        proposed dam locations (and the associated hazard intensity and hazard
                        consequences), particularly since two of these structures are now proposed to
                        be 50 m high and are located upstream from proposed residential and
                        commercial areas.

                        In addition, the debris slide in terrain unit 222 that was highlighted in both the
                        TE 2003 and 2009 reports is actually located in the reservoir above the newly
                        proposed 50 m dam (not below the dam); this was mis-located in the Thurber
                        Engineering Ltd. 2009 report. This indicates the risks/hazards for this reservoir
                        have not been properly assessed.

                        Finally, Northwest Hydraulic Consultants, in their April 25, 2009 report (GAS
                        Application, Addendum 3) notes several types of flood hazards in the Brohm
                        River drainage, including that the higher gradient sections of the Brohm River
                        that are linked to upslope processes will be subject to debris flows, sediment
                        and debris events and debris floods.
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                               EAO recognizes that detailed design and risk/hazard assessments are
                               conducted as part of the dam safety review in a water licensing process,
                               however the general concerns raised above regarding inconsistencies and
                               inaccuracies in information submitted for an EA decision create considerable
                               uncertainty regarding the feasibility and potential for impacts from the
                               proposed reservoirs and dam structures.

TOPIC: SOLID WASTE MANAGEMENT

  125. July 9,       SLRD      Information on waste management needs to be updated to reflect 2007 GAS is aware the SLRD is reviewing its Solid Waste                     GAS commits to complying with all
       2007                    situation (Carnie’s no longer has a composter, the Squamish landfill should not Management Plan (SWMP) options for the future,             principles and policies of the
                               be taking sludge, etc.).                                                         which include (1) continued use of the DOS Landfill       Squamish-Lillooet Regional District
                                                                                                                site for the District’s use only, (2) continued use of    “Solid Waste Management Plan for the
                                                                                                                the site by the entire region, and (3) trucking solid     region, (approved November 2008) or
        January 7,             SLRD comments on GAS responses in the Issue Tracking Table and letter            waste to a location outside the SLRD. GAS is not          any of its future amendments and
        2010                   correspondence to Graeme McLaren from GAS Inc. dated December 16,                aware of any decisions regarding the preferred            GAS       will    also    follow the
                               2009:                                                                            option for solid waste disposal.                          recommendations of the SWMP”
                               SLRD commented that the handling of biosolids is not addressed within the                                                                  including preferred option for:
                               SLRD SWMP and should be addressed within a Liquid Waste Management               In a letter dated January 24, 2008, Urban Systems             • Solid waste management;
                               Plan. A viable option for disposal will be required as biosolids are banned from updated solid waste management options and                    • Household hazardous waste;
                               being disposed of at the Squamish Landfill by the MOE.                           concluded the following: GAS will need to work with           • Composting;
                                                                                                                the DOS to get incorporated into the SWMP. It is              • Recycling;
                               A provision should be included regarding land clearing material in that non envisioned at this point that GAS would be charged                 • Collection system/illegal
                               merchantable timber not be burned and that the preference is that it is chipped. the appropriate tipping fee to dump at the                        dumping; and
                                                                                                                new/expanded Squamish Landfill/SLRD regional                  • Tipping fees.
                                                                                                                landfill. If the land fill does not proceed, it is
                                                                                                                expected that eventually all waste in the Valley will
                                                                                                                have to be hauled away.

                                                                                                                Whistler is setting up an in-vessel    composter for
                                                                                                                sludge from their sewage treatment     plant. Sludge
                                                                                                                from GAS could be sent to Whistler,    after GAS had
                                                                                                                paid their share of an expanded        facility or an
                                                                                                                appropriate tipping fee.

                                                                                                                GAS understands that there is a compositing facility
                                                                                                                and a solid waste transfer site is located in Whistler,
                                                                                                                which could take compostable material from GAS

                                                                                                                GAS will incorporate the following principles into the
                                                                                                                resort Solid Waste Management plan:
                                                                                                                    1. The Regional District goal of waste reduction
                                                                                                                       will be endorsed by the Garibaldi Resort.
                                                                                                                       Significant waste reduction will be gained by
                                                                                                                       targeting organic waste from residential
                                                                                                                       users, day use areas, hotels, and food
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                                                                                                               service industries. Garibaldi will meet the
                                                                                                               Regional District’s waste reduction by
                                                                                                               offering the same waste reduction initiatives
                                                                                                               within the Resort in coordination with the
                                                                                                               Regional District.
                                                                                                           2. GAS will endorse the Squamish Lillooet
                                                                                                              Regional District waste reduction principals
                                                                                                              (i.e. reduce, reuse, and recycle).
                                                                                                           3. GAS will participate in the Regional District’s
                                                                                                              waste diversion programs.
                                                                                                           4. The Resort will implement as many proactive
                                                                                                              waste reduction measures as possible (i.e.
                                                                                                              Disposal ban on recyclable materials, yard
                                                                                                              waste and products covered by product
                                                                                                              stewardship programs). and
                                                                                                           5. Separate out biosolids and hauling the
                                                                                                              biosolids to the in vessel composter in
                                                                                                              Whistler, and if this option is not available,
                                                                                                              examining alternative disposal options for
                                                                                                              biosolids;
                                                                                                           6. Meeting or exceeding the Resort Municipality
                                                                                                              of Whistler standards for wildlife and water
                                                                                                              management to avoid human bear conflicts,
                                                                                                              and by using animal proof receptacles for
                                                                                                              any items that may attract wildlife; storing
                                                                                                              waste in buildings or bins on-site that do not
                                                                                                              allow animal access while awaiting transfer
                                                                                                              to other locations;
                                                                                                           7. Not providing curbside waste collection to
                                                                                                              avoid attracting animals and potential
                                                                                                              animal/human conflicts; and,
                                                                                                           8. Implementing a bear awareness and safety
                                                                                                              program.
                                                                                                        GAS Inc recognizes that the resort is responsible for
                                                                                                        developing and implementing an acceptable solid
                                                                                                        waste management plan, and in the unlikely event
                                                                                                        the existing regional waste management facilities
                                                                                                        cannot accommodate GAS wastes, GAS will
                                                                                                        investigate an independent solid waste management
                                                                                                        disposal facility or disposal option.

  126. August 30,   Ministry of   Since the disposal of solid waste is the mandate of the SLRD, the addition of GAS will consult with SLRD regarding the GAS commits to complying with all
       2007         Environmen    the Garibaldi project would require a major amendment to the SWMP and development’s effect on and place in the SWMP.   principles and policies of the
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                    t,           therefore full consultation and review and be signed off by the Minister of                                                                 Squamish-Lillooet Regional District
                    Environmen   Environment. In the end, the resort needs to start talks with the SLRD as the                                                               “Solid Waste Management Plan for
                    tal          plan is currently being reviewed for an amendment.                                                                                          the region, (approved November
                    Protection                                                                                                                                               2008) or any of its future amendments,
                    Division                                                                                                                                                 and GAS will also follow the
                    (MOE –                                                                                                                                                   recommendations of the SWMP”
                    EPD)                                                                                                                                                     including preferred option for:
                                                                                                                                                                                 • Solid waste management;
                                                                                                                                                                                 • Household hazardous waste;
                                                                                                                                                                                 • Composting;
                                                                                                                                                                                 • Recycling;
                                                                                                                                                                                 • Collection system/illegal
                                                                                                                                                                                     dumping; and
                                                                                                                                                                                 • Tipping fees.
                                                                                                                                                                             See Action under old #95 above for
                                                                                                                                                                             more detail.

  127. August 30,   MOE – EPD    The project based its Waste Generation Estimates on the 1999 SWMP. Since Regional growth does not affect GAS’s per person GAS commits to complying with all
       2007                      1999, the region has seen significant growth and the numbers formulated may waste generation estimates.                   principles and policies of the
                                 not be realistic.                                                                                                         Squamish-Lillooet Regional District
                                                                                                                                                           “Solid Waste Management Plan for the
                                                                                                                                                           region, (approved November 2008) or
                                                                                                                                                           any of its future amendments, and
                                                                                                                                                           GAS       will    also    follow   the
                                                                                                                                                           recommendations of the SWMP”
                                                                                                                                                           including preferred option for:
                                                                                                                                                               • Solid waste management;
                                                                                                                                                               • Household hazardous waste;
                                                                                                                                                               • Composting;
                                                                                                                                                               • Recycling;
                                                                                                                                                               • Collection system/illegal
                                                                                                                                                                   dumping; and
                                                                                                                                                           Tipping fees. See Action under old
                                                                                                                                                           #95 above for more detail.

  128. August 30,   MOE – EPD    During recent solid waste plan committee meetings between the SLRD, local         GAS is aware the SLRD hired a consultant to review        GAS commits to complying with all
       2007                      municipalities and MOE, not once was Garibaldi at Squamish discussed. It          their SWP and provided options for the future, which      principles and policies of the
                                 would seem with the comment mentioned above that the project would be             include (1) continued use of the DOS Landfill site for    Squamish-Lillooet Regional District
                                 mentioned as it would have a significant impact on numbers and determining        the District’s use only, (2) continued use of the site    “Solid Waste Management Plan for the
                                 which waste disposal method is most prudent (W2E facility, landfill or shipping   by the entire region, and (3) trucking solid waste to a   region, (approved November 2008) or
                                 out all waste).                                                                   location outside the SLRD. While the report was           any of its future amendments, and
                                                                                                                   submitted to the SLRD in late 2007 we are not             GAS       will    also    follow the
                                 If the Garibaldi Resort falls within the DOS boundaries, GAS would be able to aware of any decisions regarding the preferred                recommendations of the SWMP”
                                 use the landfill. If the Garibaldi Resort falls outside the boundaries, GAS would option for solid waste disposal. In addition, we          including preferred option for:
                                 have to come to an agreement with Squamish.                                       understand that Carnie has a compositing facility in          • Solid waste management;
                                                                                                                   Whistler, which could take compostable material               • Household hazardous waste;
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                                A transfer station may be more feasible than pick up and direct haul to a final from GAS.                                                        •   Composting;
                                disposal site based on distance and transportation costs. There is no                                                                            •   Recycling;
                                guarantee that the Squamish Landfill will accept their waste or if it remains                                                                    •   Collection system/illegal
                                open after 2008.                                                                                                                                     dumping; and
                                                                                                                                                                              Tipping fees.
                                Section 3.1.3.2 talks about recycling. The collection of recyclables is part of
                                the SWMP and would need to meet the requirements of the SWMP.

                                Section 3.1.3.3 talks about composting and the implementation of a
                                composting facility for the corridor. The concept of centralized composting for
                                the southern part of the regional district has been a part of the SLRD solid
                                waste management planning process since its inception. Carney Waste
                                Systems began operating in 2004 and was deemed a success as it diverted up
                                to 40% of MSW. Unfortunately, Carney’s was shutdown in late 2006 by the
                                DOS due to complaints. The SLRD is currently reviewing the feasibility of
                                purchasing the facility and moving the location to a better-suited site. A
                                possible location currently being talked about is the new Callaghan Valley
                                transfer station in Whistler. Since the closure of the facility, all residual waste
                                including compostable materials are either being shipped out of the region at
                                great expense or being landfilled at Squamish.

  129. August 30,   MOE – EPD   Household hazardous waste is a stewardship initiative that falls under the            GAS would be interested in developing a hazardous GAS Inc. commits to complying with
       2007                     recycling regulation and the hazardous waste regulation (HWR). If a depot is          waste facility for the resort. Alternatively, it would the B.C. Environmental Management
                                built to handle household hazardous waste, it would need to meet all the              deal with hazardous waste as required by the Act, Hazardous Waste Regulation for
                                requirements of the HWR. In the end, the resort would have to deal with the           SWMP.                                                  household hazardous waste, and in
                                minimization, handling, collection and disposal in conjugation with the SLRD                                                                 the development of a hazardous waste
                                and the SWMP.                                                                                                                                facility for the GAS resort, if this is
                                                                                                                                                                             required.

  130. August 30,   MOE – EPD   UPDATE- The SLRD and Whistler have agreed to purchase the composting GAS has previously noted its understanding that .
       2007                     facility and move it to the new Callaghan Valley transfer station. The transfer there is a compositing facility in Whistler, which
                                station and composting facility should be up and running in the fall, 2007.     could take compostable material from GAS.

                                                                                                                      GAS Inc recognizes that the resort is responsible for
                                                                                                                      developing and implementing an acceptable solid
                                                                                                                      waste management plan, and in the unlikely event
                                                                                                                      the existing regional waste management facilities
                                                                                                                      cannot accommodate GAS wastes, GAS will
                                                                                                                      investigate an independent solid waste management
                                                                                                                      disposal facility or disposal option.

  131. August 30,   MOE – EPD   Section 3.1.3.4 talks about landclearing and construction waste. An alternative       GAS is looking into alternatives to burning such as
                                                                                                                                                                              GAS      commits    to   investigating
       2007                     to landfilling and burning is needed especially in the Sea to Sky corridor.           recycling and onsite composting. If burning is
                                                                                                                                                                              alternatives to burning, wood waste
                                Material bans and/or recycling should be looked into. MOE is unsure where the         necessary, GAS will adhere to all provincial
                                                                                                                                                                              and construction materials and GAS
        Keep                    SLRD is at the reduction of land clearing and construction waste. Any burn            legislation (Open Burning Regulation), air quality
                                                                                                                                                                              will comply with the Open Burning
        separate                would need to meet the Air Quality Management Plan currently being                    objectives and the requirements of the Air Quality
                                                                                                                                                                              Regulation.
                                implemented in the corridor.                                                          Management Plan for the Sea-to-Sky corridor.
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  132. August 30,   MOE – EPD   Section 3.1.3.5 talks about residual waste management. A residual waste Comment noted.
       2007                     management strategy is needed for all regional districts and will be pushed
                                during a plan amendment.

  133. August 30,   MOE – EPD   This section talks about the Whistler landfill and Squamish landfill closing in     GAS is aware the SLRD hired a consultant to review
       2007                     2008. Whistler landfill is already closed while the Squamish landfill is set to     their SWP and provided options for the future, which
                                close in 2008. There is a potential that the Squamish landfill could be extended    include (1) continued use of the DOS Landfill site for
                                depending on certain outcomes. If the landfill is to expand, it would have to       the District’s use only, (2) continued use of the site
                                meet all the current provincial and federal legislation and the permit would        by the entire region, and (3) trucking solid waste to a
                                need to be updated and converted over to an operational certificate. Since the      location outside the SLRD. While the report was
                                Squamish landfill is set to close in 2008, an alternative disposal site should be   submitted to the SLRD in late 2007 we are not
                                looked into and/or look at exporting all the southern corridors waste streams       aware of any decisions regarding the preferred
                                outside of the regional district.                                                   option for solid waste disposal. In addition, GAS
                                                                                                                    understands that there is a composting facility in
                                                                                                                    Whistler, which could take compostable material
                                                                                                                    from GAS.

                                                                                                                    GAS Inc recognizes that the resort is responsible for
                                                                                                                    developing and implementing an acceptable solid
                                                                                                                    waste management plan, and in the unlikely event
                                                                                                                    the existing regional waste management facilities
                                                                                                                    cannot accommodate GAS wastes, GAS will
                                                                                                                    investigate an independent solid waste management
                                                                                                                    disposal facility or disposal option.

  134. August 30,   MOE – EPD   Section 3.1.4.3 talks about collection systems and bear/human interaction. The GAS will work with Revelstoke and Whistler, two                GAS commits to meet or exceed
       2007                     wording needs to be stronger; similar to the RMOW.                             communities that have programs in place to deal                RMOW standards for wildlife and
       Keep                                                                                                    with bear management, to plan for the waste                    waste management to avoid human-
       separate                                                                                                management systems needed to avoid human-bear                  bear and by using animal proof
                                                                                                               conflicts. GAS will also work with DOS about                   receptacles for any items that may
                                                                                                               becoming a “bear aware” area to best manage for                attract wildlife; storing waste in
                                                                                                               bear interactions on site.                                     buildings or bins on-site that do not
                                                                                                                                                                              allow animal access while awaiting
                                                                                                                                                                              transfer to other locations conflicts.

  135. August 30,   MOE – EPD                                                                                       GAS favours secure transfer stations and minimizing GAS commits to meet or exceed
       2007                                                                                                         conflicts with wildlife.                            RMOW standards for wildlife and
                                                                                                                                                                        waste management to avoid human-
                                Table 4.1 Criteria for Siting and Sizing a transfer depot. An unattended drop off                                                       bear conflicts and by using animal
                                facility at the Garibaldi Resort would not be advised due to the close proximity                                                        proof receptacles for any items that
                                to the municipality. A higher potential for illegal dumping could happen. A                                                             may attract wildlife; storing waste in
                                secure and staffed site would be the most ideal. Also, a preferable way of                                                              buildings or bins on-site that do not
                                disposing waste into bins is to have an elevated ramp and the waste is
                                dropped into the bins based on human health concerns. In the end, any site                                                              allow animal access while awaiting
                                would need to be approved by the SLRD and entered into the SWMP.                                                                        transfer to other locations conflicts..e

  136. November     SLRD        Solid Waste Management- The Garibaldi at Squamish Project has not been In a letter dated January 24, 2008, Urban Systems GAS commits to complying with all
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        15, 2007            specifically accounted for in the SLRD’S new Solid Waste Management Plan.      updated solid waste management options and               principles and policies of the
                            SLRD recommends that the applicant contact the SLRD to discuss this further.   concluded the following: GAS will need to work with      Squamish-Lillooet Regional District
                            GAS’s assumptions about existing facilities being adequately sized to          the DOS to get incorporated into the SWMP. It is         “Solid Waste Management Plan
                            accommodate solid waste generate by Garibaldi at Squamish should be            envisioned at this point that GAS would be charged       (approved November 2008) for the
                            substantiated with projected volumes of waste and further planning.            the appropriate tipping fee to dump at the               region, and GAS will also follow the
                                                                                                           new/expanded Squamish Landfill/SLRD regional             recommendations of the SWMP”
                                                                                                           landfill. If the landfill does not proceed, it is        including preferred option for:
                                                                                                           expected that eventually all waste in the Valley will        • Solid waste management;
                                                                                                           have to be hauled away.                                      • Household hazardous waste;
                                                                                                           GAS will follow the recommendations of the                   • Composting;
                                                                                                           Squamish-Lillooet Regional District “Solid Waste             • Recycling;
                                                                                                           Management Plan Update” report dated December                • Collection system/illegal
                                                                                                           2007 for solid waste management (included in Table               dumping; and
                                                                                                           of Commitments and Assurances).                          Tipping fees.
                                                                                                           GAS will incorporate the following principles into the
                                                                                                           Solid Waste Management plan:
                                                                                                              1. The Regional District goal of waste reduction
                                                                                                                 will be endorsed by the Garibaldi Resort.
                                                                                                                 Significant waste reduction will be gained by
                                                                                                                 targeting organic waste from residential
                                                                                                                 users, day use areas, hotels, and food
                                                                                                                 service industries. Garibaldi will meet the
                                                                                                                 Regional District’s waste reduction by
                                                                                                                 offering the same waste reduction initiatives
                                                                                                                 within the Resort in coordination with the
                                                                                                                 Regional District.
                                                                                                              2. GAS will endorse the Squamish Lillooet
                                                                                                                 Regional District waste reduction principals
                                                                                                                 (i.e. reduce, reuse, and recycle).
                                                                                                              3. GAS will participate in the Regional District’s
                                                                                                                 waste diversion programs.
                                                                                                              5. The Resort will implement as many proactive
                                                                                                                 waste reduction measures as possible (i.e.
                                                                                                                 Disposal ban on recyclable materials, yard
                                                                                                                 waste and products covered by product
                                                                                                                 stewardship      programs);Separate        out
                                                                                                                 biosolids and hauling the biosolids to the in
                                                                                                                 vessel composter in Whistler, and if this
                                                                                                                 option is not available, examining alternative
                                                                                                                 disposal options for biosolids;
                                                                                                              6. Meeting or exceeding the Resort Municipality
                                                                                                                 of Whistler standards for wildlife and water
                                                                                                                 management to avoid human bear conflicts,
                                                                                                                 and by using animal proof receptacles for
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                                                                                                                     any items that may attract wildlife; storing
                                                                                                                     waste in buildings or bins on-site that do not
                                                                                                                     allow animal access while awaiting transfer
                                                                                                                     to other locations;
                                                                                                                 7. Not providing curbside waste collection to
                                                                                                                    avoid attracting animals and potential
                                                                                                                    animal/human conflicts; and,
                                                                                                                 8. Implementing a bear awareness and safety
                                                                                                                    program.
                                                                                                              GAS Inc recognizes that the resort is responsible for
                                                                                                              developing and implementing an acceptable solid
                                                                                                              waste management plan, and in the unlikely event
                                                                                                              the existing regional waste management facilities
                                                                                                              cannot accommodate GAS wastes, GAS will
                                                                                                              investigate an independent solid waste management
                                                                                                              disposal facility or disposal option.

  137. November   MOE – EPD   Table 1 states that GAS will follow the solid waste management                  In a letter dated January 24, 2008, Urban Systems        GAS commits to complying with all
       29, 2007               recommendations of the SLRD revised SWMP. At this time, there is                updated solid waste management options and               principles and policies of the
                              insufficient information to show us that there can be accommodation for their   concluded the following: GAS will need to work with      Squamish-Lillooet Regional District
                              solid waste management needs within the recently updated SWMP, or that          the DOS to get incorporated into the SWMP. It is         “Solid Waste Management Plan for the
                              there is capacity at nearby landfills. There is also no proposed contingency    envisioned at this point that GAS would be charged       region (November 2008) or any of its
                              plan for the waste generated.                                                   the appropriate tipping fee to dump at the               future amendments, and GAS will also
                                                                                                              new/expanded Squamish Landfill/SLRD regional             follow the recommendations of the
                                                                                                              landfill. If the land fill does not proceed, it is       SWMP” including preferred option for:
                                                                                                              expected that eventually all waste in the Valley will         • Solid waste management;
                                                                                                              have to be hauled away.                                       • Household hazardous waste;
                                                                                                              Whistler is setting up an in-vessel    composter for          • Composting;
                                                                                                              sludge from their sewage treatment     plant. Sludge          • Recycling;
                                                                                                              from GAS could be sent to Whistler,    after GAS had          • Collection system/illegal
                                                                                                              paid their share of an expanded        facility or an            dumping; and
                                                                                                              appropriate tipping fee.                                      • Tipping fees.
                                                                                                              GAS will incorporate the following principles into the
                                                                                                              Solid Waste Management plan:
                                                                                                                 1. The Regional District goal of waste reduction
                                                                                                                    will be endorsed by the Garibaldi Resort.
                                                                                                                    Significant waste reduction will be gained by
                                                                                                                    targeting organic waste from residential
                                                                                                                    users, day use areas, hotels, and food
                                                                                                                    service industries. Garibaldi will meet the
                                                                                                                    Regional District’s waste reduction by
                                                                                                                    offering the same waste reduction initiatives
                                                                                                                    within the Resort in coordination with the
                                                                                                                    Regional District.
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                                                                                                      2. GAS will endorse the Squamish Lillooet
                                                                                                         Regional District waste reduction principals
                                                                                                         (i.e. reduce, reuse, and recycle).
                                                                                                      3. GAS will participate in the Regional District’s
                                                                                                         waste diversion programs.
                                                                                                      4. The Resort will implement as many proactive
                                                                                                         waste reduction measures as possible (i.e.
                                                                                                         Disposal ban on recyclable materials, yard
                                                                                                         waste and products covered by product
                                                                                                         stewardship programs);.
                                                                                                      5. Separate out biosolids and hauling the
                                                                                                         biosolids to the in vessel composter in
                                                                                                         Whistler, and if this option is not available,
                                                                                                         examining alternative disposal options for
                                                                                                         biosolids;
                                                                                                      6. Meeting or exceeding the Resort Municipality
                                                                                                         of Whistler standards for wildlife and water
                                                                                                         management to avoid human bear conflicts,
                                                                                                         and by using animal proof receptacles for
                                                                                                         any items that may attract wildlife; storing
                                                                                                         waste in buildings or bins on-site that do not
                                                                                                         allow animal access while awaiting transfer
                                                                                                         to other locations;
                                                                                                      7. Not providing curbside waste collection to
                                                                                                         avoid attracting animals and potential
                                                                                                         animal/human conflicts; and,
                                                                                                      8. Implementing a bear awareness and safety
                                                                                                         program.




                                                                                                   GAS Inc recognizes that the resort is responsible for
                                                                                                   developing and implementing an acceptable solid
                                                                                                   waste management plan, and in the unlikely event
                                                                                                   the existing regional waste management facilities
                                                                                                   cannot accommodate GAS wastes, GAS will
                                                                                                   investigate an independent solid waste management
                                                                                                   disposal facility or disposal option.
TOPIC: LIQUID WASTE MANAGEMENT

  138. July 9,   SLRD      Any new information on Squamish’s sewage treatment plant upgrades should GAS will have an onsite resort wastewater treatment GAS commits to having an onsite
       2007                be incorporated.                                                         plant and will not require access to or use of a resort wastewater treatment plant.
                                                                                                    Squamish based Waste Water Treatment Plant.
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        January 7,             SLRD noted that the impacts of onsite treatment have not been assessed.             [EAO     note:     GAS    December      16,    2009
        2010                                                                                                       correspondence – the District of Squamish treatment
                                                                                                                   system (Mamquam Station) is one of the three
                                                                                                                   options still being considered for the discharge of
                                                                                                                   liquid wastewater]

  139. July 9,       SLRD      Given the chemical spill into the Cheakamus River, the impacts of effluent GAS will complete an Environmental Impact Study                GAS commits to developing a liquid
       2007                    should be re-evaluated.                                                    (EIS) for wastewater treatment plant as required by            waste management plan as part of the
                                                                                                          the MOE Municipal Sewage Regulation (MSR) and                  Environmental Management Plan and
                                                                                                          the impacts of the effluent will be assessed as part           to complying with the MSR.
        January 7,             SLRD commented that at the rezoning stage major project (eg. Porteau.Cove) of the Environmental Impact Study (EIS) required by
        2010                   have been strongly encouraged to exceed MSR.                               the.MSR

  140. January 7,    SLRD      SLRD comments on Liquid Waste Management in letter correspondence to
       2010                    Graeme McLaren from GAS Inc. dated December 16, 2009:
                               Based on the amount of visitors that are being anticipated at GAS this will
                               result in a significant increase in the amount of biosolids requiring treatment
                               within the southern portion of the SLRD. The Resort Municipality of Whistler
                               (RMOW) constructed the in-vessel compost facility to provide end treatment of
                               biosolids from their wastewater treatment plant. GAS should be determining a
                               final treatment option to work in combination with their plant as well.

  141. January 7,    SLRD      SLRD comments on Liquid Waste Management in letter correspondence to
       2010                    Graeme McLaren from GAS Inc. dated December 16, 2009:
                               The RMOW compost facility is currently operating at capacity and will not be
                               able to accommodate additional material unless an expansion of the facility
                               occurs. That being said, there are no guarantees they will accept the biosolids
                               from GAS as any additional space at the facility will be used for food waste
                               generated within Whistler.

                               GAS should not be relying on Whistler for the treatment of their biosolids.

                               In addition, by proposing that they will utilize the RMOW facility will increase
                               the amount of large truck traffic on the Sea to Sky Highway.

  142. January 7,    SLRD      SLRD comments on Liquid Waste Management in letter correspondence to
       2010                    Graeme McLaren from GAS Inc. dated December 16, 2009:
                               The letter states that GAS will provide secondary or tertiary wastewater
                               treatment. There is a big difference in capital costs of these options and if the
                               “or” is left in, the treatment option will be secondary. SLRD believes that
                               tertiary treatment should be the recommendation, taking into account the
                               discharge waters in the area are fish sensitive habitats.

  143. January 7,    SLRD      SLRD comments on Liquid Waste Management in letter correspondence to
       2010                    Graeme McLaren from GAS Inc. dated December 16, 2009:
                               A hydrogeological investigation should take place if the proposed golf course
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                               location is suitable for the use of sewage effluent for irrigation purposes. Page
                               3 last paragraph states the Brohm Lake will not be affected as the “drainage
                               patterns are generally to the south”. This is not a reassuring comment.

  144. November    MOE – EPD   In addition to the requirements of the MSR, GAS is required to not cause Comment noted. Treatment and operation of the GAS commits to developing a liquid
       29, 2007                pollution as defined under the Environmental Management Act.             wastewater treatment plant will be designed to waste management plan as part of the
                                                                                                        ensure that the discharge does not cause pollution. Environmental Management Plan and
                                                                                                                                                            to complying with the MSR.
                                                                                                                            The EIS will determine the level of treatment
                                                                                                                            necessary to avoid pollution. In order to
                                                                                                                            ensure that treated wastewater does not
        January                MOE-EPD –further comments on the EIS– The EIS is an integral part of the
                                                                                                                            cause pollution, GAS will develop a liquid
        14, 2010               MSR registration process. The wastewater treatment plant will need to be
                                                                                                                            waste management plan as part of the
                               operated according to a designed operation plan.
                                                                                                                            Environmental Management Plan.

  145. November    MOE – EPD   Will there be a commitment to public education re household products that can GAS will provide public education regarding GAS commits to developing a public
       29, 2007                have significant impacts on receiving waters? This would assist in addressing household products that can have significant environmental education program
                               impacts related to micro-contaminants (e.g. surfactants) that are typically not impacts on receiving waters.               regarding   hazardous  household
                               effectively treated prior to discharge.                                                                                    products.

  146. November    MOE – EPD   GAS stated that, "the Cheekye, Cheakamus or Squamish Rivers are relatively            As EIS, the potential for nuisance algal blooms/mats    GAS commits to undertake an EIS on
       29, 2007                fast flowing, mountain fed streams - this eliminates the potential for free           to occur will be assessed. The assessment will          the river that is ultimately selected to
                               floating algae blooms to develop and dramatically reduces the potential for           consider nutrients discharged, background nutrient      receive treated effluent during the
                               attached mats of algae." This is not true. In these systems, during certain           concentrations and downstream locations favourable      detailed design phase of the project
                               times of the year, water clarity, substrate stability, solar angle and velocity are   to periphyton growth.                                   and to including in the EIS, an
                               all ideal for periphyton growth, if inorganic nutrient levels are sufficient. MOE                                                             assessment for endocrine disrupting
                               does not agree with GAS position regarding endocrine disrupting substances.           The effects of endocrine disrupting substances will substances.
                               Some EDCS have been shown to cause impacts to aquatic life at levels that             be assessed as part of the EIS. The assessment
                               could exist in streams receiving sewage discharges. Available dilution must be        will include determining the minimum dilution GAS commits to developing a liquid
                               sufficient to ensure such impacts do not occur. The main EPD issue here will          required to protect fish. To ensure that there is waste management plan as part of the
                               be the amount of water available to provide sufficient dilution for wastewater        adequate available dilution in the discharge river at Environmental Management Plan and
                               and stormwater.                                                                       all times including the low flow period                 to complying with the MSR and
        January                                                                                                                                                              ensure that there is adequate
        14, 2010                                                                                                     The EIS will consider the dilution available for available dilution in the discharge river
                               MOE-EPD further commented, upon reviewing the response from GAS, that                 wastewater. The preferred discharge option to date at all times, including during the low
                               the MSR process includes registering the discharge and completing an EIS              is the Cheekeye River, subject to the MSR review flow periods.
                               and operating plan. Part of the EIS includes assessing the receiving                  and associated MSR EIS. GAS will if authorized,
                               environment, its uses and sensitivity and proving dilution modeling to support        build one treatment plant and discharge treated
                               the discharge and meet the requirements of the MSR.                                   effluent to the Cheekye River with beneficial reuse of
                                                                                                                     some of the effluent for irrigating the golf course(s)
                                                                                                                     as the preferred method of disposal. The Cheekeye
                                                                                                                     is a relatively fast flowing, mountain fed river - this
                                                                                                                     aspect eliminates the potential for free floating algae
                                                                                                                     blooms to develop and dramatically reduces the
                                                                                                                     potential for attached mats of algae. However GAS
                                                                                                                     can commit to implementing any of the three
                                                                                                                     disposal options, determined in accordance with the
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                                                                                                             Environmental Management Act, Municipal Sewage
                                                                                                             Regulation (MSR).

                                                                                                             The EIS will consider the dilution of wastewater,
                                                                                                             effects of endocrine disrupting substances, free
                                                                                                             floating algae blooms, periphyton growth and micro-
                                                                                                             contaminates from household products (e.g.
                                                                                                             surfactants) and effluent reuse for golf course
                                                                                                             irrigation.

TOPIC: ENERGY

  147. July 9,       SLRD      Update reference to policy regarding provincial government’s moratorium on EAO comment – there is not a moratorium on IPPs.
       2007                    new IPP construction.


TOPIC: ROADS AND HIGHWAY

  148. July 9,       SLRD      Need a summary table of road types and length of road to be built             McElhanney has provided an update on the lengths
       2007                                                                                                  of all levels of roads within the resort boundaries
                                                                                                             (October 12, 2007). The total length of the main
                                                                                                             access road and all other roads within the resort
                                                                                                             boundaries is ~99km., however during the first 10
                                                                                                             years of development roadway lengths will likely be
                                                                                                             less than 50 kms in total.

  149. July 9,       SLRD      SLRD understanding is that a Class D cost estimate is a preliminary estimate Cost estimates for road network were prepared .
       2007                    based on little or no site information that indicates the approximate magnitude based on standard Ministry of Transportation and
                               of costs.                                                                       Infrastructure (MOTI) requirements for this level of
                                                                                                               detail. GAS will be responsible for all road costs.

  150. July 9,       SLRD      Commercial node at highway in direct conflict with RGS, community planning GAS will continue to work with MTCA, the SLRD and GAS commits to incorporate smart
       2007                    and provincial resort development best practices principles.               DOS to resolve this issue in the Master Plan and growth and sustainability principles
                                                                                                          OCP amendment process                             into development and operation where
                                                                                                                                                            feasible.
        January 7,             SLRD concurred that the issue can be addressed at OCP/rezoning stage
        2010

  151. August 3,     RMOW      According to the transportation study, the most significant traffic impacts will GAS Inc. will work with MOTI with respect to GAS has committed to the following
       2007                    develop between the proposed GAS and the DOS. This section of roadway highway upgrades.                                       Highway 99 upgrades:
                               currently provides a poor level of service during peak times. The expectation
                                                                                                                                                                1. At Phase 3 (>12,000 bed units)
                               that current highway improvements would improve access to Whistler will likely
                                                                                                                                                                   build an additional southbound
                               be unrealized due to approved and forecast new development south of
                                                                                                                                                                   Highway 99 lane to achieve a
                               Squamish and made significantly worse by GAS.
                                                                                                                                                                   basic four lanes between the
                                                                                                                                                                   Garibaldi Way intersection in
                                                                                                                                                                   Squamish and the resort
                                                                                                                                                                   primary access; and
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                                                                                                                                                                               2. Build a grade separated
                                                                                                                                                                                  highway      connection, with
                                                                                                                                                                                  northbound and southbound on
                                                                                                                                                                                  and off ramps for the main
                                                                                                                                                                                  collector road.

  152. November   Transport   TC will need to be provided with additional information on stream crossings.       TC has been provided additional information on all GAS commits to submit bridge design
       8, 2007    Canada                                                                                         crossings that would require their approval, and drawings to TC, Navigable Waters for
                  (TC),       Dam for primary reservoir is 20 meters high X 100 meters long. TC requires         updated information on the withdrawal locations to approval prior to construction.
                  Marine      more information on the dam and reservoir design, such asthe square area the       federal and provincial agencies. Navigable Waters
                  Branch      reservoir will take up, location, co-ordinates, is the stream navigable etc. and   has determined that this detailed information is not
                  Pacific     drawings and will also require information on locations for water withdrawal. If   required at present.
                  Region      stream is determined to be navigable, design drawing information will be
                              required.                                                                             GAS will submit bridge design drawings to TC,
                                                                                                                    Navigable Waters for approval prior to construction
                              Following an investigation of the site information, it is the opinion of TC officials of these crossings, recognizing that 4-6 month lead
                              that waters of “Brohm River” at the site of the proposed bridge are considered time is required for Navigable Waters review and
                              to be NAVIGABLE, therefore an application is required under the Navigable public advertising of the application.
                              Waters Protection Act for the above noted work.


  153. November   MOFR        Industrial access to Crown Lands beyond the “footprint” of the proposed            GAS will ensure the project provides industrial            GAS commits to prepare a Forestry
       26, 2007               development must be maintained. Specifically, access along the Cheekeye            access through the development to access current           Management Plan for MTCA as part of
                              River FSR and the Swift Creek FSR are required to access current and future        and future timber harvesting and ongoing silviculture      its MDA requirements which will
                              timber harvesting and ongoing silviculture opportunities. These roads must be      (if no other option exists) and that the project design    identify methods for addressing
                              designated for industrial use. Moreover, industrial logging traffic is often       minimizes the need for non-industrial traffic to utilize   forestry issue.
                              viewed as not being compatible with residential development; therefore, GAS        the roads. Road locations, design, load limits, and
                              should also ensure the project design minimizes the need for non-industrial        recreation use of any remaining FSR’s will need to         GAS to continue to work with the
                              traffic to utilize the roads.                                                      be coordinated between resort development plans            MOFR and MTCA to address issues
                                                                                                                 and MoFR logging plans. Generally, continued               related to continued industrial logging
                              See old #39 through #41 for other MOFR comments and commitments.                   logging access over these roads should not be an           access.
                                                                                                                 issue affecting resort construction, and resort
                                                                                                                 operations, with good, ongoing communication.


  154. November   MOFR        Woodlot #1930, held by the Squamish Nation, and a small portion of woodlot         GAS would propose a review of the wood lot plans, GAS to work with the MTCA, MOFR
       26, 2007               #027, held by Doug Horth, lie within the boundaries of the proposed project.       fiber values, the resort plans, the timing and location and the woodlot owners to resolve any
                              While there has been some discussions surrounding the possibility of               of resort development in relation to the existing woodlot issues.
                              cancelling Woodlot #1930 and deleting a portion of woodlot #027, a final           wood lots, and the ability to harvest the wood lots
                              decision has not been made. If the proponents feel that the woodlots would         prior to the resort development or in conjunction with
                              not be compatible with their development proposal, Ministerial approval will be    resort development plans. It is likely a reasonable to
                              required in order to have the tenures cancelled. Cancellation and/or deletion      high percentage of the fiber could be removed prior
                              may take up to a year to complete. Should the woodlots be cancelled or a           to addressing the woodlot licenses. GAS would
                              portion deleted GAS or the Provincial Agency selling the lands will be required    support continue, managed wood lot activity where
                              to compensate the holder of the license.                                           that is compatible with the resort development and
                                                                                                                 operation.
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                                                                                                               GAS and MTCA will follow up with the woodlot
                                                                                                               owners about their license plans and coordination
                                                                                                               with resort development plans to minimize
                                                                                                               compensation needs and to coordinate harvest
                                                                                                               activity.

TOPIC: GEOTECHNICAL

  155. July 9,       SLRD      The field checking of the terrain mapping was waived by the subcommittee        Thurber Engineering, one of the most recognized              GAS commits to conducting detailed
       2007                    based on the consultant’s prior knowledge of the study area and restrictions    geotechnical firms in the province, has done site            geotechnical assessments prior to
                               imposed by the 2002 study schedule. It is recommended that the field            reconnaissance since 1993 and Thurber believes               construction and as required for
                               checking be completed and reported on given that morainal materials and         their information is sufficient for planning purposes.       subsequent permits, approvals and
                               colluvium exist in the study area and are obscured in air photos (page 13).     Detailed geotechnical assessments will be                    authorizations.
                                                                                                               completed for all resort facilities prior to construction.

  156. July 9,       SLRD      Building on slopes of 50% may be inappropriate given the amount of rain and     The information referred to is general design criteria GAS commits to working with local
       2007                    snow in the area – more discussion is recommended. What type of                 provided by Thurber Engineering, not specific government to develop criteria for
                               development is planned for 50% slopes? Where is it located? What are the        development plans. Decisions regarding feasibility development on slopes >30%.
                               criteria for allowing development on slopes over 30%?                           of constructing on steeper areas will be made on a
                                                                                                               site by site basis.        The criteria for allowing
                                                                                                               development on slopes over 30% will be determined
                                                                                                               in negotiation with local governments.

  157. July 9,       SLRD      Who would fund and manage the recommended monitoring program for Government should fund the monitoring program if
       2007                    possible movement of the Brohm Ridge linears?                    required from a public safety perspective..

  158. July 9,       SLRD      Could not find references to earthquakes, which may be relevant to the linears The potential for earthquakes and their effects on            GAS commits to conducting further
       2007                    and the water storage reservoirs.                                              design of structures is addressed in the update               geotechnical assessments (including
                                                                                                              section “Effects of the Environment on the Project.”          earthquake stability) of water storage
        January 7,             SLRD stated that issue can be addressed at OCP/rezoning design.                Thurber Engineering provided updated information              reservoirs during detailed design.
        2010                                                                                                  on all reservoir dam structures and locations in
                                                                                                              October 2007, which was included in Addendum 1
                                                                                                              and distributed by the EAO to the working group
                                                                                                              members. The October 2007 report assessed
                                                                                                              earthquake hazards that could impact the
                                                                                                              development and concluded that “permanent ground
                                                                                                              displacement or settlement resulting from an
                                                                                                              earthquake event is expected to be minimal.”
                                                                                                              However, additional geotechnical assessments
                                                                                                              (including earthquake stability) of water storage
                                                                                                              reservoirs will be undertaken at detailed design, and
                                                                                                              mitigation will be incorporated as required.

                                                                                                               In letter correspondence dated November 16, 2009,
                                                                                                               Thurber Engineering provided a geotechnical
                                                                                                               assessment of the eight water storage facilities
                                                                                                               currently under consideration for the development.
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  159. October       EAO       Within Section 8 of Volume 6, provide a conceptual plan for each of the Thurber (October 2008) provided additional
       16, 2007                proposed water storage reservoirs and dams including:                      information on reservoir/dam construction including
                                                                                                          schematics of dam types. ENKON Environmental
                               • Identify anticipated vegetation or habitat removal that will result from Limited (January 2008) identified vegetation and
                                  creation of the reservoirs                                              wildlife habitat impacts from the proposed reservoirs
                                                                                                          and outlined various mitigation strategies to
                                                                                                          minimize impacts.

                                                                                                                  In letter correspondence dated November 16, 2009,
                                                                                                                  Thurber Engineering provided a geotechnical
                                                                                                                  assessment of the eight water storage facilities
                                                                                                                  currently under consideration for the development.
                                                                                                                  ENKON Environmental Limited (November 2009)
                                                                                                                  updated an assessment of the potential impacts to
                                                                                                                  existing forest cover, wildlife habitat, and
                                                                                                                  habitat/vegetation – noting the changes associated
                                                                                                                  with the proposed reservoir locations.
TOPIC: ENVIRONMENTAL
  160. July 9,       SLRD      The bird count stations (figure 5-3) do not correlate well with the old growth   The 2002 nesting bird and raptor surveys focused        GAS commits to undertaking a further
       2007                    forests (figure 4-3) 4 of the 43 survey locations were in the forest age classes on the base area development. Therefore, they           survey for marbled murrelets, surveys
                               121 to 250+ yrs (similarly with the raptor survey (figure 5-4)). Could this have were not conducted in the larger blocks of old-         for spotted owl and northern goshawk
                               impacted the ability to detect spotted owls, goshawks and marbled murrelets?     growth forest, where spotted owls and northern          in old-growth areas where clearing is
                                                                                                                goshawks would be more likely to nest than younger      planned and conducting nesting bird
        January 7,             SLRD supports the view that this information should be available while forest and the edges of smaller old-growth patches.               surveys prior to any clearing that
        2010                   planning the development in order to avoid impacts, not right before clearing is Earlier survey sites for marbled murrelets were         occurs during the bird breeding
                               to take place.                                                                   appropriate.                                            season.

                                                                                                                  GAS has committed to undertaking a further survey
                                                                                                                  for marbled murrelets. Nesting bird surveys will be
                                                                                                                  completed prior to any clearing that occurs during
                                                                                                                  the bird breeding season.       These will include
                                                                                                                  surveys for spotted owl and northern goshawk in
                                                                                                                  old-growth areas where clearing is planned.

  161. July 9,       SLRD      The sections on harlequin ducks need to be updated. Application states the A report on harlequin duck surveys (dated
       2007                    study would be completed in 2003.                                          September 26, 2007) was submitted in Addendum 1
                                                                                                          to the EAO in October 2007.

  162. July 9,       SLRD      The sections on marbled murrelets need to be updated. Application states the This study was not completed, but GAS has                   GAS commits to undertaking a further
       2007                    study would be completed in 2003.                                            committed to undertaking a marbled murrelet                 survey for marbled murrelets, surveys
                                                                                                            survey. If further studies indicate that murrelets do       for spotted owl and northern goshawk
        December               It is recommended that the possible impacts to marbled murrelets be further nest on the site, a management plan will be                  in old-growth areas where clearing is
        4, 2007                studied and mitigation measures proposed before an EA certificate is issued. developed to minimize impacts to marbled                    planned and conducting nesting bird
                               Also, there is a discrepancy between the table of commitments and best murrelets.                                                        surveys prior to any clearing that
                               management practices described.        The best management practices                                                                     occurs during the bird breeding
                               recommend a 500 to 2000m buffer where a marble nest is found, while the                                                                  season.
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        January 7,             applicant commits to a 100 m buffer.
        2010
                               SLRD supports the view that this information should be available while
                               planning the development in order to avoid impacts, not right before clearing is
                               to take place.

  163. July 9,       SLRD      It appears that the upper diversion (figure 18-1) is located on an GAS has provided the flow data collected by
       2007                    ephemeral/intermittent stream (figure 10-1). More information needed. Northwest Hydraulics and the 20 year modeling
                                                                                                     results from Urban Systems to the EAO in draft in
                                                                                                     February 2009 as part of the Addendum 3 and the
                                                                                                     final Northwest Hydraulics and the interim (May
                                                                                                     2009) Urban Systems report to EAO in June 2009.

  164. July 9,       SLRD      More information is needed on the anticipated backcountry use resulting from            Information on anticipated backcountry use and        GAS commits to participating with BC
       2007                    the new lift access to alpine areas. It is likely that impacts will not be limited to   effects on Garibaldi Park is provided in Volume 9.    Parks and the First Nations in a public
                               the summer months. How many more people will there be? How will                         The effect of recreation on mountain goats is         review of the Garibaldi Park Master
                               increased backcountry access affect wildlife outside of the project area, such          assessed in Section 12.3.5.       Effects on other    Plan (if required) and to support the
                               as the goat winter range (figure 5-7)? How will this new access affect the              species also are assessed in Volume 7. GAS made       outcome of a Master Plan amendment
                               management goals of Garibaldi Provincial Park? How will recreation access to            revisions to the April 2003 BC Parks issues report    related to the interface between the
                               backcountry areas beyond the resort be managed? Who would fund and                      (dated January 2008) and submitted it to the EAO in   park and the resort.
                               manage the proposed permit system?                                                      January 2008 as part of the Addendum 2 information
                                                                                                                       requirements.

                                                                                                                       Backcountry access management is the responsible
                                                                                                                       of BC Parks. GAS is not aware of the proposed
                                                                                                                       permit system.

                                                                                                                       In correspondence dated December 2, 2009, GAS
                                                                                                                       Inc. agreed to comply with those requirements
                                                                                                                       proposed by MOE, Parks and Protected Areas letter
                                                                                                                       dated November 5, 2009.

  165. July 9,       SLRD      The cumulative impacts section should be updated to reflect the highway An updated Cumulative Effects Assessment, which
       2007                    upgrades and new development in Squamish.                               addresses the Sea-to-Sky Highway, was submitted
                                                                                                       to the EAO in October 2007 as part of the
                                                                                                       Addendum 1 information requirements. The update
                                                                                                       addressed the information that was available from
                                                                                                       the Sea to Sky Highway Improvement Application
                                                                                                       (Ministry of Transportation 2003).

  166. July 9,       SLRD      How will minimizing air traffic during denning periods or setting a minimum GAS will work with MOE to set minimum flight GAS commits to not having resort-
       2007                    flight altitude be carried out?                                             altitudes and/or other necessary wildlife impact based wildlife helicopter tours.
                                                                                                           mitigations, as required.

  167. July 9,       SLRD      How will residents and visitors be encouraged to use transit to access the There will be direct transit connections between
       2007                    resort?                                                                    Squamish and the resort.
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  168. July 9,    SLRD         How are the following programs to be funded and managed?                            Local government will fund and manage transit. GAS      commits    to    funding  an
       2007                                                                                                        GAS will fund and manage the remaining programs. environmental education program.
                                  •   Transit bus system from Squamish
                                  •   Monitoring program for the Brohm River water flow and quantity during
                                      operation of the resort
                                  •   Program for curtailment of wood burning during periods of stagnant
                                      weather
                                  •   Program for water conservation
                                  •   Bear Information Center and page 25-18 – Aversive conditioning
                                      program.

  169. July 9,    SLRD         Could not find a wildfire protection plan. Application should be updated to A Wildfire Protection Plan will be prepared prior to GAS commits to prepare a Wildfire
       2007                    reference the SLRD’s new Community Wildfire Protection Plan.                construction.                                        Protection Plan prior to construction.

  170. July 9,    SLRD         Appendix 4-1 (Ceskas’ report) says, “Environmental concerns speak against Detailed design of the ski                   runs   will   avoid GAS commits to working with MTCA
       2007                    the proposed development of the G-cluster of ski runs.” How is this environmentally sensitive areas.                                       during the Master Plan review process
                               addressed?                                                                                                                                 to design ski runs to avoid
                                                                                                                                                                          environmentally sensitive areas, as
                                                                                                                                                                          much as possible.

  171. July 29,   MOE - ESD,   Grizzly bear - MOE will be insisting on a monitoring plan, the grizzly population   GAS will develop a grizzly bear monitoring plan with    GAS commits to developing a grizzly
       2007                    here is low but the intent is to recover the population unit from threatened to     the MOE/Squamish Nation which will include sub-         bear monitoring plan with MOE and
                               viable. The monitoring plan will include sub-population monitoring through DNA      population monitoring through DNA analysis and/or       the Squamish Nation which will
                               analysis and/or collaring.                                                          collaring. GAS will fund a grizzly bear research in     include sub-population monitoring
                                                                                                                   cooperation with the MoE on the following basis to      through DNA analysis and/or collaring.
                                                                                                                   address potential effects on grizzly bear’s             GAS commits to partially funding
                                                                                                                   associated with the resort project.                     grizzly bear research in cooperation
                                                                                                                                                                           with the MoE.
                                                                                                                   “An annual GAS contribution of approximately
                                                                                                                   $33,000.00 will be provided; based on agreement
                                                                                                                   with an overall research program; to be prepared
                                                                                                                   and fully funded before being implemented. The
                                                                                                                   monitoring program will be managed and delivered
                                                                                                                   by MoE who will monitor for grizzly bear in the
                                                                                                                   relevant Sea to Sky GBPU with the objective of
                                                                                                                   increasing the grizzly bear population in the area
                                                                                                                   overtime. MoE will not be reimbursed for costs but
                                                                                                                   will participate in the program by contributing staff
                                                                                                                   time and equipment (bear monitoring collars). This
                                                                                                                   bear research program and GAS’s continued
                                                                                                                   participation will be assessed each year to re-
                                                                                                                   establish the financial commitment and will continue
                                                                                                                   for three years to assess baseline conditions, and a
                                                                                                                   follow-up monitoring program every five years during
                                                                                                                   construction to full build-out and post build-out.”

  172. July 9,    SLRD         “The viability of the [Culliton Creek grizzly bear linkage zone] will be largely Area 12 impacts will be assessed at the time of See above Action in old #152
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        2007                      dependent on land use decisions by associated governing bodies.” How does proposed development.
                                  this plan ensure its viability? (Including future study area 12)

        December                  The SLRD recommends that the impacts to local and regional grizzly bear See above response.
        4, 2007                   movement corridors be explored and mitigation measures proposed before an
                                  EA certificate is issued.
        January 7,
        2010                      SLRD still feels its December 4, 2007 comment still applies.

  173. July 29,      MOE - ESD,   Mountain. Goats - A monitoring plan to monitor nanny/kid ratio and continued GAS will develop a mountain goat monitoring              GAS commits to developing a
       2007                       use of the winter range polygons to the current or increased levels. Industrial program in consultation with MOE/Squamish Nation.     mountain goat monitoring plan with the
                                  and recreational buffers and use timing guidelines are to be included. No                                                             MOE and the Squamish Nation to
                                  helicopter viewing for wildlife.                                                                                                      monitor nanny/kid ratios and continued
                                                                                                                                                                        use of the winter range polygons to
                                                                                                                                                                        the current or increased levels and to
                                                                                                                                                                        developing      a    mountain      goat
                                                                                                                                                                        management plan with the MOE and
                                                                                                                                                                        the Squamish Nation to address
                                                                                                                                                                        potential impacts from avalanche
                                                                                                                                                                        control and helicopter approach and
                                                                                                                                                                        departure routes.

  174. July 29,      MOE - ESD    Wolverine - a monitoring plan should be developed. There is a need to GAS will develop a wolverine monitoring program in              GAS commits to developing a
       2007                       maintain wolverine use of the area at current or increased levels.    consultation with MOE/Squamish Nation. A public                 wolverine monitoring plan with the
                                                                                                        education program regarding Wolverine will target               MOE and the Squamish Nation. Key
                                                                                                        summer outdoor recreationists. Emphasis will be                 goals of the plan are to ensure
                                                                                                        placed on informing people how to minimize                      wolverine use of the area is
                                                                                                        attractants such as garbage, and how to respond if              maintained at least at the current level
                                                                                                        an encounter occurs.                                            and to try to achieve an increased use
                                                                                                                                                                        of the area by wolverine.

  175. July 29,      MOE - ESD    Deer - Some of the current planning occurs over known and identified deer GAS will avoid deer winter range wherever possible          GAS commits to working with the
       2007                       winter range. GAS needs to move or adapt development to minimize impacts by re-locating residential developments away from            MOE/Squamish Nation to develop a
                                  on deer winter range.                                                     high quality deer winter range. To mitigate potential       deer management plan to identify
                                                                                                            impacts of golf course development on wintering             winter range that will be protected
                                                                                                            deer, large areas of existing forest will be retained       from development.
                                                                                                            between fairways, and design changes will be made
                                                                                                            to avoid habitats of high value to wintering deer,
                                                                                                            wherever possible.
                                                                                                                Recreational use of ATVs, feeding, harassment, or
                                                                                                                destruction of any wildlife by project personnel and
                                                                                                                the public on or about the project facilities will be
                                                                                                                prohibited.
                                                                                                                Vehicle speeds will be enforced to avoid collisions
                                                                                                                with deer. Signs, enforcement and speed control
                                                                                                                bumps are options that will be implemented.
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                                                                                                                  In years of deep snow, snow berms created by
                                                                                                                  ploughing will be broken at regular intervals so that
                                                                                                                  animals can easily escape from the roadway into
                                                                                                                  adjacent security cover.
                                                                                                                  To avoid attracting deer to road edges, the
                                                                                                                  shoulders and edges of roadsides will not be seeded
                                                                                                                  with highly palatable herbaceous species such as
                                                                                                                  clover.

  176. July 29,   MOE-ESD     MOE opposed to resort-based wildlife helicopter tours. -Specifically the Comment noted.                                                     GAS commits to not having resort-
       2007                   mountain goat herds in the area of the development are vulnerable to noise                                                                  based wildlife helicopter tours.
                              disturbance.

  177. February   MOE – ESD   MOE supports certain guidelines and practices. Guidelines and practices that Advice noted.                                                  GAS Inc. commits wherever possible
       26, 2009               should be contained in the Table of Commitments and Assurances include:                                                                     to incorporate the Best Management
                                                                                                                                                                          Practices/Guidelines      for     trails,
                                 •   With respect to Trail work and Amphibians the “Standards and Best                                                                    amphibians, marbled murrelet and
                                     Practices for Instream Work (MOE 2004)” be followed for any works in                                                                 raptors during the construction and
                                     and about streams                                                                                                                    operation of the resort, as outlined by
                                 •   Also for Amphibians follow “Best Management Practices for                                                                            the Ministry of Environment.
                                     Amphibians and Reptiles in Urban and Rural Environments in BC (MOE
                                     2004)”
                                 •   With respect to Marbled Murrelets – During each breeding season
                                     before construction of each phase of the Project, conduct radar surveys
                                     (RISC 2006) and subsequent audio-visual surveys (RISC 2001)
                                 •   With respect to Raptors follow “Best Management Practices for Raptor
                                     Conservation during Urban and Rural Land Development (MOE 2005)”

  178. May 18,    MOE-ESD     Comments on ecosystem/Species at Risk information:                                  GAS will conduct Species at Risk surveys in areas       GAS commits to conducting Species
       2009 and               June 30th - In order to adhere to best management practices and guidelines          of potential habitat prior to construction of resort    at Risk surveys in areas of potential
       June 30,               before and during construction and operation of the resort, GAS Inc. should         base development areas, ski runs/lift lines,            habitat prior to construction of resort
       2009                   commit to augmenting the”Garibaldi at Squamish” Volume 7 Environmental              reservoirs and golf course development areas.           base development areas, ski runs/lift
                              Impact Assessment as outlined by MOE on February 26 (see commitment                                                                         lines, reservoirs and golf course
                              above) and May 18, 2009.                                                                                                                    development areas.

                              May 18th - The assessment effort documented in the “Garibaldi at Squamish”
                              Volume 7 Environmental Impact Assessment for the taxa groups listed below
                              is insufficient. At minimum, the proponent needs to adhere to RISC standards
                              corresponding to each taxa group to determine relative abundances with a
                              minimum effort of 3 surveys per year that will be representative of the entire
                              project area and of taxa-specific important times (ex. Breeding periods, life
                              stages):
                                   • For passerine birds, 2 surveys in July is insufficient effort (from survey
                                      results in Volume 7)
                                   • For diurnal and nocturnal Raptors, 2 and 1 survey respectively is
                                      insufficient effort (from survey results in Volume 7)
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                               •   For Harlequin Ducks- no results in Volume 7 [EAO note – April 2003
                                   survey results in Addendum #1]
                               •   Small Mammals – need to pay particular attention to Species at Risk
                                   (e.g. Pacific Water Shrew) (no survey results in Volume 7 for small
                                   mammals)
                               •   Marbled Murrelets – MOE-ESD has previously commented on
                                   information requirements for this species
                               •   Amphibians (excluding Coastal Tailed Frog) and Reptiles – The
                                   reported surveys do not meet Project specifications and are insufficient
                                   in scope and effort (from survey results in Volume 7)
                               •   Great Blue Herons – no survey results in Volume 7)

                            All assessment of ecological values for this project needs to occur for two
                            years prior to commencement of construction, continue through the
                            construction period and then for a minimum of 5 years post-construction (with
                            extended monitoring efforts determined in consultation with concerned
                            agencies). This monitoring approach will lead to an understanding of impacts
                            of resort development and the effectiveness of mitigation.

  179. December   EAO       The following is a summary of comments from the EA Working Group on a
       17, 2009             report dated November 2009 by Enkon Environmental Ltd. regarding “Garibaldi
                            at Squamish Project, Addendum Report, Potential Impacts to Vegetation and
                            Wildlife Habitat and Overall Relative Impact Ranking Associated with Eight
                            Water Storage Reservoirs”:

                            Vegetation Impacts: Enkon has assessed areal impacts of the reservoirs at full
                            supply level (fsl) but has not taken into account the footprint of the dam
                            structures. The Thurber Engineering Ltd November 2009 report indicates that
                            a 50 m high dam will have a 75-100 m downstream footprint. It appears the
                            Enkon report underestimates impacts, particularly in sensitive riparian
                            vegetation sites (e.g. see Figures 3 and 5 that show old growth forest
                            immediately downslope of the dam for supplemental storage 1; the footprint of
                            this 50 m dam will likely include all or most of this old growth and this has not
                            been assessed by Enkon).

                            Enkon’s Figure 3 shows a patch of forest age class 2 (40-80 yrs) northeast of
                            supplemental storage 2 while Figure 1, the 2009 photo image of the area,
                            shows this same patch as a very recent clear cut. Comparisons of other sites
                            also suggest some discrepancies; hence questions arise as to the accuracy of
                            the forest age map.

  180. December   DOS       DOS comments on a report dated November 2009 by Enkon Environmental                 GAS has committed to do these plans in advance of
       10, 2009             Ltd. regarding “Garibaldi at Squamish Project, Addendum Report, Potential           construction and these commitments will be
                            Impacts to Vegetation and Wildlife Habitat and Overall Relative Impact              reflected in the GAS Table of Commitments and
                            Ranking Associated with Eight Water Storage Reservoirs”:                            Assurances.
                            DOS agrees that the sites that have been identified in the study as having the
                            least amount of wildlife and vegetation destruction be selected to the greatest
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                                extent   possible. The report appears to indicate that sites with the least impact
                                are:
                                    •    original primary storage;
                                    •    snow making reservoir #2;
                                    •    supplemental reservoir #3 (see 2.2) - which if chosen, an in-depth
                                         survey/report of rare plant communities needs to be carried out and
                                         highest protection of any red listed (or other threatened/endangered)
                                         plant communities needs to be undertaken.

                                In-depth surveys/reports of wildlife in all the chosen locations will need to be
                                carried out in the appropriate season(s) to better understand what is out there
                                and plan best management/construction options. DOS trusts that these
                                facilities will be developed on a no-net loss of vegetation basis.

  181. August 3,    RMOW        GAS must quantify the carbon and energy footprint of the proposal from               GAS will develop an Air Quality Protection Plan to GAS commits to developing an Air
       2007                     construction through transportation, measures to mitigate the emission of            address carbon and energy footprint, greenhouse Quality Protection Plan.
                                Greenhouse Gas and the potential increase in air pollution and particulate           gas, air emissions including particulate matter
                                emissions,                                                                           emissions.

  182. August 30,   MOE - EPD   Description of Drainages: For the smaller streams, we need to know more              GAS original stormwater management planning           GAS commits to developing a
       2007                     than just the seasonal patterns; we also need to know how they respond to a          (April 2003) indicated that future systems would     stormwater management plan during
                                storm event, with respect to water quality as well as flow patterns. Existing        comply with the Stormwater Guidebook for the         the detailed design phase of the
                                correlations in the scientific literature of land use and resulting storm event      Province of British Columbia. However, subsequent    Project which will be provided to
                                water quality could then be used to estimate resulting impacts to stream water       to the submission of the initial documents a new     provincial and federal agencies for
                                quality (and flow) during events. This information could even feed back into         approach has been developed. The new approach        review and comment.
                                final design plans and BMP usage to minimize water quality (and flow) impacts.       described as “Beyond the Guidebook” is founded
                                                                                                                     upon the principal of avoiding adverse impacts to
                                                                                                                     aquatic environments through an analytical process
                                                                                                                     that is based upon the best available scientific
                                                                                                                     principles.

                                                                                                                     GAS provided a stormwater report (McElhanney
                                                                                                                     October 2008: revised January 2009) that outlined
                                                                                                                     global performance targets and the water balance
                                                                                                                     modeling process, as per the new approach
                                                                                                                     described as “Beyond the Guidebook” submitted to
                                                                                                                     the EAO in February 2009 as part of the Addendum
                                                                                                                     3.

                                                                                                                     GAS proposed 2008/2009 stormwater planning
                                                                                                                     process incorporated the new approach as
                                                                                                                     described in “Beyond the Guidebook” and involved
                                                                                                                     establishing targets that would be implemented
                                                                                                                     during the detailed design process. Targets will
                                                                                                                     include matching:
                                                                                                                     1. Pre and post development runoff volumes,
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                                                                                                                        2. Pre and post flow durations,
                                                                                                                        3. Pre and post discharges for a range of return
                                                                                                                        periods or flood frequency,
                                                                                                                        4. Pre and post stream habitat availability,
                                                                                                                        5. Pre and post water quality; and
                                                                                                                        6. Pre and Post stream erosion potential.
                                                                                                                        The effects upon the streams caused by the
                                                                                                                        alteration of each of these areas, individually and
                                                                                                                        cumulatively, will be assessed and documented.
                                                                                                                        The identified impacts will then be reduced and
                                                                                                                        wherever possibly eliminated with the application of
                                                                                                                        Low Impact Development and construction
                                                                                                                        techniques.

  183. August 30,   MOE - EPD   There should be an explanation of how the water quality monitoring plan was             The water quality monitoring program design was         GAS commits to developing a Water
       2007                     designed. Again, there is a need to correlate the data with more than just the          based on the Final Project Report Specifications,       Quality Monitoring Program prior to
                                season, but also to precipitation events. As well, the inadequate sampling size         which state: “Water quality monitoring will be          construction and as required for other
                                is not really large enough to accurately characterize water quality, especially in      required to characterize baseline conditions prior to   authorizations.
                                the smaller systems                                                                     any construction commencing on this project.
                                                                                                                        Baseline water quality monitoring should include
                                                                                                                        each season with particular emphasis on periods of
                                                                                                                        change such as spring freshet, freeze up, the onset
                                                                                                                        of storm events in the fall and the dry period in the
                                                                                                                        summer.” Specific needs for additional baseline
                                                                                                                        data prior to construction of various project
                                                                                                                        components were identified in the Water Quality
                                                                                                                        Monitoring Plan (Volume 7, Section 30.0).

                                                                                                                        GAS provided a draft water quality monitoring plan.
                                                                                                                        This plan was submitted in Addendum 3 to the EAO
                                                                                                                        in February 2009.

  184. August 30,   MOE - EPD   The water quality hardness results should be interpreted further (seasonal? Except for the Cheekye River, hardness in all                       GAS commits to developing a Water
       2007                     event response?), as metals toxicity can vary significantly with hardness.  streams during all sampling events was so low that it               Quality Monitoring Program prior to
                                                                                                            would not provide any protection from metals                        construction and as required for other
                                                                                                            toxicity. Information on response to storm events                   authorizations.
                                                                                                            would not alter this conclusion.

  185. August 30,   MOE - EPD   While the elevated nitrate level in the Cheakamus River in February is                  A transitory source of elevated nitrogen cannot be      GAS commits to developing a Water
       2007                     apparent at both the upstream and downstream stations, the elevated organic             entirely ruled out. However, based on the much          Quality Monitoring Program prior to
                                nitrogen reading at the Cheakamus downstream station in September is not                lower concentrations of organic nitrogen in October     construction and as required for other
                                reflected at the upstream station. Is this result an error, or is there a significant   and February (similar to the other sampling             authorizations.
                                organic N source that was not sampled?                                                  stations), it likely was an error.

  186. August 30,   MOE - EPD   The high total phosphorus in the Cheekye River in October appears to be The Warren Glacier would contribute to elevated GAS commits to developing a Water
       2007                     related to the very high TSS result on that day. While there is no apparent suspended solids to both the Cheekye River and Quality Monitoring Program prior to
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                                correlation with True Colour during this sampling day event, the high total       Culliton Creek. True colour differences suggest construction and as required for other
                                phosphorus in Culliton Creek in September is correlated to both an elevated       differences in the amounts of glacial flour in the two authorizations.
                                TSS and an elevated True Colour. Elevations in TSS for both systems have          streams. High concentrations of TSS in glacial melt
                                been attributed to the fact that they both drain the Warren Glacier. Do the       water include larger suspended particles that would
                                True Colour differences suggest there is also another TSS source in one of the    not contribute to true colour.       However, there
                                systems?                                                                          potentially are other sources of TSS in both streams.

  187. August 30,   MOE - EPD   Data collected by Perrin likely gives a much more accurate average Perrin’s data for Cheakamus River are far more                         GAS commits to developing a Water
       2007                     phosphorus concentration in the systems.                           extensive than the data collected for the Garibaldi at                 Quality Monitoring Program prior to
                                                                                                   Squamish Project. Samples were collected every                         construction and as required for other
                                                                                                   two weeks in 1996 and monthly in 2000. Therefore,                      authorizations.
                                                                                                   they would give a more accurate average
                                                                                                   phosphorus concentration for Cheakamus River,
                                                                                                   which is one reason for having presented the data.
                                                                                                                  With respect to data for Culliton Creek and Cheekye
                                                                                                                  River, Volume 7 (page 2-19) states, “Differences in
                                                                                                                  sampling frequency and/or year to year variability in
                                                                                                                  phosphorus levels may account for the difference”
                                                                                                                  between Perrin’s data and the 1997-98 baseline
                                                                                                                  data. Since Perrin took monthly samples (compared
                                                                                                                  with quarterly samples), his average phosphorus
                                                                                                                  concentrations might more accurately reflect
                                                                                                                  average phosphorus in the two streams. However,
                                                                                                                  Perrin’s data were collected in only one year (2000)
                                                                                                                  and thus might not accurately represent year-to-year
                                                                                                                  differences, particularly if there were significant
                                                                                                                  differences in weather conditions between 1997-98
                                                                                                                  and 2000.

  188. August 30,   MOE - EPD   While these observations [metals above receiving water guidelines] are noted      Tables 9-3 and 9-4 note typical concentrations and      GAS commits to developing a Water
       2007                     in the subject report, there is no further consideration given to an assessment   loadings of copper, lead and zinc in runoff from        Quality Monitoring Program prior to
                                of the metals typically expected to increase from stormwater contributions        residential developments. Tables 9-7 and 9-8 show       construction and as required for other
                                arising from such a development.                                                  expected loadings after mitigation and resulting        authorizations.
                                                                                                                  concentrations in Brohm River (which would receive
                                                                                                                  the highest loadings).     Other metals are not
                                                                                                                  discussed due to lack of data on typical
                                                                                                                  concentrations in stormwater runoff and/or removal
                                                                                                                  efficiencies of BMPs. However, we believe that the
                                                                                                                  assessment of copper, lead and zinc accurately
                                                                                                                  represents the effectiveness of mitigation and the
                                                                                                                  expected lack of measurable residual effect for all
                                                                                                                  metals.

  189. August 30,   MOE - EPD   A correction of the zinc aquatic life guideline.    While 0.033 mg/L is the Comparison with the 30-day average guideline for              GAS commits to developing a Water
       2007                     maximum, the 30 day average is 0.0075 mg/L.                                 zinc (or any other parameter) requires 5 samples              Quality Monitoring Program prior to
                                                                                                            collected over a 30-day period. Thus, the data were           construction and as required for other
                                                                                                            compared only with maximum guidelines.                        authorizations.
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  190. August 30,   MOE - EPD   An mdc problem with the zinc and lead analyses. They are higher than the The zinc detection limit was below the maximum               GAS commits to developing a Water
       2007                     guidelines.                                                              guideline but above the 30-day average guideline.            Quality Monitoring Program prior to
                                                                                                         The lead detection limit was higher than both the            construction and as required for other
                                                                                                         maximum and 30-day average guidelines. Future                authorizations.
                                                                                                         monitoring will use detection limits ≤0.1 the 30-day
                                                                                                         average guideline, if available. GAS will use lower
                                                                                                         detection limits for metals in future monitoring.

  191. August 30,   MOE - EPD   A correction of the February W6 Cd result (<0.0010 should be <0.0001?).        Correct.
       2007

  192. August 30,   MOE - EPD   Further discussion on the low calcium levels for the Cheekye, Swift and Brohm This sensitivity was noted. It was not discussed
       2007                     systems, which make them highly sensitive to acidic discharges.               further because the project is not expected to create
                                                                                                              any acidic discharge.

  193. August 30,   MOE - EPD   When land clearing around a creek occurs, especially in the riparian zone, the No, this impact is not expected to occur. Riparian GAS to maintain riparian setbacks as
       2007                     natural periphyton community can change. Is this type of impact expected to setbacks will be maintained to prevent this type of per the requirements of legislation at
                                occur?                                                                         impact (among other impacts). There will be only the time of clearing.
                                                                                                               small areas of clearing for road and ski run
                                                                                                               crossings.

  194. August 30,   MOE - EPD   The sampling effort, in which most stations were only sampled on two separate The monitoring effort was sufficient for the level of   GAS commits to developing a
       2007                     occasions, may be too restricted to accurately characterize baseline periphyton assessment of the base area development given the     stormwater management plan during
                                conditions.                                                                     extent of riparian retention planned. Additional      the detailed design phase of the
                                                                                                                periphyton monitoring will be considered as a         Project which will be provided to
                                                                                                                component of the monitoring program for the EIS of    provincial and federal agencies for
                                                                                                                the wastewater treatment plant.                       review and comment.

                                                                                                                                                                      GAS commits to developing a Water
                                                                                                                                                                      Quality Monitoring Program prior to
                                                                                                                                                                      construction and as required for other
                                                                                                                                                                      authorizations.

  195. August 30,   MOE - EPD   Do they expect site runoff to contribute nitrogen and alter the periphyton Based on typical loadings of nitrogen and
       2007                     community structure? What impact, if any, would that change have on higher phosphorus in urban runoff, there is no reason to
                                trophic level organisms?                                                   believe that site (except from the golf course) runoff
                                                                                                           would contribute a disproportionate amount of
                                                                                                           nitrogen that would change the molar N:P ratio and
                                                                                                           alter periphyton community structure. The effect of
                                                                                                           the golf course is assessed on page 9-17.

  196. August 30,   MOE - EPD   The sampling area was quite small, thus there is some concern regarding how The monitoring effort was sufficient for the level of     GAS commits to developing a
       2007                     representative the samples may be of the overall systems.                   assessment of the base area development given an          stormwater management plan during
                                                                                                            expected impervious area <10% of watershed.               the detailed design phase of the
                                                                                                            Additional benthic invertebrate monitoring will be        Project which will be provided to
                                                                                                            considered as a monitoring component for the EIS of       provincial and federal agencies for
                                                                                                            the wastewater treatment plant.                           review and comment.
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                                                                                                                                                                            GAS commits to developing a Water
                                                                                                                                                                            Quality Monitoring Program prior to
                                                                                                                                                                            construction and as required for other
                                                                                                                                                                            authorizations.

  197. August 30,   MOE - EPD   The conclusion that the macroinvertebrate densities in the subject streams The effect of basket samplers’ maximizing or
       2007                     were on the low end of typically reported ranges is questioned. Some of the overestimating invertebrate density was noted in the
                                density comparisons are made with studies that used basket samplers, which discussion (page 2-30).
                                typically maximize or even overestimate the density of invertebrates on natural
                                substrate.

  198. August 30,   MOE - EPD   It is noteworthy that mayflies, stoneflies and caddisflies comprised the majority                                                           GAS commits to developing a
                                                                                                                    In small streams, the physical consequences of
       2007                     of invertebrates found at almost all the stations, and that many of the species                                                             stormwater management plan during
                                                                                                                    uncontrolled stormwater discharges (scouring,
                                are considered intolerant of pollution.        It would be useful to have the                                                               the detailed design phase of the
                                                                                                                    changes to streambed composition) have far more
                                proponent assess the likely impact to these communities from the stormwater                                                                 Project which will be provided to
                                                                                                                    significant effects on these invertebrates than do
                                contaminant flows that are forecast.                                                                                                        provincial and federal agencies for
                                                                                                                    toxic substances in the stormwater.
                                                                                                                                                                            review and comment.

  199. August 30,   MOE - EPD   Ensure that all exposed, disturbed soils and especially sloped areas are This is the intention of the Sediment and Erosion GAS commits to the development of
       2007                     revegetated with established plant cover well before the onset of fall rain. Plan Control Plan.                            an “Erosion and Sediment Control
                                for high intensity fall and winter storms. This should be the top priority and                                             Plan”, prior to construction and
                                must not be risk managed if there are project delays.                                                                      implementation of the plan through all
                                                                                                                                                           phases of development.

  200. August 30,   MOE - EPD   Table 9-2: Effectiveness of BMPs for sediment control - while the percent           Effectiveness data were presented as a basis for        GAS commits to the development of
       2007                     sediment removal rates stated in the table come from the EPA, the reality is        assessing residual effects, assuming that mitigation    an “Erosion and Sediment Control
                                that these mitigation measures - due to various reasons such as poor                measures are implemented properly. The sediment         Plan”, prior to construction and
                                maintenance, local conditions, poor installation, etc.- can result in much lower    and erosion control plan addresses maintenance of       implementation of the plan through all
                                actual sediment removal rates. Therefore it is important that mitigation            sediment and erosion control measures, monitoring       phases of development.
                                measures such as BMPs are not relied upon too heavily and that effort is            and adaptive management.
                                placed more on preventative measures. In addition, sediment basins/settling
                                ponds need to be designed to ensure they can adequately settle out a large
                                enough volume of water that comes with the heavy winter precipitation for this
                                area.

  201. August 30,   MOE - EPD   P.9-7 Ski area recommendations state that a contingency plan is needed in           The intention of the erosion and sediment control       GAS commits to the development of
       2007                     case a run under construction is delayed by an early snowfall. It is                plan is to stabilize and protect slopes adequately      an “Erosion and Sediment Control
                                recommended that all construction on sloped areas be completed and                  before the onset of fall rain. However, there needs     Plan”, prior to construction and
                                adequately reseeded well before fall precipitation is expected to occur and this    to be a contingency plan within the erosion and         implementation of the plan through all
                                is one area that should be of highest priority and must not be risk managed.        sediment control plan that includes emergency slope     phases of development
                                                                                                                    stabilization in the event of an unexpected change in
                                                                                                                    the weather – be it early rain or heavy snowfall at
                                                                                                                    higher elevations.

  202. August 30,   MOE - EPD   The report compared the proposed quantity of explosives to that utilized by a GAS acknowledges that this comparison was .
       2007                     large coal mine (Fording Coal in the Elk Valley). These kinds of comparisons irrelevant and should have been omitted. However,
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                                are misleading from a receiving environment perspective since the Elk River is it did not affect the assessment of project effects or
                                much larger than the Brohm and the application and the project scale are very the mitigation recommendations.
                                different.

  203. August 30,   MOE - EPD   The report utilized the total annual flow of the Brohm River to estimate              Nitrogen from explosives would enter the Brohm
       2007                     predicted nitrogen concentrations. This is unrealistic as most construction           River and other watercourses primarily during
                                would likely occur during dryer times of the year when flows are lower resulting      rainfall events. Likely the worst case dilutions would
                                in nitrogen concentrations to be relatively higher. In reality nitrogen inputs from   occur during early fall rainstorms that follow a long
                                explosives use would enter the aquatic environment in 'pulses' on an                  summer dry period, although summer rainstorms
                                intermittent basis.                                                                   could release pulses of nitrogen into streams during
                                                                                                                      low flows. Under these circumstances, nitrogen
                                                                                                                      concentrations would be higher than predicted
                                                                                                                      based on average flows. However, the pulses would
                                                                                                                      be so brief that they would have a very minor, if any,
                                                                                                                      effect on primary productivity and would not affect
                                                                                                                      phytoplankton species composition.

  204. August 30,   MOE - EPD   The report concludes that explosives would not have a measurable effect on            Releases of nitrogen from explosives would occur .
       2007                     primary or secondary productivity in the Brohm. While this may be true, it            during construction. Stormwater pollutants would be
                                could be one component of an overall cumulative impact i.e. along with                released during operation of the base area village
                                stormwater pollutants, less riparian shading, increased sedimentation, etc.           and roads. Even without mitigation, there would be
                                                                                                                      little, if any, overlap, hence little or no cumulative
                                                                                                                      effect. The effects of nitrogen release, which can
                                                                                                                      stimulate primary productivity, and sedimentation,
                                                                                                                      which (among other effects) reduces light and thus
                                                                                                                      reduces primary productivity, would be antagonistic.
                                                                                                                      Reduction in riparian shading will be limited to
                                                                                                                      stream crossings and will affect a very limited area
                                                                                                                      of any watercourse. Thus, this effect is not expected
                                                                                                                      to be significant.

  205. August 30,   MOE - EPD   Section 9.1.2.1 indicates that the operational phase of this project will rely on     Mitigation measures described in this section (page
                                                                                                                                                                               GAS commits to employ a series of
       2007                     BMPs to mitigate urban runoff contaminants. It has been shown that BMPs               9-11) include LID techniques recommended in
                                                                                                                                                                               stormwater       Best       Management
                                alone will not mitigate impacts from NPS runoff to aquatic environments. It is        Stormwater Planning: A Guidebook for British
                                                                                                                                                                               Practices (BMP’s) and ensure that
                                recommended that this project utilize preventative measures such as low               Columbia. The conceptual stormwater management
                                                                                                                                                                               BMP’s are aggressively implemented
                                impact development techniques (LID) rather than rely on treatment of NPS via          plan envisioned a combination of LID techniques
                                                                                                                                                                               where necessary. Stormwater BMPs
                                BMPs.                                                                                 and more traditional structural BMPs.        During
                                                                                                                                                                               will include a number of appropriate
                                                                                                                      detailed design of the base area, emphasis will be
                                                                                                                                                                               Low Impact Development (LID)
                                                                                                                      placed on LID, but the techniques most suited to site
                                                                                                                                                                               guidelines for site development and
                                                                                                                      conditions will be selected.
                                                                                                                                                                               building design to manage pre-
                                                                                                                                                                               development         conditions,     post
                                                                                                                                                                               development,      that    are    to   be
                                                                                                                                                                               considered     in    conjunction    with
                                                                                                                                                                               stormwater BMP's in the stormwater
                                                                                                                                                                               management           plan, prior      to
                                                                                                                                                                               construction, to the satisfaction of the
                                                                                                                                                                               Regional Manager, Environmental
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                                                                                                                                                                             Protection  Division,   Ministry   of
                                                                                                                                                                             Environment (Surrey).

  206. August 30,   MOE - EPD   The effectiveness of proposed mitigation (p.9-12) mentions that quantity See GAS response to old #160 above.
                                                                                                                                                                             GAS commits to developing a
       2007                     control facilities will be planned in accordance to currently accepted criteria
                                                                                                                                                                             stormwater management plan during
                                without stating where and whose criteria will be used.
                                                                                                                                                                             the detailed design phase of the
                                                                                                                                                                             Project that will be provided to
                                                                                                                                                                             provincial and federal agencies for
                                                                                                                                                                             review and comment.

  207. August 30,   MOE - EPD   It is recommended that post development monitoring verify the anticipated Receiving water monitoring is proposed to assess                   GAS commits to including stormwater
       2007                     NPS loadings presented in Table 9-7.                                      the effects of stormwater discharges. If stormwater                discharge    in   post-development
                                                                                                          treatment facilities that can be monitored (e.g.                   monitoring program as part of the
                                                                                                          wetlands as opposed to soak-away pits) are                         stormwater management plan.
                                                                                                          installed, the discharge could be included in the
                                                                                                          monitoring program.

  208. August 30,   MOE - EPD   This section stated that pesticides and nutrients from a study conducted in          Numerous studies conducted worldwide over the GAS commits to the development and
       2007                     1992 by Alberta Environmental Protection resulted in no pesticides found in          last 20 years have shown minimal impacts of implementation of the “Fertilizer and
                                sediment samples collected. This information is now dated and more current           pesticide and fertilizer use on a well-managed golf Pesticide Management Plan”.
                                studies are needed to adequately compare the potential impacts from the              course. ENKON is not aware of similar studies
                                proposed golf course. In addition, comparisons need to be made with studies          conducted locally. However, we have monitored
                                conducted in a similar biogeoclimatic zone i.e. comparable amounts of rainfall,      water quality associated with several golf courses in
                                temperatures, types of pesticides, etc.                                              the Lower Mainland, have found minimal or no
                                                                                                                     impacts attributable to the golf courses.

  209. August 30,   MOE - EPD   P.9-17 states that increased inorganic nitrogen levels in the Brohm River could      The same paragraph states that a significant GAS commits to the development and
       2007                     potentially stimulate algal growth since this system appears to be nitrogen          increase in productivity is unlikely, due to the short- implementation of the “Fertilizer and
                                limited and that a moderate increase in periphyton biomass would provide             term, intermittent nature of the nitrogen inputs. The Pesticide Management Plan”.
                                additional food for benthic inverts resulting in a "positive effect". The goal for   intention of the mitigation described in this section is
                                this project is to minimize changes from natural background conditions and           to minimize changes from background levels. Slight
                                increasing the fish food supply should not necessarily be assumed as a               changes that might occur despite mitigation would
                                positive effect.                                                                     not have a negative effect and might have a slightly
                                                                                                                     positive effect.
                                The report stated that an increase in nitrogen and phosphorus in the Cheekye
                                could have a positive effect by providing more food for fish through increased GAS to implement Stormwater Management and
                                algal production and subsequent benthic invertebrate production. The goal Pesticide and Fertilizer Management Plans.
                                should be to minimize changes from natural conditions and not fish production.

  210. August 30,   MOE - EPD   P.9-19 the report states that appropriate wastewater treatment can mitigate for      Page 9-19 says: “Endocrine disrupting substances        GAS commits to implementing BMPs
       2007                     wastewater effluent components such as endocrine disrupting substances,              are poorly understood. There currently is no            and/or complying with any future
                                pharmaceuticals, hormones, detergents and ethyoxylates.             This is an       mitigation for these substances, but there also is no   regulations   that    may  address
                                inappropriate assumption as it is well known that many pharmaceuticals and           agreement       on   whether   and     under    what    endocrine disrupting substances in
                                personal care product substances (PPCPs) pass through waste water                    circumstances mitigation would be required.             wastewater treatment.”
                                treatment and are more closely associated with the effluent fraction rather than     However, GAS commits to implementing BMPs
                                the solids.    Sewage treatment plants are not designed to remove                    and/or complying with any future regulations that
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                                microcontaminants, bioaccumulative substances, hormones, etc.                         may address endocrine disrupting substances.”


  211. August 30,   MOE - EPD   The use of golf course ponds for excess sewage capacity may have health GAS does not intend to put excess sewage into golf                      GAS commits to undertake an EIS on
       2007                     implications. In addition, the ponds need to ensure they have enough capacity course ponds. Any effluent that would be directed to              the river that is ultimately selected to
                                to store wastewater during high flow periods.                                 these ponds would be treated effluent. Health                     receive treated effluent during the
                                                                                                              implications will be considered in the EIS required by            detailed design phase of the project.
                                                                                                              the MSR. An appropriate level of treatment and
                                                                                                              other mitigation measures will be implemented to                  GAS commits to developing a liquid
                                                                                                              protect human health.                                             waste management plan as part of the
                                                                                                                                                                                Environmental Management Plan and
                                                                                                                                                                                to complying with the MSR and to
                                                                                                                                                                                directing excess treated effluent to golf
                                                                                                                                                                                course ponds to maintain a minimum
                                                                                                                                                                                40:1 dilution ensure that there is
                                                                                                                                                                                adequate available dilution in the
                                                                                                                                                                                discharge river at all times, including
                                                                                                                                                                                during the low flow periods, when
                                                                                                                                                                                feasible in the resort development
                                                                                                                                                                                program.

  212. August 30,   MOE - EPD   The predicted concentrations for ammonia in the Cheekye River at the Initial          The MSR requires ammonia removal to ensure that           GAS commits to developing a liquid
       2007                     Dilution Zone edge downstream the WWTP based on modeling lowest mean                  provincial 30-day average (i.e., chronic) guideline is    waste management plan as part of the
                                monthly flows in February and September (winter and summer) were shown to             met at the initial dilution zone boundary (IDZ) when      Environmental Management Plan and
                                meet Provincial water quality criteria for the protection of aquatic life (Table 9-   the maximum ammonia concentration at the                  to complying with the MSR
                                9). These predicted ammonia concentrations, however, were 40 times higher             maximum weekly effluent discharge rate is diluted
                                than background levels in summer and over 80 times background levels in               by the 2-year, 7-day low flow. There is no specific
                                winter. The predicted 7-day winter low flow ammonia concentration was over            requirement to prevent localized ammonia toxicity
                                140 times background levels. With the predicted ammonia levels at the IDZ             within the IDZ. However, safety factors built into the
                                just below Provincial ambient criteria, it is possible that localized ammonia         guidelines along with the worst case assumptions of
                                toxicity could occur within the mixing zone.                                          the model will avoid toxicity. (Note also that the
                                                                                                                      model presented in this section used the 10-year, 7-
                                                                                                                      day low flow, which is considerably lower than the 2-
                                                                                                                      year, 7-day low flow).
                                                                                                                      During detailed design, an EIS will be conducted as
                                                                                                                      required under the MSR. Further modeling will be
                                                                                                                      done and used to determine if mitigation, such as
                                                                                                                      nitrogen removal, is required.

  213. August 30,   MOE - EPD   The report summarizes this section by stating that residual impacts to water          The section referred to (9.1.2.6) summarizes
       2007                     quality are expected to be sporadic, short term increases in suspended                residual effects of the project using the impact
                                sediment during construction and slight increases in nutrients due to the             significance attributes defined in Table 7-1 (including
                                WWTP during operation and that these impacts are not significant on a                 the scale of the effect). The cumulative effects of
                                regional level. Localized impacts may not appear significant on a large scale,        the residual impacts are assessed in Chapter 15.
                                but they can cumulatively impact sensitive aquatic environments over time or
                                in conjunction with other potentially impacting activities such as storm water
                                runoff, spills, habitat loss, etc.
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  214. August 30,   MOE - EPD   The report needs to update the hydrometric data for modeling of the fate of The most up-to-date flow information available will
       2007                     wastewater in the Cheekye as well as predicted changes in flow due to climate be used for the EIS of the wastewater treatment
                                change.                                                                       plant discharge.

  215. August 30,   MOE - EPD   Supplemental Information – Section 14 Environmental Effects of Accidents and    This section is assessing the effects of accidents GAS commits to preparing a detailed
       2007                     Malfunctions:                                                                   and malfunctions, not presenting a detailed spill spill contingency plan prior to
                                   • Page 14-1- This section should have a more defined list with reference     contingency plan. Detailed spill contingency plans construction.
                                       to the location where the Material Safety Data Sheets can be obtained    will be prepared for construction and various aspects
                                       within the Plan or within the Resort's Plan.                             of operation.      These plans will include the
                                   • This plan should clearly describe how the resort plan can be obtained      information requested.
                                       and from where on a 24 hour basis in a timely fashion.
                                   • Recommend a template that prompts for appropriate information that is
                                       required/useful to identify Hazard.
                                   • Recommend providing actions on how to identify Hazards (e.g. observe
                                       upwind, upslope, note identifiable labels from a safe distance, obtain
                                       copy of shipping documents or manifest, etc.)
                                   • Page 14-2 - provide definition of spill as defined in the Environmental
                                       Management Act, Spill Reporting Regulation. Note that spill is
                                       considered a release to the environment that includes a release to
                                       water, land or air (includes emissions from fire).
                                   • Page 14-2 - in BC, details for transport of Hazardous Waste are
                                       prescribed in the BC Environmental Management Act and the
                                       associated Hazardous Waste Regulation.
                                   • Page 14-2 - in BC, details for transport of Hazardous Waste are
                                       prescribed in the BC Environmental Management Act and the
                                       associated Hazardous Waste Regulation. Page 14-3 - include
                                       markings, management, transport and disposal of "any other waste" as
                                       per the Hazardous Waste Regulation.
                                   • Spill Contingency Plan should clearly list in order the internal and
                                       external 24 hour assured notification contacts.
                                   • Page 14-3 - under Fire and Explosion ... "contact relevant emergency
                                       agencies." Who are? and what are their assured contact phone
                                       numbers?
                                   • Page 14-3 - under Contingency Plan - May also reference "BC
                                       Environment Guidelines for Industry Emergency Response
                                       Contingency Plans"
                                   • Page 14-4 Table 14-1 under Report the Spills - The current
                                       Environmental Management Act supersedes the former BC Waste
                                       Management Act.
                                   • Page 14-5 Advisable to include assured 24 hour contacts to Canutec
                                       and suitable spill response contractors (with back-ups should primary
                                       contractor be indisposed). Ensure that the DOS is aware of materials
                                       being hauled/stored in significant quantities.

  216. August 30,   MOE - EPD   In addition, there are other waste types that should be included in the Accident This section is assessing the effects of accidents GAS commits to preparing a detailed
       2007                     Release/Spill waste types that require proper response such as Ozone and malfunctions, not presenting a detailed spill spill contingency plan prior to
                                Depleting Substances (in accordance with the Ozone Depleting Substances contingency plan. Detailed spill contingency plans construction.
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                                and Other Halocarbons Regulation)), sewage and chlorinated water.                   will be prepared for construction and various aspects
                                                                                                                    of operation. These types of substances will be
                                                                                                                    included, if they are relevant to a specific activity or
                                                                                                                    component of the Garibaldi and Squamish Project.

  217. August 30,   MOE - EPD   Note that MOE no longer use the term "Special Waste". This former term is The final hazardous materials management and spill
       2007                     now defined as "Hazardous Waste".                                         contingency plans will use this terminology.

  218. August 30,   MOE - EPD   Climate Change should be noted as a key factor in moving baseline conditions. Comment noted.
       2007                     It could be considered as another factor that will alter or stress the subject
                                aquatic ecosystems. [in reference to cumulative impacts]

  219. August 30,   MOE - EPD   MOE does not agree that the residual effects of the proposed project on             The potential for stormwater runoff to alter hydrology     GAS commits to developing a
       2007                     hydrology will be limited to minor reductions in the flow of some streams.          was assessed, and mitigation was recommended.              stormwater management plan during
                                Rather, the development can also alter both the magnitude and duration of           The implementation of appropriate mitigation such          the detailed design phase of the
                                storm event responses in the streams, as well as alter base flows. These            as the Stormwater Management Plan and LID’s                Project which will be provided to
                                potential impacts should be assessed.                                               measures will avoid or minimize the residual effects.      provincial and federal agencies for
                                                                                                                                                                               review and comment. and GAS
                                                                                                                                                                               commits to incorporate LID techniques
                                                                                                                                                                               most suited to the site conditions into
                                                                                                                                                                               all phases of development, where
                                                                                                                                                                               feasible.

  220. August 30,   MOE - EPD   MOE does not agree that residual effects with respect to TSS will be limited to     The potential for stormwater runoff to alter hydrology      GAS commits to developing a
 209   2007                     short duration, sporadic increases during construction. Rather, stormwater          was assessed, and mitigation was recommended.              stormwater management plan during
                                inputs coupled with any resulting increase in streambank erosion will also          The implementation of appropriate mitigation such          the detailed design phase of the
                                impact on TSS loadings. Storm event responses may be more significant, and          as the Stormwater Management Plan and                      Project which will be provided to
                                of greater duration.                                                                LID’s.measures will avoid or minimize the residual         provincial and federal agencies for
                                                                                                                    effects.                                                   review and comment and GAS
                                                                                                                                                                               commits to incorporate LID techniques
                                                                                                                                                                               most suited to the site conditions into
                                                                                                                                                                               all phases of development, where
                                                                                                                                                                               feasible.

  221. August 30,   MOE - EPD   Potential impacts to receiving waters due to the treated sewage discharge to        The residual effects of sewage discharge have been
       2007                     the Cheekye River will be related to more than just inorganic nutrient levels. In   assessed in Chapter 9, section 9.1.2.5 and section
                                the immediate receiving waters, organic nutrients can support a sewage              9.1.2.6.
                                fungus matrix, organics ranging from surfactants to pharmaceuticals can alter
                                populations and community structures of aquatic life forms, and some sewage         The effects of all constituents of the wastewater
                                contaminants can even illicit a toxic response in fish and invertebrates. The       effluent will be assessed further in the EIS. Since
                                potential cumulative impacts with other development-related activities on the       only a small portion of the base area development
                                immediate receiving waters should be assessed, as should the potential              drains to the Cheekye River, even without mitigation
                                cumulative impacts in further downstream waters with the unrelated activities       of stormwater effects, there would be only minor
                                outlined in the report.                                                             potential for cumulative effects of project
                                                                                                                    components on this watercourse.

  222. August 30,   MOE - EPD   Upgrading of the Sea-to-Sky Highway will result in more than an increased Effects of the Sea-to-Sky Highway were considered
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        2007                    loading in TSS. Other contaminants related to highway runoff may increase as in the updated Cumulative Effects Assessment.
                                the impermeable highway surface area and vehicle usage are both increased. However, as discussed in Volume 7, after mitigation
                                These factors should be considered when assessing cumulative impacts.        residual effects of stormwater discharges are not
                                                                                                             expected. Therefore, cumulative effects of runoff
                                                                                                             from the expanded highway were not assessed.

  223. August 30,   MOE - EPD   MoE disagrees that the cumulative effect of project construction will be a net    Residual effects are the effects that remain after        GAS commits to developing a
       2007                     benefit of slightly reduced TSS levels in Brohm River and Swift Creek. Rather,    mitigation. The potential for stormwater runoff to        stormwater management plan during
                                as they have noted, many of the logging roads have already been                   alter hydrology was assessed, and mitigation was          the detailed design phase of the
                                decommissioned, and are apparently not significant TSS contributors. In           recommended. The implementation of appropriate            Project which will be provided to
                                addition, any stormwater from impermeable surface areas will very likely result   mitigation will avoid residual effects. Mitigation for    provincial and federal agencies for
                                in an increase over previous TSS levels. This result should not be discounted,    stormwater runoff is expected to result in negligible     review and comment.
                                and should be addressed to ensure significant impacts do not occur.               increases in TSS and other substances.

  224. August 30,   MOE - EPD   Some water quality concerns have already been highlighted from the limited        Existing metals concentrations above provincial           GAS commits to developing a
       2007                     data collected. These existing impacts should be considered from the              guidelines are associated with suspended solids;          stormwater management plan during
                                perspective of potential cumulative impacts when linked with impacts caused       dissolved (more likely bioavailable) metals levels are    the detailed design phase of the
                                by the subject project. Some of these natural factors include the natural         low. Thus, the background condition does not              Project which will be provided to
                                softness of the water and the high TSS levels due to glacial flour, and how       change the assessment that stormwater runoff will         provincial and federal agencies for
                                climate change may alter these conditions.                                        have negligible impact because stormwater                 review and comment.
                                                                                                                  management measures will significantly reduce
                                                                                                                  metals and suspended solids concentrations. The
                                                                                                                  assessment took into account the natural softness of
                                                                                                                  the water. Elevated TSS and metals associated with
                                                                                                                  glacial flour cannot be considered an impact, since
                                                                                                                  they are natural components of the environment.

  225. August 30,   MOE - EPD   Regarding Cumulative Effects Related to Nutrients, MOE would point out that       The cumulative effects assessment addresses only          GAS commits to developing a
       2007                     there is a concern regarding 'eutrophication' not just in the downstream          residual effects. These effects are assessed in           stormwater management plans during
                                Cheakamus River waters, but also in the immediate receiving waters of the         combination with the effects of other project in the      the detailed design phase of the
                                streams. These systems could suffer from cumulative impacts of nutrients,         cumulative     effects    assessment     area    (i.e.,   Project which will be provided to
                                TSS and other contaminants that emanate from both the proposed wastewater         downstream). The effects of all constituents of the       provincial and federal agencies for
                                discharge and proposed stormwater discharges. These potential cumulative          wastewater effluent will be assessed further in the       review and comment.
                                impacts should also be assessed.                                                  EIS. Since only a small portion of the base area
                                                                                                                  development drains to the Cheekye River, even
                                                                                                                  without mitigation of stormwater effects, there would
                                                                                                                  be only minor potential for cumulative effects of
                                                                                                                  project components on this watercourse.

  226. August 30,   MOE - EPD   Is any cumulative impact [on fish] anticipated from the limited loss of riparian No. The majority of water withdrawal will occur             GAS commits to providing streamside
       2007                     vegetation coupled with the water withdrawals?                                   during freshet, when it would have no significant          protection and enhancement areas for
                                                                                                                 effect on stream temperature (or stream flow from a        all   residential  and     commercial
                                                                                                                 fish habitat perspective). Water withdrawal during         developments as per the Fish
                                                                                                                 summer low flow will be minimal and therefore is not       Protection   Act-    Riparian   Areas
                                                                                                                 expected      to   affect   stream     temperature.        Regulation,      Water     Act     and
                                                                                                                 Furthermore, the loss of riparian vegetation will be       Regulations or the current regulations
                                                                                                                 limited such that little or no effect on stream            at the time of construction. Should
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                                                                                                                     temperature is expected.                                minor infringements to the Streamside
                                                                                                                                                                             Protection and Enhancement Areas be
                                                                                                                                                                             unavoidable, GAS Inc. will comply
                                                                                                                                                                             with DFO’s fisheries policy.

  227. August 30,   MOE - EPD   Regarding the Significance of Cumulative Effects, some consideration should Minor losses of riparian vegetation primarily will
       2007                     be given to impacts on [fish] species and populations that are genetically affect non-fish bearing tributaries to the Brohm
                                unique, and/or able to use only a few systems.                              River. These losses are not expected to cause any
                                                                                                            measurable effects on fish populations in the Brohm
                                                                                                            River, nor are any cumulative effects on downstream
                                                                                                            fish populations (whether genetically unique or not)
                                                                                                            anticipated.

  228. August 30,   MOE - EPD   Section 17.2 lists 10 elements of effective erosion and sediment control and it      Comment noted. Priority effort can be placed on the
       2007                     should be emphasized that not all are equal and that the highest priority effort     listed measures. However, other elements of the
                                needs to be made to: 1) minimize needless clearing and grading, 3)phase              plan including (2) protect waterways, (5) protect
                                construction to limit soil exposure, 4) stabilize exposed soils immediately and      steep slopes and cuts and (8) ensure contractors
                                10) adaptive management                                                              are trained are also very important.

  229. August 30,   MOE - EPD   Section 17.4 lists specific erosion controls for ski runs. The 2nd bullet states     Any construction that creates exposed soil will be       GAS Inc. commits to developing and
       2007                     that construction should be completed before winter snows cover the ground -         completed in time to stabilize and seed the area        implementing an erosion and sediment
                                this should be adjusted to state that construction and slope stability should be     before the onset of fall rain. Environmental monitors   control     (ESC)     plan     prior    to
                                completed well before the onset of fall rains.                                       will track construction activity and BMPs to minimize   construction to address sediment and
                                                                                                                     risk of erosion.                                        erosion issues during construction of
                                                                                                                                                                             all road, base and ski/lift areas. GAS
                                                                                                                     GAS will use erosion and sediment control BMP’s to      commits to engage an independent
                                                                                                                     establish plant cover on disturbed sites before the     third party “Environmental Monitor(s)”
                                                                                                                     onset of fall precipitation and revegetate high         for all construction phases of the
                                                                                                                     elevations sites annually to allow adequate time for    Project. The Environmental Monitor
                                                                                                                     vegetation growth prior to winter, as outlined in the   will review, evaluate, and report to
                                                                                                                     ESC to be developed to the satisfaction of the          regulators     on    the     construction
                                                                                                                     Regional Manager, Environmental Protection              activities and the effectiveness of the
                                                                                                                     Division, Ministry of Environment (Surrey).             environmental control strategies and
                                                                                                                                                                             mitigation measures, with respect to
                                                                                                                                                                             the terms and conditions of the EMPs
                                                                                                                                                                             and      other    regulatory     Permits,
                                                                                                                                                                             Approvals and Authorizations that may
                                                                                                                                                                             apply.

  230. August 30,   MOE - EPD   In general, the Project appears to rely on sediment and erosion BMPs and puts        GAS will implement LID techniques that are              GAS commits to employ a series of
       2007                     too much effort stating their effectiveness... Instead, the Project should look at   appropriate for the site. However, sediment and         stormwater Best Management Practices
                                minimizing its final impervious surface area and looking towards low impact          erosion control BMPs are necessary to deal with         (BMP’s) and ensure that BMP’s are
                                development to prevent erosion and sedimentation from occurring rather than          disturbed soils, which occur during the construction    aggressively    implemented      where
                                                                                                                                                                             necessary. Stormwater BMPs will include
                                trying to mitigate it.                                                               phase of any project.
                                                                                                                                                                             a number of appropriate Low Impact
                                                                                                                                                                             Development (LID) guidelines for site
                                                                                                                                                                             development    and   building    design
                                                                                                                                                                             to manage              pre-development
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                                                                                                                                                                              conditions, post development, that are
                                                                                                                                                                              to be considered in conjunction with
                                                                                                                                                                              stormwater BMP's in the stormwater
                                                                                                                                                                              management           plan, prior      to
                                                                                                                                                                              construction, to the satisfaction of the
                                                                                                                                                                              Regional Manager, Environmental
                                                                                                                                                                              Protection    Division,    Ministry   of
                                                                                                                                                                              Environment (Surrey).

  231. August 30,   MOE - EPD   Two dams are proposed to be built within the main channels of Brook Creek           Riparian and stream bottom habitats will not be
       2007                     and a tributary to Brohm Creek to store water for consumption and                   eliminated entirely.     Habitat characteristics will
                                snowmaking. Significant concerns exist over the use of an entire stream             change from fast-moving to slow-moving water (flow
                                channel for water storage where the riparian and stream bottom habitats would       through the reservoirs will continue), and the entire
                                be eliminated entirely. While these streams are non-fish bearing at these           water surface area may not be shaded by riparian
                                elevations, they can be significant fish food sources and provide habitat for       vegetation. These changes likely will alter the
                                other non-aquatic species such as amphibians, birds and small mammals.              periphyton and benthic invertebrate communities
                                                                                                                    within the reservoir areas. These changes might
                                                                                                                    add diversity to the overall aquatic ecosystem.

  232. August 30,   MOE - EPD   The snowmaking component proposes to use BMPs from New Hampshire                    The snowmaking BMPs cited are appropriate for any
       2007                     DOE but should try to use BMPs designed for the Pacific coast. In addition,         location. Page 9-13 notes that “the most frequently
                                snowmaking is proposed to be induced with 'additives' but the report failed to      used substance will be Snomax, an “inducer” used
                                provide details on what these additives are comprised of.                           to facilitate snowmaking. Snomax is protein derived
                                                                                                                    from       the   naturally  occurring    bacterium,
                                                                                                                    Pseudomonas syringae (strain 31a). It is non-
                                                                                                                    pathogenic and non-toxic.”

  233. August 30,   MOE - EPD   The Watershed Protection Plan appears to be incomplete and provides very            A detailed Source Protection (Watershed Protection)       GAS commits to develop a Source
       2007                     little detail besides stating that the potable water supply will have a Watershed   Plan will be developed as part of the application for     Protection Plan as part of the
                                Protection Plan developed. It is recommended that more info be provided as          an Operating Permit for the drinking water treatment      application for an Operating Permit for
                                well as extending the Watershed Protection Plan to include the entire               and distribution system.         The Project Report       the drinking water system.
                                development footprint area, not just upstream of the water diversion points for     Specifications for this plan focus on protection of the
                                potable water.                                                                      drinking water supply for the development (i.e., the
                                                                                                                    area upstream of the diversion).             However,
                                                                                                                    stakeholders, including downstream water users will
                                                                                                                    be consulted during development of the final plan.

  234. August 30,   MOE - EPD   Golf course irrigation is listed under the unrestricted category for reclaimed      The appropriate use category, reclaimed water             GAS commits to comply with MSR
       2007                     water (schedule 2) of the Municipal Sewage Regulation (MSR) whereby the             quality, monitoring frequency, etc. will be addressed     requirements, including conducting an
                                plan states effluent quality for the restricted category, although there are some   during detailed design of the wastewater treatment        EIS.prior to the wastewater treatment
                                provisions in the MSR for allowing for this.                                        plant and preparation of the EIS.                         plant construction.

                                Although the plan provides only preliminary information regarding reclaimed
                                water it should be noted that the MSR has numerous requirements that need
                                to be met.

  235. August 30,   MOE - EPD   For the discharge to the Cheekye River, the plan indicates a minimum dilution The GAS phased operating wastewater treatment
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        2007                    of 40:1. It is unclear if this is initial dilution or dilution ratio.                 plant will ensure that there is adequate available
                                                                                                                      dilution in the discharge river at all times, including
                                                                                                                      during the low flow periods

  236. August 30,   MOE - EPD   Will the discharger be a municipal government or a private company? If it is a This will be determined through further negotiations
       2007                     private company and there are primary residences at the site, financial with the local government during the rezoning
                                assurance will be required.                                                    process.

  237. August 30,   MOE - EPD   It is assumed that the discharge will be registered under the MSR and GAS understands and will comply with these GAS commits to comply with MSR
       2007                     therefore an EIS and an operating plan will be required. Also, all applicable requirements.                      requirements, including conducting an
                                requirements of the MSR need to be met.                                                                          EIS, prior to the waste water treatment
                                                                                                                                                 plant construction.

  238. August 30,   MOE - EPD   It is recommended that this project adopt the integrated strategy for managing        GAS’s original stormwater management planning              GAS commits to developing a
       2007                     the rainfall spectrum as outlined in the "Stormwater Planning: a Guidebook for        (April 2003) indicated that future systems would          stormwater management plan during
                                BC" and in "Beyond the Guidebook". These guides promote using the water               comply with the Stormwater Guidebook for the              the detailed design phase of the
                                balance model for the site, neighborhood and entire watershed as a tool to            Province of British Columbia. GAS provided an             Project which will be provided to
                                evaluate source control options. Stormwater should not be seen as a drainage          addendum stormwater report (McElhanney October            provincial and federal agencies for
                                issue but as a resource for groundwater recharge, aquatic and riparian                2008: revised January 2009) that outlined global          review and comment.
                                species, drinking water and for recreational uses.                                    performance targets and the water balance
                                                                                                                      modeling process, as per the new approach
                                                                                                                      described as “Beyond the Guidebook.” This report
                                                                                                                      was submitted to the EAO in February 2009 as part
                                                                                                                      of the Addendum 3 documents.


  239. August 30,   MOE - EPD   22.1.3 Rainfall data - this section utilizes rainstorm data from the 1980s. More The rainfall data presented in Table 22-1 were
       2007                     recent rainstorm data is required as well as predicted rainfall patterns due to current at the time of report submission. The
                                climate change.                                                                  reference to the 1980s involved studies on which
                                                                                                                 AES based a 1-hour rainfall model. Urban Systems
                                                                                                                 has collected up-to-date rainfall data and
                                                                                                                 incorporated into the revised modeling of Brohm
                                                                                                                 River flows submitted in draft in Addendum 3 in
                                                                                                                 February 2009 and an updated interim report in
                                                                                                                 June 2009. The most recent rainfall data available,
                                                                                                                 and the most recent model applicable to the project
                                                                                                                 area, will be used to design any required stormwater
                                                                                                                 management structures. Climate (including rainfall)
                                                                                                                 monitoring stations will be established at an
                                                                                                                 appropriate time.

  240. August 30,   MOE - EPD   22.1.4 Hydrologic Modeling - the model used in this section appears to be             GAS’s original stormwater management planning              GAS commits to developing a
       2007                     focused solely on water draining by pipe or overland routes. A more                   (April 2003) indicated that future systems would          stormwater management plan during
                                progressive approach to rainwater management is currently being used where            comply with the Stormwater Guidebook for the              the detailed design phase of the
                                rainfall capture/retention/infiltration is the first priority rather than conveying   Province of British Columbia. GAS provided an             Project which will be provided to
                                water immediately into stormwater detention ponds.                                    addendum stormwater report (McElhanney October            provincial and federal agencies for
                                                                                                                      2008: revised January 2009) that outlined global          review and comment.
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                                                                                                                     performance targets and the water balance
                                                                                                                     modeling process, as per the new approach
                                                                                                                     described as “Beyond the Guidebook.” This report
                                                                                                                     was submitted to the EAO in February 2009 as part
                                                                                                                     of the Addendum 3 documents.


  241. August 30,   MOE - EPD   The proposed impervious surface area for residential zones is 40% and 60%            The proposed impervious area is <6% on a              GAS commits to reporting the
       2007                     for other developed areas (p.22-9) - this is a very high level of                    watershed basis. Higher imperviousness within the    percentage of impervious surface area
                                imperviousness. Impacts to resident aquatic organisms in small streams are           base area development is due to limited area         by sub-watershed in the Stormwater
                                measureable at EIS of 30% or greater (effective impervious surface area).            available for development due to topographic         Management Plan and to provide
                                The project proponent needs to reduce the amount of total impervious surface         constraints; these higher impervious areas are       appropriate mitigation accordingly by
                                area through various means (conserving natural areas, disconnecting roof             limited in size and dispersed (see Urban Systems     sub-watershed.
                                leaders, pervious roads/parking lots, infiltration & rainfall retention, etc.) to    Interim Report (May 2009) in Addendum 3).
                                have an effective impervious surface area near or under 30%.                         Methods of reducing total impervious area that are   GAS commits to implement methods
                                                                                                                     compatible with soils and topographic constraints    of reducing total impervious area that
                                                                                                                     will be implemented during further stormwater        are compatible with soils and
                                                                                                                     management planning.                                 topographic constraints.

  242. August 30,   MOE - EPD   22.2 Stormwater Volume management - this section does refer to infiltration as       GAS’s original stormwater management planning
       2007                     a source control tool and calculates infiltration sizing systems using both the      (April 2003) indicated that future systems would
                                DFO and the Ministry of Environment methods. DFO was a partner in                    comply with the Stormwater Guidebook for the
                                developing the BC Stormwater Planning guidebook so the Provincial                    Province of British Columbia. GAS provided an
                                guidebook should be the method used as the DFO guidelines are now dated.             addendum stormwater report (McElhanney October
                                                                                                                     2008: revised January 2009) that outlined global
                                                                                                                     performance targets and the water balance
                                                                                                                     modeling process, as per the new approach
                                                                                                                     described as “Beyond the Guidebook.” This report
                                                                                                                     was submitted to the EAO in February 2009 as part
                                                                                                                     of the Addendum 3 documents.

  243. August 30,   MOE - EPD   Page 22-21 suggests that Tier C storms should be conveyed safely to a As stated on pp 10-21 and 22-19, Tier A is less than
       2007                     stream without mentioning how that would be done nor defining what 'safely' 50% of a Mean Annual Storm (MAS), and is the
                                means. This page also utilizes rainfall rates that likely need to be updated.    source of 74% of all rainfall volume.
                                The 2nd paragraph uses Tier A rainfall volume for this project as 50% of total
                                rainfall volume but in an earlier paragraph (p.22-19), it was stated that Tier A
                                storms are 74% of rainfall volume.

  244. August 30,   MOE - EPD   In summary, the use of infiltration is highly recommended as a source control        GAS’s original stormwater management planning
                                                                                                                                                                          GAS commits to developing a
       2007                     tool for stormwater. This report, however, suggests that infiltration is a lower     (April 2003) indicated that future systems would
                                                                                                                                                                          stormwater management plan during
                                priority than conveying runoff immediately or detention pond construction and        comply with the Stormwater Guidebook for the
                                                                                                                                                                          the detailed design phase of the
                                does not mention how the stormwater management plan would link these                 Province of British Columbia. GAS provided an
                                                                                                                                                                          Project which will be provided to
                                various components and BMPs together to protect the receiving environment            addendum stormwater report (McElhanney October
                                                                                                                                                                          provincial and federal agencies for
                                from stormwater impacts. This report also needs to look at stormwater                2008: revised January 2009) that outlined global
                                                                                                                                                                          review and comment.
                                management at the site, neighborhood and watershed scales as well as at              performance targets and the water balance
                                conserving natural areas and rainfall retention as top priorities on site followed   modeling process, as per the new approach
                                by runoff control via detention and infiltration ponds.                              described as “Beyond the Guidebook.” This report
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                                                                                                           was submitted to the EAO in February 2009 as part
                                The NPS Control Plan should shift its focus from treatment systems towards of the Addendum 3 materials.
                                incorporating low impact development design into the construction plan.

  245. August 30,   MOE - EPD   It is recommended that the NPS Control Plan utilize up to date references for The “Final Stormwater Management Plan” will be
       2007                     NPS treatment as well as information derived from the West Coast/Pacific based on up-to-date information applicable to local
                                Northwest which is most relevant to the conditions near Squamish.             conditions.

  246. August 30,   MOE - EPD   23.1 Water Quality Management – this section implies that drinking water and    This section was not intended to imply that drinking
       2007                     recreational opportunities are the only values to be protected from NPS         water and recreational opportunities are the only
                                discharges (p.23-2, last paragraph) when fisheries, fish habitat and riparian   values to be protected.        GAS recognizes the
                                ecosystems are also of great importance in need of protection.                  importance of protecting aquatic ecosystems as
                                                                                                                discussed in other sections of the report.

  247. August 30,   MOE - EPD   23.2 Options for Improving Water Quality - this section needs to address the The detailed stormwater design will consider the GAS commits to developing a
       2007                     issue of the potential for contaminant build-up in wet-pond detention facilities potential for contaminant build-up.          Stormwater Management Plan during
                                as this can contribute to chronic, long term impacts to resident species and, if                                              the detailed design phase of the
                                bioaccumulative substances are present, to regional species as well.                                                          Project which be provided to provincial
                                                                                                                                                              and federal agencies for review and
                                                                                                                                                              comment and which will address
                                                                                                                                                              contaminant build up and will include
                                                                                                                                                              appropriate    maintenance      and/or
                                                                                                                                                              monitoring programs.

  248. August 30,   MOE - EPD   23.2.3 Stormwater Wetlands - this section stated that the use of natural GAS does not intend to use natural wetlands for .
       2007                     wetlands for stormwater treatment should be approached with a "great deal of stormwater treatment.
                                caution". Native, naturally occurring wetlands are not allowed to be utilized for
                                stormwater treatment.

  249. August 30,   MOE - EPD   23.3. Water Quality Improvement - this section mentions water quality Any stormwater treatment facilities that discharge to            GAS commits to developing a
       2007                     objectives, operational criteria and refers to predicted sediment removal rates surface waters would be designed with the intention    Stormwater Management Plan during
                                from the scientific literature (which are very outdated). What is not clear from of meeting provincial receiving water guidelines.     the detailed design phase of the
                                this section is how water quality objectives would be applied, how monitoring                                                          Project which will be provided to
                                would be conducted to measure potential water quality improvements. In the                                                             provincial and federal agencies for
                                3rd paragraph on p.23-5, the report states that it "...would be difficult for a                                                        review and comment and which will
                                regulatory agency to place strict measureable criteria upon the quality of the                                                         address receiving water guidelines.
                                effluent." If no site-specific objectives are developed, then Provincial Approved
                                and Working Water Quality Criteria apply to stormwater effluent discharges. In
                                addition, pollution, as defined in the Environmental Management Act, must not
                                be caused as well as the release of a deleterious substance under the Federal
                                Fisheries Act.

  250. August 30,   MOE - EPD   Consider no burning of land clearing debris – chip material or compost as an GAS is investigating alternatives to burning including
       2007                     alternative. There are facilities and equipment in the area to facilitate recycling recycling and onsite composting.
                                of woody debris.

  251. August 30,   MOE - EPD   If burning must occur:                                                          Any open burning will be done in compliance with GAS commits to comply with the Open
       2007                                                                                                     the Open Burning Smoke Control Regulation. GAS Burning Smoke Control Regulation, if
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                                   •   Ensure that every reasonable alternative for reducing, reusing or will consider monitoring PM2.5 during burning.            burning is required.
                                       recycling debris has been pursued to minimize the amount of debris to
                                       be open burned, as indicated by the Open Burning Smoke Control
                                       Regulation.
                                   •   Ensure no burning of prohibited materials, as specified in the Open
                                       Burning Smoke Control Regulation.
                                   •   Follow the ventilation index for Squamish, and burn according to the
                                       Open Burning Smoke Control Regulation.
                                   •   Consider PM2.5 monitoring in the vicinity of the project to ensure human
                                       and environmental health are protected.

  252. August 30,   MOE - EPD   For dust control, consider covering storage piles.                                Storage piles would be covered if dust became and GAS commits to implement a Fugitive
       2007                                                                                                       issue and watering them proved unfeasible or Dust Control Plan.
                                                                                                                  ineffective.

  253. August 30,   MOE - EPD   Section 26.3.1 First paragraph second sentence. “such as ???” - Contaminants It should have said “particulate matter”.             .
       2007                     are missing.

  254. August 30,   MOE - EPD   The objectives of environmental monitoring are commendable and the Ministry GAS will employ an environmental monitor to help GAS      commits     to     engage        an
       2007                     would like to stress that the key to effective environmental monitoring is for ensure that construction contractors correct “Environmental     Monitor(s)”     for     all
                                construction contractors to be adaptive to correct problems as they arise.     problems as they arise.                       construction phases of the Project.

  255. August 30,   MOE - EPD   It is proposed the EM inspect sediment control systems weekly. It is The Environmental Monitor will make additional site GAS          commits     to     engage        an
       2007                     recommended that additional inspections be targeted during storm/rain events visits during significant storms to ensure that “Environmental    Monitor(s)”     for     all
                                especially at the onset of fall rains.                                       sediment control works are functioning and/or   construction phases of the Project.
                                                                                                             recommend adaptive management measures to
                                                                                                             construction contractors.

  256. August 30,   MOE - EPD   Management Plans for Vegetation and Wildlife - it is recommended that the GAS will submit vegetation and wildlife management GAS commits to submit Vegetation
       2007                     project proponents and the EM consult with Ecosystems Section biologists, plans to the Ecosystem Section for review.         and Wildlife Management Plans to
                                Environmental Stewardship Division prior to finalizing management plans.                                                     MOE - ESD (Ecosystem Section) for
                                                                                                                                                             review.

  257. August 30,   MOE - EPD   Additional recommended monitoring should include:                             Runoff monitoring during construction (as well as    GAS commits to:
       2007                                                                                                   turbidity monitoring upstream and downstream of      a) monitoring stream discharge
                                   •   Stream discharge volumes monitored downstream the water construction) is included in the responsibilities of the            volumes downstream of the water
                                       withdrawals                                                            Environmental Monitor.                               withdrawal points as per the conditions
                                   •   Stormwater/runoff monitoring be conducted during construction not just Stream discharge will be monitored downstream of     of the water license; and
                                       during operation                                                       water withdrawals during operation.                  b) monitoring stream temperatures at
                                   •   Stream temperatures be monitored throughout the project area not just                                                       each of the diversion points and two
                                       in the headwaters where the withdrawals are occurring                  Stream temperatures will be monitored at locations
                                                                                                                                                                   locations in the lower Brohm River.
                                                                                                              throughout the project area.

  258. August 30,   MOE - EPD   Section 30.2.1. Baseline monitoring for the WWTP - additional parameters These field measurements will be included in the GAS        commits      to    include
       2007                     should include field measurements of dissolved oxygen (DO), turbidity and pH. baseline monitoring program.                measurements of dissolved oxygen,
                                                                                                                                                          turbidity and pH in the Water Quality
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                                                                                                                                                                           Monitoring Plan.

  259. August 30,   MOE - EPD   Section 30.2.2. Monitoring during operation - consult and coordinate with         ENKON Environmental Limited’s proposed water             GAS commits to continue to collect
       2007                     Environment Canada and MOE Ecosystems staff on benthic invertebrate               license monitoring plan includes five locations within   stream flow data as long as required
                                monitoring. Any further work in the Cheakamus should coordinate with the          the Brohm River watershed for on-going                   by government agencies to protect
                                Cheakamus Ecosystem Recovery Plan.                                                macroinvertebrate sampling. GAS will consult with        water quality, fisheries or fisheries
                                                                                                                  Environment Canada and MOE Ecosystems staff on           habitat, or in accordance with the
                                                                                                                  benthic invertebrate monitoring.                         water license requirements, and to
                                                                                                                                                                           collect additional biological data as
                                                                                                                                                                           required as part of the water licensing
                                                                                                                                                                           process.

  260. August 30,   MOE - EPD   Section 30.3 states that water withdrawals will not result in significant changes The volume of water withdrawn will comply with GAS commits to monitoring stream
       2007                     in stream temperatures without data or references to back this claim.             current provincial guidelines. Meeting the guidelines flows and temperature as a condition
                                                                                                                  should ensure maintenance of instream temperature of the water license.
                                                                                                                  within an acceptable range. In addition, no water
                                                                                                                  will be withdrawn during the summer low flow period,
                                                                                                                  which will further reduce the potential for effects on
                                                                                                                  stream temperature.

  261. August 30,   MOE - EPD   Section 30.4 Monitoring Related to Stormwater Runoff - this section stated that   Additional baseline water quality monitoring will be     GAS commits to developing a Water
       2007                     water quality data already collected will provide baseline info for the           undertaken. It will include two 5-week monitoring        Quality Monitoring Program prior to
                                operational phase stormwater monitoring program. The baseline data is now         cycles during critical time periods (summer and          construction and as required for other
                                dated and will need to be updated if it is to be applied to monitoring data       winter low flows).       However, GAS note that          authorizations.
                                collected during construction and operation.                                      monitoring upstream and downstream of the
                                                                                                                  development during storm events would be more
                                                                                                                  informative than trying to compare post-development
                                                                                                                  with baseline conditions.

  262. August 30,   MOE - EPD   Additional field parameters for stormwater monitoring should include: These field measurements will be included in the                     GAS commits to developing a Water
       2007                     temperature, turbidity, pH and dissolved oxygen. Laboratory analysis for monitoring program, as will ICP-MS detection limits               Quality Monitoring Program prior to
                                metals should utilize low level ICP-MS methods to obtain the lowest possible for metals.                                                   construction and as required for other
                                detection limits.                                                                                                                          authorizations.

  263. August 30,   MOE - EPD   Temperature loggers are proposed to be installed to monitor potential impacts     Temperature loggers will be installed at selected GAS will monitor stream temperatures
       2007                     from water withdrawls, however, continuous temperature readings are also          sites throughout the proposed development area. at each of the diversion points and two
                                useful for monitoring stormwater runoff as the removal of vegetation and          Presently GAS is measuring stream and air locations in the lower Brohm River.
                                impervious surface areas can alter stream temperature regimes.                    temperatures at the two diversion points and two
                                                                                                                  locations in the lower Brohm River (see Addendum
                                                                                                                  3).

  264. August 30,   MOE - EPD   Biodiversity is proposed to be monitored by collecting periphyton and benthic     ENKON Environmental Limited’s proposed water             GAS commits to develop the Water
       2007                     invertebrate data. Ensure coordination with the Cheakamus River Recovery          license monitoring plan includes five locations within   Quality Monitoring Plan for review with
                                Plan and Environment Canada's Canadian Aquatic Benthic Invertebrate               the Brohm River watershed for on-going                   appropriate agencies.
                                Network (CABIN).       Benthic invertebrate monitoring has already been           macroinvertebrate sampling. GAS will consult with
                                conducted using Environment Canada's approach so subsequent monitoring at         Environment Canada and MOE Ecosystems staff on           GAS commits to developing a Water
                                Garibaldi at Squamish should adopt the same methodology.                          benthic invertebrate monitoring.                         Quality Monitoring Program prior to
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                                                                                                                                                                         construction and as required for other
                                                                                                                                                                         authorizations.

  265. August 30,   MOE - EPD   The golf course runoff monitoring program should include field parameters The field parameters will be added to the golf course          GAS commits to developing a Water
       2007                     such as dissolved oxygen, temperature, turbidity as well as laboratory monitoring program as part of the Water Quality                   Quality Monitoring Program prior to
                                measurements for TSS, low level metals and hardness.                      Monitoring Plan.      Monitoring TSS, metals and               construction and as required for other
                                                                                                          hardness is unnecessary.         Once the turf is              authorizations.
                                                                                                          established, there is essentially no potential for
                                                                                                          runoff of TSS and associated metals. No pesticides
                                                                                                          that contain metals are envisioned for golf course
                                                                                                          use at this time. If such pesticides were used, low
                                                                                                          level metals and hardness would be added to the
                                                                                                          monitoring program.

  266. August 30,   MOE - EPD   Overall the water quality monitoring plan requires a lot more detail to fully More detailed maps will be provided in the final GAS commits to developing a Water
       2007                     assess its potential effectiveness. Clearer maps indicating monitoring stations Water Quality Monitoring Plan.                 Quality Monitoring Program prior to
                                and the associated land uses at completion should also be included. The maps                                                   construction and as required for other
                                included were difficult to interpret.                                                                                          authorizations.

  267. August 30,   MOE - WSD   It is unclear as to whether all works or changes in and about streams have         GAS recognizes the need to provide notification
       2007                     been identified and specified within the application. It is expected that the      and/or apply for approvals under the Water
                                proponent will apply for the appropriate approvals or provide notifications (as    Regulation/Water Act. Project-specific requirements
                                indicated under the Water Regulation) for any works in and about a stream.         will be identified during detailed design.

        December                Change in and about a Stream applications will need to clearly identify the
        18, 2009                stream crossings that are being submitting under a Water Act Notification,
                                versus those requiring a Water Act Approval. Plans will need to clearly identify
                                those streams that are within the debris flow criteria, and have been designed
                                with a “factor of four” applied to the culvert diameter.

  268. August 30,   MOE - WSD   Insufficient details have been provided regarding the Watershed Protection  A water quality monitoring plan specific to the              GAS commits to developing a Water
       2007                     Plan (Volume 7) and Water Quality Monitoring Plan. WSD considers that       requirements for an Operating Permit for the                 Quality Monitoring Program prior to
                                ongoing monitoring is fundamental to understanding the impact of GAS on the drinking water treatment and distribution will be            construction and as required for other
                                watersheds and ecosystems in the project area. As such, updated plan(s) for developed and implemented. A detailed Source                 authorizations..
                                Watershed Protection and Water Quality must be provided for review.         Protection (Watershed Protection) Plan will be
                                                                                                            developed as part of the application for an Operating
        December                This is a multi MOE division issue; monitoring plans are to be submitted to Permit for the drinking water system. These plans
        18, 2009                MOE-EPD/WSD for review and approval. Water Quality issues are raised by will be provided to MOE for review.
                                MOE-EPD, while source water protection are issues raised by MOE-WSD.

  269. August 30,   MOE - WSD   In terms of source drinking water quality, the monitoring sites shown are          The water quality monitoring plan addresses           GAS commits to developing a Water
       2007                     inappropriate as they are not located at the proposed withdrawal sites. The        potential project impacts. It does not address the    Quality Monitoring Program prior to
                                area directly upstream of the intake is most appropriate to monitor source         data required to design a drinking water treatment    construction and as required for other
                                water quality.                                                                     plant. A separate water quality monitoring program    authorizations.
        December                                                                                                   will be developed for this purpose.
        18, 2009                This is a multi MOE division issue; monitoring plans are to be submitted to
                                MOE-EPD/WSD for review and approval. Water Quality issues are raised by
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                                MOE-EPD, while source water protection are issues raised by MOE-WSD.

  270. August 30,   MOE - WSD   Grab samples collected in 1997 and 1998 cannot be used to establish a A water quality monitoring plan specific to the                     GAS commits to developing a Water
       2007                     current water quality baseline. Recent data is necessary to fully evaluate the requirements for an Operating Permit for the               Quality Monitoring Program prior to
                                risks to water supply.                                                         drinking water treatment and distribution will be          construction and as required for other
        December                                                                                               developed and implemented.      Additional water           authorizations.
        18, 2009                This is a multi MOE division issue; monitoring plans are to be submitted to quality sampling will also be done as part of the
                                MOE-EPD/WSD for review and approval. Water Quality issues are raised by assessment of the wastewater treatment plant.
                                MOE-EPD, while source water protection are issues raised by MOE-WSD.

  271. August 30,   MOE - WSD   There is no mention of water quality monitoring in relation to the domestic The baseline water quality monitoring program will ..
       2007                     license downstream on the Brohm River. It may be in the proponent’s best include a site appropriate for assessing current
                                interest to assess the quality of water before, during and after construction to water quality at the downstream water intake.
                                document any potential changes to water quality.

        December                This is a multi MOE division issue; monitoring plans are to be submitted to
        18, 2009                MOE-EPD/WSD for review and approval. Water Quality issues are raised by
                                MOE-EPD, while source water protection are issues raised by MOE-WSD.

  272. August 30,   MOE - WSD   Parameters such as pH, turbidity, total organic carbon, bacteria can be highly The monitoring program for the drinking water ..
       2007                     variable and event driven, thus monitoring is recommended to take place source will include monthly monitoring with weekly
                                under all event (low flow, storm flow and freshet) and seasonal conditions.    monitoring during freshet.

        December                This is a multi MOE division issue; monitoring plans are to be submitted to
        18, 2009                MOE-EPD/WSD for review and approval. Water Quality issues are raised by
                                MOE-EPD, while source water protection are issues raised by MOE-WSD.

  273. August 30,   MOE - WSD   The proponent should consider the monitoring approach used by the Province          Monitoring for the wastewater treatment plant ..
       2007                     to monitor for attainment of water quality objectives. The monitoring should        (baseline and post-operational) will include a series
                                takes place over a 5 week period at critical times when it has been determined      of 5 weekly samples collected during the annual low
                                that water quality may be at its worst. MOE -WSD's expectations are that any        flow period. The baseline water quality monitoring
                                monitoring program would include at a minimum monitoring for quantity and           program will include sites upstream and downstream
                                quality upstream of proposed intakes and upstream of existing downstream            of intakes and upstream of the existing downstream
                                water licenses before, during and after construction.                               domestic water intake.

        December                This is a multi MOE division issue; monitoring plans are to be submitted to
        18, 2009                MOE-EPD/WSD for review and approval. Water Quality issues are raised by
                                MOE-EPD, while source water protection are issues raised by MOE-WSD.

  274. August 30,   MOE - WSD   Volume 7 mentions the potential for the use of porous pavement in parking lots      Porous pavement is one LID technique mentioned in
       2007                     or conventional pavement with perimeter infiltration. The proponent must            Volume 7.       The detailed design studies will
                                provide additional information to support or confirm that the chosen option will    determine the appropriateness of this and other LID
                                not have an impact on ground water quality.                                         techniques for the project site.

        December                This is a multi MOE division issue; plans for runoff from parking areas are to be
        18, 2009                submitted to MOE-EPD/WSD for review and approval. Water Quality issues
                                are raised by MOE-EPD, while groundwater protection are issues raised by
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                             MOE-WSD.




  275. September   DFO       Some guidelines, reports and legislation related to streamside riparian           Widths of riparian protection areas in the base area       GAS commits to providing streamside
       28, 2007              protection areas referenced in Section 10.1 are outdated.            Widths of    development (including the golf course) will be            protection and enhancement areas for
                             streamside riparian protection areas for the resort base area, including golf     determined in accordance with the RAR or the               all   residential   and      commercial
                             courses, should be determined in accordance with the RAR. DFO would not           current legislation at the time of development.            developments as per the Fish
                             object to application of the setbacks proposed in the Riparian Management                                                                    Protection    Act-   Riparian    Areas
                                                                                                               With respect to S4 streams, based on fish presence,
                             Area Guidebook (1995) so long as there is close to full retention of vegetation                                                              Regulation,      Water      Act    and
                                                                                                               it is recommended that ski run development afford
                             within the management zones for S4, S5 and S6 classified streams.                                                                            Regulations or the current regulations
                                                                                                               the full retention of appropriate riparian setbacks
                                                                                                                                                                          at the time of construction. Should
                                                                                                               which could be negotiated to comply with the
                                                                                                                                                                          minor infringements to the Streamside
                                                                                                               requirements of the RAR; however, non-fish bearing
                                                                                                                                                                          Protection and Enhancement Areas be
                                                                                                               S5 and S6 streams may be a ubiquitous feature on
                                                                                                                                                                          unavoidable, GAS Inc. will comply
                                                                                                               the upper ski slopes.
                                                                                                                                                                          with DFO’s fisheries policy.
                                                                                                               Recommendations for BMP’s associated with S5               GAS commits to BMP’s for ski runs
                                                                                                               and S6 streams in the RMAG were developed with             development near S4, S5 and S6
                                                                                                               consideration given to their potential impact on           streams:
                                                                                                               timber supply. In similar ski resort development
                                                                                                               projects, adaptive BMP’s have been implemented to             •   define and protect (i.e. fencing)
                                                                                                               facilitate ski run development and address potential              machine free zones which will
                                                                                                               channel stability and water quality concerns:                     be established from edge of
                                                                                                                                                                                 stream channel bank;
                                                                                                                  •   Ensure falling and yarding is conducted away           •   fall vegetation away from
                                                                                                                      from, not across stream channels                           streams and where it is not
                                                                                                                  •   Limit machine access to a maximum of 10m                   possible to fall vegetation away
                                                                                                                      from top of bank or top to address bank                    from streams, the Riparian
                                                                                                                      stability concerns.                                        Vegetation          Management
                                                                                                                                                                                 Section will provide policy to
                                                                                                                  •   Prohibit grubbing within 10m of stream and
                                                                                                                                                                                 follow for these situations such
                                                                                                                      “close-cut” conifer stumps to retain bank
                                                                                                                                                                                 as vegetation will be removed
                                                                                                                      stabilizing root network
                                                                                                                                                                                 by hand immediately;
                                                                                                                  •   Retain understory deciduous trees, shrubs              •   require “flush-cutting” and full
                                                                                                                      and herbaceous vegetation within 10m of the                retention of coniferous and
                                                                                                                      channel to the fullest extent possible                     deciduous tree stumps to
                                                                                                                  •   Remove slash and debris that enters the                    maintain slope/bank stability
                                                                                                                      stream      while    retaining   all   existing            via root networks;
                                                                                                                      hydraulically active LWD features                      •   retain all hydraulically active
                                                                                                                  •   Retain wildlife trees.                                     large woody debris and coarse
                                                                                                                                                                                 woody debris in riparian
                                                                                                               GAS submitted an assessment of the linear impacts                 management zones;
                                                                                                               to fish habitat from construction of ski runs/lift lifts      •   maintain all ground cover and
                                                                                                               and golf course fairway crossings of watercourses in              shrub vegetation within defined
                                                                                                               February 2009 as part of the EAO Addendum 3                       riparian management zones;
                                                                                                               information requirements.      The results of the             •   implement appropriate erosion
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                                                                                                              analysis indicated that depending on which stream           and          sediment      control
                                                                                                              layer was used (TRIM or McElhanney) the potential           measures along margins of
                                                                                                              impacts from ski run/lift and golf course development       shrub layer buffer zone to
                                                                                                              ranged between 3.7-4.7% of the entire Brohm River           mitigate sediment transfers
                                                                                                              watershed or 1.7-2.8% of the combined Brohm                 upon completion of tree
                                                                                                              River, Cheekye River, Culliton Creek and Swift              removal and grubbing;
                                                                                                              Creek watershed sub-basins.                             •   stabilize and seed all disturbed
                                                                                                                                                                          surfaces within the riparian
                                                                                                                                                                          management zone immediately
                                                                                                                                                                          upon completion of summer
                                                                                                                                                                          ground grooming;
                                                                                                                                                                      •   restrict vegetation maintenance
                                                                                                                                                                          within shrub-layer buffer zone
                                                                                                                                                                          to that necessary for skier
                                                                                                                                                                          safety (i.e. early winter &
                                                                                                                                                                          spring conditions);
                                                                                                                                                                      •   vegetation topping to 2m in
                                                                                                                                                                          height will be conducted below
                                                                                                                                                                          lift lines; and
                                                                                                                                                                      •   no ski runs/lift lines will cross
                                                                                                                                                                          fish bearing streams.


  276. September   DFO       DFO requests additional and more detailed information on the location and        GAS assessed the effect of the golf course plans on GAS commits to providing streamside
       28, 2007              extent of impact on streamside vegetation for all proposed fairway-stream        riparian vegetation and provided this information toprotection and enhancement areas for
                             crossings be provided. DFO would like to clarify that it is our understanding    DFO in October 2008. GAS revised the golf course    all   residential   and      commercial
                             that streamside protection areas for golf course development should be           layout in January 2009 which resulted in no impacts developments as per the Fish
                             determined in accordance with the RAR.                                           to streams from development of golf course          Protection    Act-   Riparian    Areas
                                                                                                              fairways.                                           Regulation,      Water      Act    and
                                                                                                                                                                  Regulations or the current regulations
                                                                                                              GAS provided an assessment report of the potential at the time of construction. Should
                                                                                                              impacts of ski run/lift and golf course development minor infringements to the Streamside
                                                                                                              within the Garibaldi resort boundaries in Addendum Protection and Enhancement Areas be
                                                                                                              3 documents.                                        unavoidable, GAS Inc. will comply
                                                                                                                                                                  with DFO’s fisheries policy.

  277. September   DFO       DFO would like confirmation from Garibaldi at Squamish Inc. that there will be   Cart paths may cross a small number of fish-bearing GAS commits to design the golf
       28, 2007              no golf cart path crossings of any fish-bearing watercourses, golf cart path     watercourses. The final design of cart paths will courses based on the following
                             crossings of watercourses that are not frequented by fish will be avoided as     avoid watercourse crossings as much as possible criteria:
                             much as possible, channel-spanning bridges shall be used where golf cart path    and use channel spanning bridges where crossings • Cart paths to avoid watercourse
                             crossings of watercourses are unavoidable, and that golf cart path crossings     of fish-bearing and non-fish-bearing streams are      crossings as much as possible.
                             will be located outside of riparian setback areas.                               unavoidable. Cart paths will be located outside
                                                                                                              riparian setback areas except at watercourse • Channel spanning bridges to be
                                                                                                              crossings (if any).      Crossings will be set        used where crossings of fish-
                                                                                                              perpendicular to the streams to minimize              bearing     and    non-fish-bearing
                                                                                                              encroachment of the paths into the riparian area.     streams are unavoidable.
                                                                                                                                                                  • Cart paths running parallel to
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                                                                                                                                                                               streams will be located outside
                                                                                                                                                                               riparian setback areas except at
                                                                                                                                                                               watercourse crossings.

  278. September   DFO         DFO does not agree with the opinion stated in Section 3.7 (Fish Habitat) of the The sentence quoted referred to the amount of fish
       28, 2007                report which states “the habitat available to salmonids in the immediate project habitat relative to the entire project area. The same
                               vicinity is relatively limited.”                                                 paragraph continued, “…the lower reaches of Brohm
                                                                                                                River offer significant spawning and rearing habitat,
                                                                                                                with previous studies indicating that Brohm itself is
                                                                                                                an extremely important contributor to the Squamish
                                                                                                                watershed’s       juvenile    steelhead     population,
                                                                                                                contributing approximately 27% of total juvenile
                                                                                                                steelhead biomass.”

  279. September   DFO         DFO recommends that streamside protection areas should be separated from GAS agrees to fencing of streamside protection GAS commits to fence “Streamside
       28, 2007                golf course areas by fencing in order to adequately discourage disturbance of areas within the golf course.             Protection Areas” within the golf
                               these areas.                                                                                                            course.

  280. September   DFO         DFO requests additional and more detailed information on the location and The base area development layout presented in the                   GAS commits to providing streamside
       28, 2007                extent of impact on watercourses and streamside vegetation for all proposed Draft Master Plan is conceptual. The design will be               protection and enhancement areas for
                               encroachments due to residential or commercial developments be provided.    adjusted as necessary based on RAR setback                        all   residential   and      commercial
                                                                                                           requirements. GAS will provide information on                     developments as per the Fish
                                                                                                           setback determination and resulting project design                Protection    Act-   Riparian    Areas
                                                                                                           to DFO at the detailed design stage.                              Regulation,      Water      Act    and
                                                                                                                                                                             Regulations or the current regulations
                                                                                                                                                                             at the time of construction. Should
                                                                                                                                                                             minor infringements to the Streamside
                                                                                                                                                                             Protection and Enhancement Areas be
                                                                                                                                                                             unavoidable, GAS Inc. will comply
                                                                                                                                                                             with DFO’s fisheries policy.

  281. February    MOE - ESD   MOE Ecosystems review of the riparian habitat impacts in the “Preliminary              The assessment methodology for assessing riparian GAS Inc. has also committed to
       26, 2009                Stream Crossing Impact Analysis of Garibaldi at Squamish Resort Project Ski            impacts from the ski area development was provide streamside protection and
                               Runs/Lifts and Golf Course Fairways” noted the following:                              recommended by Fisheries and Oceans Canada.              enhancement areas for all residential
                                   • This report is an excellent accounting of the number and linear                                                                           and commercial developments as per
                                                                                                                      GAS Inc. has also committed to the following “Best
                                     proportion of stream crossings associated with the ski runs, lifts and                                                                    the Fish Protection Act- Riparian
                                                                                                                      Management Practices” to facilitate safe skier
                                     golf course development. However, without areal measurements and                                                                          Areas Regulation, Water Act and
                                                                                                                      passage and mitigate impacts to the “features
                                     good documentation of the activities anticipated within the riparian area                                                                 Regulations or the current regulations
                                                                                                                      functions and conditions” afforded by riparian
                                     it is still difficult to understand the impacts to riparian habitat associated                                                            at the time of construction. Should
                                                                                                                      vegetation which will limit impacts to stream bed and
                                     with stream crossings.                                                                                                                    infringements to the Streamside
                                                                                                                      bank stability and aquatic resource values
                                                                                                                                                                               Protection and Enhancement Areas be
                                  •   The report states that the impacts involved with the ski runs would be             • define and protect (i.e. fencing) machine free unavoidable, GAS Inc. will comply with
                                      selective vegetation removal. The stream in Photograph 1, as an                         zones which will be established from edge of DFO’s fisheries policy.
                                      illustration of the riparian buffers that would be applied under the                    stream channel bank;
                                      suggested riparian management zone concept, appears to be                          • fall vegetation away from streams and where
                                      completely free of overstory canopy cover – apparently all of the trees                 it is not possible to fall vegetation away from
                                      were selected for removal.                                                              streams,       the      Riparian      Vegetation
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                       BY
                                •   Streamside protection areas should be derived from the Fish Protection          Management Section will provide policy to
                                    Act, RAR. The Forest and Range Practices Act, Forest Planning and               follow for these situations such as vegetation
                                    Practices Regulation does not apply ecologically as this project is a           will be removed by hand immediately;
                                    much more permanent footprint development than forest practices.            •   require “flush-cutting” and full retention of
                                                                                                                    coniferous and deciduous tree stumps to
                                •   30 metres is a minimum setback for amphibian best management, is                maintain slope/bank stability via root
                                    well short of Pacific Water Shrew best management buffers, and it is            networks;
                                    also the resulting setback from a RAR Simple Assessment for a non-          •   retain all hydraulically active large woody
                                    fish bearing stream with no buildings in the assessment area. MOE               debris and coarse woody debris in riparian
                                    suggests that GIS analysis of the riparian impacts of development               management zones;
                                    measure the areal footprint to at least 30 metres of streams. It would      •   maintain all ground cover and shrub
                                    also be informative to overlay habitat suitability maps onto such an            vegetation       within     defined      riparian
                                    areal analysis to understand more species specific impacts.                     management zones;
                                                                                                                •   implement appropriate erosion and sediment
                                                                                                                    control measures along margins of shrub
                                                                                                                    layer buffer zone to mitigate sediment
                                                                                                                    transfers upon completion of tree removal
                                                                                                                    and grubbing;
                                                                                                                •   stabilize and seed all disturbed surfaces
                                                                                                                    within the riparian management zone
                                                                                                                    immediately upon completion of summer
                                                                                                                    ground grooming;
                                                                                                                •   restrict vegetation maintenance within shrub-
                                                                                                                    layer buffer zone to that necessary for skier
                                                                                                                    safety (i.e. early winter & spring conditions);
                                                                                                                •   vegetation topping to 2m in height will be
                                                                                                                    conducted below lift lines; and
                                                                                                                •   no ski runs/lift lines will cross fish bearing
                                                                                                                    streams.


  282. September   DFO       In order to adequately mitigate hydrologic effects due to impervious surfaces   GAS’s original stormwater management planning
                                                                                                                                                                        . GAS commits to developing and
       28, 2007              on fish habitat, project components must be designed and constructed in         (April 2003) indicated that future systems would
                                                                                                                                                                        implementing a sediment and erosion
                             accordance with an integrated stormwater management strategy that sets          comply with the Stormwater Guidebook for the
                                                                                                                                                                        control plan prior to construction to
                             appropriate quantitative goals for infiltration of most of the volume of        Province of British Columbia. GAS provided an
                                                                                                                                                                        address sediment and erosion issues
                             frequently-occurring rainfall events as well as detention and release of peak   addendum stormwater report (McElhanney October
                                                                                                                                                                        during construction of all road, base
                             rainfall events.                                                                2008: revised January 2009) that outlined global
                                                                                                                                                                        and ski/lift areas.    GAS Inc. also
                                                                                                             performance targets and the water balance
                                                                                                                                                                        commits to have the final sediment
                                                                                                             modeling process, as per the new approach
                                                                                                                                                                        and erosion control plan reviewed by a
                                                                                                             described as “Beyond the Guidebook.” This report
                                                                                                                                                                        Certified Professional in Erosion and
                                                                                                             was submitted to the EAO in February 2009 as part
                                                                                                                                                                        Sediment Control (CPESC) prior to
                                                                                                             of the Addendum 3 documents.
                                                                                                                                                                        construction. GAS Inc. will continue to
                                                                                                                                                                        consult with the CPESC during
                                                                                                                                                                        construction to review if adaptive
                                                                                                                                                                        management measures need to be
                                                                                                                                                                        incorporated into the plan to ensure
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                       BY
                                                                                                                                                                            the plan successfully manages
                                                                                                                                                                            sediment and erosion control.

  283. September   DFO       DFO is not confident that the stream flow assessment method provides                  In August/September 2007, GAS initiated surface          GAS commits to additional modeling
       28, 2007              adequate certainty that fish habitat will not be adversely affected by the            flow monitoring at the two proposed water                of water supply/demand to be used to
                             proposed water withdrawal and recommends that current assessment methods              withdrawal diversion points and at the upper and         further assess potential impacts to fish
                             be followed to assess impacts. DFO also recommends that a minimum of one              lower limits of fish in Lower Brohm River                habitat.
                             year of continuous flow data (preferably more) be collected to support this
                                                                                                                   GAS presented the one year stream flow data to
                             assessment.
                                                                                                                   MOE and DFO in November 2008. The flow data
                                                                                                                   collected by Northwest Hydraulics and the 20-year
                                                                                                                   modeling results from Urban Systems were provided
                                                                                                                   to the EAO in draft in February 2009 as part of the
                                                                                                                   Addendum 3 and the final Northwest Hydralics and
                                                                                                                   the interim (May 2009) Urban Systems report to
                                                                                                                   EAO in June 2009. This analysis demonstrated that
                                                                                                                   water supply was adequate and withdrawals would
                                                                                                                   not negatively affect fish habitat. It indicates that
                                                                                                                   there is sufficient water to provide total potable and
                                                                                                                   snowmaking demand at full build out and still
                                                                                                                   provide more than sufficient flows to protect fish
                                                                                                                   populations according to the BC Instream Flow
                                                                                                                   Guidelines requirements.

  284. September   DFO       The guidelines for stormwater management (Land Development Guidelines                 GAS’s original stormwater management planning            GAS commits to developing and
       28, 2007              1992) referenced in section 22.0 (Stormwater Management) are out of date              (April 2003) indicated that future systems would         implementing a sediment and erosion
                             and are generally do not adequately mitigate the impact of impervious areas           comply with the Stormwater Guidebook for the             control plan prior to construction to
                             on fish habitat and water quality. A stormwater management plan should be             Province of British Columbia. GAS provided an            address sediment and erosion issues
                             developed for the proposed project that sets appropriate quantitative criteria for    addendum stormwater report (McElhanney October           during construction of all road, base
                             volume reduction, water quality and rate control (detention) based on current         2008: revised January 2009) that outlined global         and ski/lift areas. GAS also commits
                             guidelines for protection of fish and fish habitat. This strategy should illustrate   performance targets and the water balance                to have the final sediment and erosion
                             how these criteria will be achieved and the types of best management                  modeling process, as per the new approach                control plan reviewed by a Certified
                             practices that will be used. DFO recommends that low impact development               described as “Beyond the Guidebook.” This report         Professional in Erosion and Sediment
                             (LID) strategies and best management practices that infiltrate runoff from            was submitted to the EAO in February 2009 as part        Control (CPESC) prior to construction.
                             frequently occurring precipitation events are applied for all impervious surfaces     of the Addendum 3                                        GAS will continue to consult with the
                             created by the project.                                                                                                                        CPESC during construction to review
                                                                                                                                                                            if adaptive management measures
                                                                                                                                                                            need to be incorporated into the plan
                                                                                                                                                                            to ensure the plan successfully
                                                                                                                                                                            manages sediment and erosion
                                                                                                                                                                            control.



  285. September   DFO       The proposed development would occupy and alter a large area within the               WLAP (2002) provides a guideline of limiting             GAS commits to providing streamside
       28, 2007              Brohm River watershed. The potential effects of project changes on watershed          impervious area to less than 10% of total watershed      protection and enhancement areas for
                             processes should be assessed to determine whether any cumulative adverse              area. The base area development will create an           all   residential  and  commercial
                             effects on the fish and fish habitat in the Brohm River are likely to occur. This     impervious area equal to 5.9% of the total Brohm         developments as per the Fish
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                      BY
                            assessment should consider the riparian integrity of the watershed, total          River watershed area (Volume 7, Table 8-3 on page   Protection    Act-   Riparian   Areas
                            impervious area, road density, number of stream crossings and forest cover in      8-5). The Sea-to-Sky Highway widening will not      Regulation,     Water       Act    and
                            the Brohm River watershed and should consider the existing condition,              increase watershed imperviousness above the 10%     Regulations or the current regulations
                            changes due to the project and any future projects or activities that are          threshold.                                          at the time of construction. Should
                            expected to occur.                                                                                                                     minor infringements to the Streamside
                                                                                                               Riparian integrity within the resort/golf course
                                                                                                                                                                   Protection and Enhancement Areas be
                                                                                                               development areas will be maintained by adhering to
                                                                                                                                                                   unavoidable, GAS Inc. will comply
                                                                                                               riparian setbacks dictated in the RAR.
                                                                                                                                                                   with DFO’s fisheries policy.
                                                                                                               GAS provided an assessment report of the potential
                                                                                                               impacts of ski run/lift and golf course development
                                                                                                               within the Garibaldi resort boundaries (dated
                                                                                                               October 2008: revised January 2009) which was
                                                                                                               submitted to the EAO in February 2009 as part of
                                                                                                               the information requirements for Addendum 3
                                                                                                               documents.

  286. November   DFO       DFO does not agree with GAS's response to our comment and proposed                 With respect to S4 streams, based on fish presence,       GAS      commits       to    providing
       27, 2007             action for setbacks for watercourses in the ski area. As stated in our original    it is recommended that ski run development afford       streamside        protection        and
                            comment DFO supports the use of the management zones for small fish                the full retention of appropriate riparian setbacks     enhancement areas for all residential
                            streams or fishless streams (S4, S5 and S6) described in the Riparian              which could be negotiated to comply with the            and commercial developments as per
                            Management Area Guidebook but only if there is close to full retention of all      requirements of the RAR; however, non-fish bearing      the Fish Protection Act- Riparian
                            vegetation within the management zones for these streams. If GAS feels that        S5 and S6 streams may be a ubiquitous feature on        Areas Regulation, Water Act and
                            full retention of all vegetation in the management zones of these streams is not   the upper ski slopes.                                   Regulations or the current regulations
                            possible then DFO would need to see more detailed information showing the                                                                  at the time of construction. Should
                                                                                                               GAS will continue to reduce potential riparian habitat
                            locations, areas and proposed treatment where GAS proposes to remove                                                                       minor infringements to the Streamside
                                                                                                               impacts through the detailed design phase.
                            vegetation from the management zone.                                                                                                       Protection and Enhancement Areas be
                                                                                                                                                                       unavoidable, GAS Inc. will comply
                                                                                                               Recommendations for BMP’s associated with S5 with DFO’s fisheries policy.
                                                                                                               and S6 streams in the RMAG were developed with
                                                                                                               consideration given to their potential impact on GAS commits to BMP’s for ski runs
                                                                                                               timber supply                                           development near S4, S5 and S6
                                                                                                               GAS has further discussed this issue with DFO in streams, such as:
                                                                                                               June/July of 2008 and agreed to assess the linear           • define and protect (i.e. fencing)
                                                                                                               impacts of the ski trails/lifts and golf course fairway        machine free zones which will
                                                                                                               stream crossings for review by DFO to determine                be established from edge of
                                                                                                               the significance of the impacts and whether further            stream channel bank;
                                                                                                               mitigation/compensation        is  required.        The     • fall vegetation away from
                                                                                                               preliminary report was presented to the working                streams and where it is not
                                                                                                               group members in November 2008 and a revised                   possible to fall vegetation away
                                                                                                               report was submitted to the EAO in February 2009               from streams, the Riparian
                                                                                                               as part of the Addendum 3 information                          Vegetation           Management
                                                                                                               requirements.                                                  Section will provide policy to
                                                                                                               GAS prepared an assessment of the linear impacts                follow for these situations such
                                                                                                               to fish habitat from construction of ski runs/lift lifts        as vegetation will be removed
                                                                                                               crossings of watercourses in February 2009 as part              by hand immediately;
                                                                                                               of the EAO Addendum 3 information requirements.             •   require “flush-cutting” and full
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                      BY
                                                                                                               The results of the analysis indicated that depending             retention of coniferous and
                                                                                                               on which stream layer was used (TRIM or                          deciduous tree stumps to
                                                                                                               McElhanney) the potential impacts from ski run/lift              maintain slope/bank stability
                                                                                                               development ranged between 3.7-4.7% of the entire                via root networks;
                                                                                                               Brohm River watershed and 1.7-2.8% of the                    •   retain all hydraulically active
                                                                                                               combined Brohm River, Cheekye River, Culliton                    large woody debris and coarse
                                                                                                               Creek and Swift Creek watershed sub-basins.                      woody debris in riparian
                                                                                                                                                                                management zones;
                                                                                                                                                                            •   maintain all ground cover and
                                                                                                                                                                                shrub vegetation within defined
                                                                                                                                                                                riparian management zones;
                                                                                                                                                                            •   implement appropriate erosion
                                                                                                                                                                                and          sediment      control
                                                                                                                                                                                measures along margins of
                                                                                                                                                                                shrub layer buffer zone to
                                                                                                                                                                                mitigate sediment transfers
                                                                                                                                                                                upon completion of tree
                                                                                                                                                                                removal and grubbing;
                                                                                                                                                                            •   stabilize and seed all disturbed
                                                                                                                                                                                surfaces within the riparian
                                                                                                                                                                                management zone immediately
                                                                                                                                                                                upon completion of summer
                                                                                                                                                                                ground grooming;
                                                                                                                                                                            •   restrict vegetation maintenance
                                                                                                                                                                                within shrub-layer buffer zone
                                                                                                                                                                                to that necessary for skier
                                                                                                                                                                                safety (i.e. early winter &
                                                                                                                                                                                spring conditions);
                                                                                                                                                                            •   vegetation topping to 2m in
                                                                                                                                                                                height will be conducted below
                                                                                                                                                                                lift lines; and
                                                                                                                                                                            •   no ski runs/lift lines will cross
                                                                                                                                                                                fish bearing streams
                                                                                                                                                                            •

  287. November   DFO       Based on the Application, DFO understood that there would be no more than a        Fairway crossings of fish-bearing watercourses will       GAS commits to providing streamside
       27, 2007             total of two fairway crossings of streams required for the golf course; however,   be avoided and channel-spanning bridges will be           protection and enhancement areas for
                            GAS's response and proposed action indicates that they propose up to two           used where golf cart path crossings of these              all   residential   and     commercial
                            fairway crossings for any stream (i.e. potentially more than a total of two        watercourses are unavoidable.                             developments as per the Fish
                            stream crossings). As per our original comment, DFO will need to see more                                                                    Protection    Act-   Riparian   Areas
                                                                                                               GAS has further discussed this issue with DFO in
                            detailed information on the location and extent of impact on streamside                                                                      Regulation,      Water      Act    and
                                                                                                               June/July of 2008 and agreed to assess the linear
                            vegetation for every fairway-stream crossing proposed by GAS in order to                                                                     Regulations or the current regulations
                                                                                                               impacts of the ski trails/lifts and golf course fairway
                            determine whether these will require authorization under s.35(2) of the                                                                      at the time of construction. Should
                                                                                                               stream crossings for review by DFO to determine
                            Fisheries Act, whether DFO will be required to conduct an environmental                                                                      minor infringements to the Streamside
                                                                                                               the significance of the impacts and whether further
                            assessment under CEAA, and to determine the significance of any residual                                                                     Protection and Enhancement Areas be
                                                                                                               mitigation/compensation is required.
                            effects.                                                                                                                                     unavoidable, GAS Inc. will comply
                                                                                                               GAS prepared an assessment of the linear impacts          with DFO’s fisheries policy..
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                      BY
                            If GAS cannot confirm that there will be no golf cart path crossings of streams    to fish habitat from construction of ski runs/lift lifts
                            or encroachments into vegetated streamside areas then DFO will need                and golf course fairway crossings of watercourses in
                            information on the number, location, and extent of impact on streamside            February 2009 as part of the EAO Addendum 3
                            vegetation for all stream crossings or streamside area encroachments               information requirements.      The results of the
                            proposed by GAS in order to determine whether these will require authorization     analysis indicated that depending on which stream
                            under s.35(2) of the Fisheries Act, whether DFO will be required to conduct an     layer was used (TRIM or McElhanney) the potential
                            environmental assessment under CEAA, and to determine the significance of          impacts from ski run/lift development ranged
                            any residual effects.                                                              between 3.7-4.7% of the entire Brohm River
                                                                                                               watershed and 1.7-2.8% of the combined Brohm
                                                                                                               River, Cheekye River, Culliton Creek and Swift
                                                                                                               Creek watershed sub-basins. There were no
                                                                                                               impacts from golf course fairways associated
                                                                                                               with the revised golf course layout dated
                                                                                                               January 2009.

  288. November   DFO       As per our original comment, DFO will need to see more detailed information        GAS will provide streamside protection and                 GAS commits to providing streamside
       27, 2007             on the location and extent of impact on streamside vegetation for every            enhancement areas for all residential and                  protection and enhancement areas for
                            encroachment due to residential/commercial development proposed by GAS in          commercial developments as per the Fish Protection         all   residential   and      commercial
                            order to determine whether these will require authorization under s.35(2) of the   Act-RAR or the current regulations at the time of          developments as per the Fish
                            Fisheries Act, whether DFO will be required to conduct an environmental            construction.      Should infringements to the             Protection    Act-   Riparian    Areas
                            assessment under CEAA, and to determine the significance of any residual           Streamside Protection and Enhancement Areas be             Regulation,      Water      Act    and
                            effects.                                                                           required during the detailed design, GAS will comply       Regulations or the current regulations
                                                                                                               with DFO policy direction for hierarchy of                 at the time of construction. Should
                                                                                                               preferences and no-net-loss of fisheries habitat (see      minor infringements to the Streamside
                                                                                                               Table of Commitments and Assurances).                      Protection and Enhancement Areas be
                                                                                                                                                                          unavoidable, GAS Inc. will comply
                                                                                                                                                                          with DFO’s fisheries policy.

  289. November   DFO       DFO does not agree that GAS's response and proposed action will address            GAS’s original stormwater management planning               GAS commits to developing and
       27, 2007             DFO’s concern regarding stormwater runoff. GAS makes a commitment to               (April 2003) indicated that future systems would           implementing a sediment and erosion
                            maintaining baseflows but without explaining how this will be achieved. A          comply with the Stormwater Guidebook for the               control plan prior to construction to
                            stormwater mitigation strategy should be developed that sets quantitative          Province of British Columbia. GAS provided an              address sediment and erosion issues
                            performance objectives for proposed infrastructure (buildings, roads, parking      addendum stormwater report (McElhanney October             during construction of all road, base
                            lots and other impervious areas) that address volume, rate and quality of runoff   2008: revised January 2009) that outlined global           and ski/lift areas. GAS also commits
                            as well as maintaining baseflows. This strategy should provide adequate            performance targets and the water balance                  to have the final sediment and erosion
                            assurance that its performance objectives can be achieved and the adverse          modeling process, as per the new approach                  control plan reviewed by a Certified
                            effects of stormwater runoff can be adequately mitigated to ensure there will be   described as “Beyond the Guidebook.” This report           Professional in Erosion and Sediment
                            no significant adverse effects on fish and the aquatic environment due to the      was submitted to the EAO in February 2009 as part          Control (CPESC) prior to construction.
                            proposed project.                                                                  of the Addendum 3 documents.                               GAS will continue to consult with the
                                                                                                                                                                          CPESC during construction to review
                                                                                                                                                                          if adaptive management measures
                                                                                                                                                                          need to be incorporated into the plan
                                                                                                                                                                          to ensure the plan successfully
                                                                                                                                                                          manages sediment and erosion
                                                                                                                                                                          control.

  290. November   DFO       The response and proposed action by GAS does not address DFO's comment GAS will undertake a watershed assessment at the GAS commits to conduct a watershed
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  #                  RAISED                                                                                                                                                            COMMITMENTS
                        BY
        27, 2007                which was that a watershed assessment be conducted to assess the effects of          detail design phase, to assess the effects of the assessment   on    Brohm      River
                                the project in conjunction with existing (baseline) conditions and future            Project in conjunction with existing (baseline) watershed, during the detailed design
                                anticipated projects in the Brohm Creek watershed in order to provide some           conditions and future anticipated projects in the phase.
                                assurance that the project is not likely to lead to adverse environmental effects    Brohm River watershed in conjunction with
                                on fish and the aquatic environment through many small effects due to the            development and implementation of the stormwater
                                project (e.g. construction of roads and stream crossings, riparian removal,          management plan, the water quality monitoring
                                creation of impervious areas, etc.).                                                 program and the environmental management
                                                                                                                     program (incorporating BMPs and LID guidelines
                                                                                                                     where appropriate) to identify, avoid or mitigate
                                                                                                                     effects due to the Project (e.g. construction of roads
                                                                                                                     and stream crossings, riparian removal, creation of
                                                                                                                     impervious areas, etc.)

  291. November     DFO         GAS has suggested that stormwater detention facilities will contribute to            This was an editing error. Infiltration is intended to
       27, 2007                 maintaining baseflows in Brohm Creek and its tributaries. DFO would like to          maintain baseflows. Detention (along with other
                                clarify that conventional detention facilities are designed to mitigate peak flows   methods) is intended to control peak flows. Both
                                and the runoff water is not detained for a long enough period of time to make a      infiltration and detention will contribute to
                                significant contribution to baseflows.                                               contaminant removal.

  292. November     MOE - EPD   The update on Water Quality Cumulative Effects Assessment should not be              GAS commits to conduct a watershed assessment GAS commits to conduct a watershed
       29, 2007                 restricted to one parameter such as TSS/turbidity, and should also not be            at the detail design phase, to assess the effects of assessment    on    Brohm      River
                                restricted to cumulative effects of the same parameter/impact from different         the project in conjunction with existing (baseline) watershed, during the detailed design
                                sources. It should also consider the cumulative effects of multiple stressors        conditions and future anticipated projects in the phase.
                                from the same or multiple sources.                                                   Brohm River watershed, and to development and
                                                                                                                     implementation of a stormwater management plan
                                                                                                                     and a water quality monitoring program to monitor
                                                                                                                     and mitigate cumulative and multiple stressors on
                                                                                                                     water quality.

  293. November     MOE - EPD   Section 13 Air Quality is not noted in the text but is outlined in Table 1 Air quality mitigation during construction will include            GAS commits to develop a Vegetation
       29, 2007                 Commitments and Assurances. MOE comments are as follows:                     use of wheel washes and an anti-idling policy for                Debris Management Plan prior to
                                                                                                             construction vehicles.                                           construction addressing issues such
                                • The option of chipping wood/vegetative waste is not even considered.
                                                                                                                                                                              as                chipping/compositing
                                • The Open Burning Smoke Control Regulation is not even mentioned.           At the time the application was submitted no natural
                                                                                                                                                                              wood/vegetative waste and beneficial
                                                                                                             gas line was available to serve the project.
                                • Monitoring during burning activities is not noted.                                                                                          use as fish/wildlife habitat and, GAS
                                                                                                             However, GAS will contact Terasen to discuss the
                                • Wheel washes are not mentioned.                                                                                                             will comply with the Open Burning
                                                                                                             possibility of natural gas service for the resort.
                                • Our legislation is the Environmental Management Act (EMA), not Waste                                                                        Smoke Control Regulation and
                                                                                                             The reference to the WMA in the Table of                         monitor air quality during burning, if
                                Management Act (WMA).
                                                                                                             Commitments and Assurances has been changed to                   burning is undertaken.
                                • Is the option of natural gas for fireplaces available? If so, has it been the EMA.
                                  considered?                                                                                                                                 GAS commits to implement a “no-
                                • An anti-idling policy should be implemented during the construction phase,                                                                  idling” policy for construction vehicles.
                                  not just the operational phase.

  294. August 19,   DFO         Section 2.2 Riparian Habitat Impacts                                            The residential and commercial development areas GAS commits to providing streamside
       2008                     DFO is concerned that insufficient information was available to assess riparian will follow the Fish Protection Act RAR, or the protection and enhancement areas for
                                impacts, not just from the ski area and golf courses but from any component of current legislation at the time of construction. The all residential and  commercial
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                              the project (i.e. including residential development, roads, commercial RAR is designed to provide local governments with                        developments as per the Fish
                              development or other infrastructure).                                              adequate support, direction and assurance that, with         Protection    Act-   Riparian   Areas
                                                                                                                 the exercise of due diligence, protection of riparian        Regulation,     Water       Act    and
                              DFO has further indicated to GAS that it does not support GAS following the fish habitat will be achieved.                                      Regulations or the current regulations
                              Ministry of Forests Riparian Management Guidebook (December                                                                                     at the time of construction. Should
                                                                                                                 GAS prepared an assessment of the linear impacts
                              1995).According to the guidebook, GAS could remove all riparian vegetation                                                                      minor infringements to the Streamside
                                                                                                                 to fish habitat from construction of ski runs/lift lifts
                              from all fish-less streams and all small (<1.5m wide) fish-bearing streams.                                                                     Protection and Enhancement Areas be
                                                                                                                 and golf course fairway crossings of watercourses in
                              DFO understands that this is not GAS’s intention but in order to find out what                                                                  unavoidable, GAS Inc. will comply
                                                                                                                 February 2009 as part of the EAO Addendum 3
                              the potential impact could be DFO requests GAS to quantify where and how                                                                        with DFO’s fisheries policy.
                                                                                                                 information requirements.       The results of the
                              much riparian GAS anticipates would need to be removed. Also, the
                                                                                                                 analysis indicated that depending on which stream
                              referenced guidelines are intended for forest harvesting activities where it is
                                                                                                                 layer was used (TRIM or McElhanney) the potential
                              expected that the riparian trees will regrow – this is not the case for a
                                                                                                                 impacts from ski run/lift development ranged
                              residential/commercial/golf course/ski hill development.
                                                                                                                 between 3.7-4.7% of the entire Brohm River
                              As noted above, in order to answer the question of whether too much riparian watershed and 1.7-2.8% of the combined Brohm
                              impacts are expected, GAS would need to consider all anticipated riparian River, Cheekye River, Culliton Creek and Swift
                              impacts (i.e. including those from road crossings, residential development, Creek watershed sub-basins.                There were no
                              commercial development or other infrastructure.                                    impacts from golf course fairways associated with
                                                                                                                 the revised golf course layout dated January 2009.
                              DFO agrees with the proposed method of determining the linear impacts to
                              riparian vegetation by doing a sub-basin watershed assessment based on ski As noted above, GAS is recommending that the
                              trail and golf course fairway stream crossings.                                    Fish-Stream Crossing Guidebook (March 2002) be
                                                                                                                 used for road and ski trail crossings of fishless
                              DFO would assess the level of impact and determine if the potential riparian
                                                                                                                 streams and the DFO Operational Statement for
                              impacts created a HADD and would require a Section 35(2) Authorization or
                                                                                                                 Small Clear Span Bridges be used for all road
                              potential to result in cumulative impacts. If a Section 35(2) Authorization is not
                                                                                                                 crossings of fish streams. Water Act notifications
                              required, no further information on riparian impacts is required by DFO during
                                                                                                                 would be submitted to the province/federal
                              the EA review process. If a Section 35(2) Authorization was deemed
                                                                                                                 governments for all crossings for review and
                              necessary for some sub-basin riparian impacts, GAS would need to provide
                                                                                                                 approval. This approach is consistent with other
                              conceptual habitat compensation to mitigate the impacts for review and
                                                                                                                 recent recreation development projects.
                              approval by DFO prior to the completion of the EA review process.
                              During the detailed design phase and prior to construction, GAS would provide
                              prescriptions for all stream crossings if necessary (i.e. if there is a HADD of fish
                              habitat) and detailed design drawings of the proposed habitat compensation
                              for review and approval by DFO.

  295. August 19,   DFO       Section 2.2 Riparian Habitat Impacts                                                   Due to the importance of the lower Brohm River to        GAS commits to follow the Fish-
       2008                   It should be noted that these guidelines (Fish-Stream Crossing Guidebook               anadromous and resident fish populations, GAS Inc.       Stream Crossing Guidebook (March
                              (March 2002)) are intended for forestry, mining and petroleum resource roads           is committed to construct bridges for all crossings of   2002) and apply DFO’s Operational
                              (i.e. generally narrow and temporary roads) and following these guidelines             fish bearing streams and will follow the DFO’s           Statements for Small Clear Span
                              does not necessarily avoid HADD of fish habitat (and CEAA requirements).               Operational Statement for Small Clear Span               Bridges for all road crossings of
                              DFO Fisheries and Oceans “Pacific Region Operational Statement for Small               Bridges.                                                 streams.
                              Clear Span Bridges” (March 2007). is the better guidance for the road
                              crossings that GAS is proposing.                                                       The Fish-Stream Crossing Guidebook (March 2002)
                                                                                                                     was utilized for all (80+) of the road and cross
                                                                                                                     country ski trail (6-8m widths) stream crossings (fish
                                                                                                                     and fishless streams) at the Whistler Nordic Centre
                                                                                                                     in Callaghan Valley. Both the roads and ski trails
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                                                                                                           are hard surfaced, permanent crossings. GAS
                                                                                                           would assume that the guidebook would be applied
                                                                                                           to stream crossings of fish and fishless streams for
                                                                                                           the Garibaldi project in a similar fashion as the
                                                                                                           Whistler Nordic Centre.

                                                                                                           Regarding the ski trail/lift crossings of fishless
                                                                                                           streams, ENKON’s recent experience at Mount
                                                                                                           Mackenzie in Revelstoke resulted in Water Act
                                                                                                           notifications submitted for each crossing. While fish
                                                                                                           habitat compensation was not required, best
                                                                                                           management practices were used to minimize
                                                                                                           vegetation impacts and retain channel and bank
                                                                                                           stability. For consistency with other ski resort
                                                                                                           developments, a similar approach should be used at
                                                                                                           Garibaldi resort for ski trail stream crossings

  296. August 19,   DFO       Section 3.2 Environmental Protection Plans                                   GAS provided an addendum stormwater report
                                                                                                                                                                    GAS commits to developing and
       2008                                                                                                (McElhanney October 2008: revised January 2009)
                              GAS’s proposed planning process needs to establish targets prior to                                                                   implementing a sediment and erosion
                                                                                                           that outlined global performance targets and the
                              completion of the EA process that would be implemented during the detailed                                                            control plan prior to construction to
                                                                                                           water balance modeling process, as per the new
                              design process. Targets will include matching post-development conditions                                                             address sediment and erosion issues
                                                                                                           approach described as “Beyond the Guidebook.”
                              with:                                                                                                                                 during construction of all road, base
                                                                                                           This report was submitted to the EAO in February
                                    • Predevelopment flow rates,                                                                                                    and ski/lift areas. GAS also commits
                                                                                                           2009 as part of the Addendum 3 documents.
                                                                                                                                                                    to have the final sediment and erosion
                                    • Predevelopment flow volumes,                                                                                                  control plan reviewed by a Certified
                                    • Predevelopment flow duration,                                        The updated stormwater report is intended to
                                                                                                                                                                    Professional in Erosion and Sediment
                                                                                                           provide a “road map” of the approvals process and
                                    • Predevelopment stream erosion potential; and                                                                                  Control (CPESC) prior to construction.
                                                                                                           the requirements at each milestone along the way.
                                                                                                                                                                    GAS will continue to consult with the
                                    • Predevelopment Water Quality.                                        Collection of the baseline data, preparation of the
                                                                                                                                                                    CPESC during construction to review
                                                                                                           detailed hydrologic model, incorporation of mitigation
                                                                                                                                                                    if adaptive management measures
                                                                                                           measures and LID’s would occur during further
                                                                                                                                                                    need to be incorporated into the plan
                                                                                                           planning and the detailed design phase of the
                                                                                                                                                                    to ensure the plan successfully
                                                                                                           project post EA process.
                                                                                                                                                                    manages sediment and erosion
                                                                                                                                                                    control. .
                                                                                                                                                                    GAS Inc. commits to employ a series
                                                                                                                                                                    of stormwater Best Management
                                                                                                                                                                    Practices (BMP’s) and ensure that
                                                                                                                                                                    BMP’s are aggressively implemented
                                                                                                                                                                    where necessary. Stormwater BMPs
                                                                                                                                                                    will include a number of appropriate
                                                                                                                                                                    Low Impact Development guidelines
                                                                                                                                                                    for site development and building
                                                                                                                                                                    design to manage pre-development
                                                                                                                                                                    conditions, post development, that are
                                                                                                                                                                    to be considered in conjunction with
                                                                                                                                                                    stormwater BMP's in the stormwater
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                                                                                                                                                                        management           plan, prior      to
                                                                                                                                                                        construction, to the satisfaction of the
                                                                                                                                                                        Regional Manager, Environmental
                                                                                                                                                                        Protection    Division,    Ministry   of
                                                                                                                                                                        Environment (Surrey).

  297. August 19,   DFO       Section 3.2 Environmental Protection Plans                                      GAS provided an addendum stormwater report                 GAS commits to developing a
       2008                                                                                                   (McElhanney October 2008: revised January 2009)           stormwater management plan during
                              The effects upon the streams caused by the alteration of each of these areas,
                                                                                                              that outlined global performance targets and the          the detailed design phase of the
                              individually and cumulatively, will be assessed and documented.          The
                                                                                                              water balance modeling process, as per the new            Project, which will be provided to
                              identified impacts will then be reduced and wherever possibly eliminated with
                                                                                                              approach described as “Beyond the Guidebook.”             provincial and federal agencies for
                              the application of Low Impact Development and construction techniques. The
                                                                                                              This report was submitted to the EAO in February          review and comment.
                              initial stormwater/watershed management planning completed prior to the
                                                                                                              2009 as part of the Addendum 3.
                              conclusion of the EA process will identify:                                                                                               GAS commits to developing and
                                                                                                                                                                        implementing a sediment and erosion
                                  •   Pre-existing conditions                                                 Theupdated stormwater report (October 2008:
                                                                                                                                                                        control plan prior to construction to
                                  •   Potential impacts,                                                      revised February 2009) was to identify the global
                                                                                                                                                                        address sediment and erosion issues
                                                                                                              performance targets and water balance modeling
                                  •   Mitigation measures,                                                                                                              during construction of all road, base
                                                                                                              process only, during the EA process. Collection of
                                  •   Sizing and operational requirements of proposed LID Techniques.                                                                   and ski/lift areas. GAS also commits
                                                                                                              the baseline data, preparation of the detailed
                                                                                                                                                                        to have the final sediment and erosion
                              Detailed design would follow after the EA with the inclusion of the works hydrologic model, incorporation of mitigation                   control plan reviewed by a Certified
                              necessary to mitigate potential impacts. DFO would like an opportunity to measures and LID’s would occur during further                   Professional in Erosion and Sediment
                              review (30 days) the detailed design plan before relevant construction activity planning and the detailed design phase of the             Control (CPESC) prior to construction.
                              begins.                                                                         project, post EA process.
                                                                                                                                                                        GAS will continue to consult with the
                                                                                                              The methodology chosen to analyze stormwater              CPESC during construction to review
                                                                                                              runoff and environmental impact mitigation                if adaptive management measures
                                                                                                              requirements for the GAS Project has been                 need to be incorporated into the plan
                                                                                                              identified as “Beyond the Guidebook”. This approach       to ensure the plan successfully
                                                                                                              begins with an identification of the existing             manages sediment and erosion
                                                                                                              conditions as they relate to physical properties of the   control.GAS Inc. commits to employ a
                                                                                                              watershed(s). A second step identifies potential          series       of      stormwater       Best
                                                                                                              impacts and the methodologies that can be utilized        Management Practices (BMP’s) and
                                                                                                              to mitigate the identified impacts. This results in a     ensure that BMP’s are aggressively
                                                                                                              set of identified performance objectives and design       implemented         where       necessary.
                                                                                                              standards that would be used in creating the              Stormwater BMPs will include a
                                                                                                              facilities and infrastructure associated with the GAS     number of appropriate Low Impact
                                                                                                              Project. A third step would involve preliminary           Development guidelines for site
                                                                                                              engineering design followed by detailed design and        development and building design
                                                                                                              construction.                                             to manage                pre-development
                                                                                                                                                                        conditions, post development, that are
                                                                                                              In each of these steps there is an increasing level of
                                                                                                                                                                        to be considered in conjunction with
                                                                                                              detail that is available and therefore more
                                                                                                                                                                        stormwater BMP's in the stormwater
                                                                                                              information that is utilized. Further, during each step
                                                                                                                                                                        management             plan, prior      to
                                                                                                              of this detailed design and engineering process
                                                                                                                                                                        construction, to the satisfaction of the
                                                                                                              there will be regulatory review and verification the
                                                                                                                                                                        Regional Manager, Environmental
                                                                                                              project is achieving the goal of “No Net
                                                                                                                                                                        Protection      Division,    Ministry   of
                                                                                                              Environmental Impact”.
                                                                                                                                                                        Environment (Surrey).
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  298. February   MOE - ESD   MOE’s identification of fishery related concern requiring further investigation Surface waters withdrawn from Brohm River for              GAS commits to developing and
       25, 2009               with respect to the proposed altering of late spring flow regimes for reservoir potable water will not re-enter the watershed as           implementing a sediment and erosion
                              storage within the Brohm River Watershed                                         discharge from the liquid waste management system         control plan prior to construction to
                                                                                                               will be discharged directly into the Cheekye River.       address sediment and erosion issues
                              Issue: Runoff                                                                    Water withdrawn for snowmaking will be returned to        during construction of all road, base
                                                                                                               the Brohm River system through natural processes          and ski/lift areas. GAS also commits
                              The project proposes to store large volumes of water from the spring freshet,
                                                                                                               during snow melt.                                         to have the final sediment and erosion
                              for use at other times of the year. Assuming this water eventually returns to
                                                                                                                                                                         control plan reviewed by a Certified
                              Brohm River, or other surface waters, the returning water can change and then GAS Inc.’s original stormwater management
                                                                                                                                                                         Professional in Erosion and Sediment
                              differ from receiving waters in physical (temperature) or chemical components planning (April 2003) indicated that future systems
                                                                                                                                                                         Control (CPESC) prior to construction.
                              (nutrients, pH, dissolved oxygen). Eutrophication of waters is a concern as would comply with the Stormwater Guidebook for
                                                                                                                                                                         GAS will continue to consult with the
                              Brohm River and Cat Lake water chemistry and biota demonstrate elevated the Province of British Columbia.                     However,
                                                                                                                                                                         CPESC during construction to review
                              macronutrient concentrations (specifically phosphorus), with nutrient limitation subsequent to the submission of the initial
                                                                                                                                                                         if adaptive management measures
                              and productivity atypical of a south coast aquatic ecosystems. Watershed documents a new approach has been developed
                                                                                                                                                                         need to be incorporated into the plan
                              geology likely is the source of the nutrients, and waterflows through alternate and endorsed by several reviewing agencies. The
                                                                                                                                                                         to ensure the plan successfully
                              (to existing stream channels) paths combined with soil disturbances/vegetation new approach has been labeled “Beyond the
                                                                                                                                                                         manages sediment and erosion
                              removal/surface changes can potentially increase nutrient loading to fish Guidebook.            The new approach described as
                                                                                                                                                                         control.
                              bearing/supporting waters during summer or winter low flow periods, for “Beyond the Guidebook” is founded upon the
                              example. If settling ponds are used prior to reintroduction to surface waters, principal of avoiding adverse impacts to aquatic
                              then water temperature and dissolved oxygen changes can become an issue.         environments through an analytical process that is        GAS Inc. commits to employ a series
                                                                                                               based upon the best available scientific principles.      of stormwater Best Management
                                                                                                                                                                         Practices (BMP’s) and ensure that
                              Elevated nutrient runoff (e.g. elevated nitrogen) in the early stages of resort     GAS Inc.’s proposed 2008 stormwater planning           BMP’s are aggressively implemented
                              development could temporarily increase stream productivity and fish biomass,        process will incorporate the new approach as           where necessary. Stormwater BMPs
                              which would then decline, possibly a decade later – similar to a ‘boom and          described in “Beyond the Guidebook” and will           will include a number of appropriate
                              bust’ cycle typically following dam/reservoir construction. This could              involve establishing targets that would be             Low Impact Development guidelines
                              temporarily mask declines in fish biomass resulting from alterations to a natural   implemented during the detailed design process.        for site development and building
                              stream hydrograph, until many years after they have occurred.                       Targets will include:                                  design to manage pre-development
                                                                                                                      •   Predevelopment flow rates,                     conditions, post development, that are
                                                                                                                      •   Predevelopment flow volumes,                   to be considered in conjunction with
                                                                                                                                                                         stormwater BMP's in the stormwater
                                                                                                                      •   Predevelopment flow duration,
                                                                                                                                                                         management           plan, prior      to
                                                                                                                      •   Predevelopment stream erosion potential;       construction, to the satisfaction of the
                                                                                                                          and                                            Regional Manager, Environmental
                                                                                                                      •   Predevelopment Water Quality.                  Protection    Division,    Ministry   of
                                                                                                                                                                         Environment (Surrey).
                                                                                                                  The effects upon the streams caused by the
                                                                                                                  alteration of each of these areas, individually and
                                                                                                                  cumulatively, will be assessed and documented.
                                                                                                                  The identified impacts will then be reduced and
                                                                                                                  wherever possibly eliminated with the application of
                                                                                                                  Low Impact Development and construction
                                                                                                                  techniques.     The initial stormwater/watershed
                                                                                                                  management planning will identify:
                                                                                                                      •   Pre-existing conditions
                                                                                                                      •   Potential impacts,
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                                                                                                                    •   Mitigation measures,
                                                                                                                    •   Sizing and operational requirements of
                                                                                                                        proposed      Low     Impact     Development
                                                                                                                        techniques.
                                                                                                                    • Detailed design would follow with the
                                                                                                                        inclusion of the works necessary to mitigate
                                                                                                                        potential impacts.
                                                                                                               GAS Inc. will also develop detailed stormwater
                                                                                                               management plans during the detailed design phase
                                                                                                               of the project which will be provided to provincial and
                                                                                                               federal agencies for review and comment.

  299. February   MOE - ESD   MOE’s identification of fishery related concern requiring further investigation If, during the water licensing process GAS Inc.            GAS Inc. commits to conduct an
       25, 2009               with respect to the proposed altering of late spring flow regimes for reservoir determines that additional surface/groundwater is          environmental impact assessment and
                              storage within the Brohm River Watershed                                        required to support the full build-out of the project,     seek approval from the appropriate
                                                                                                              GAS Inc. will conduct an environmental impact              regulatory agencies if, during the
                              Issue: Groundwater Withdrawals                                                  assessment and seek approval from the appropriate          water licensing process GAS Inc.
                              Groundwater withdrawals have been identified as a potential secondary water regulatory agencies.                                           determines that additional surface or
                              source. However, until more details on location/amount are provided the effect                                                             groundwater is required to support the
                              of groundwater withdrawals on other surface waters cannot be evaluated.                                                                    full build-out of the project.
                              Groundwater withdrawals can significant reduce surface water flows at certain
                              times of the year.

  300. February   MOE - ESD   Fish Data – Background and Issues                                                GAS Inc. has committed to a “flow, ecological and         GAS Inc. commits to a “flow,
       25, May                                                                                                 geomorphic data collection program as part of the         ecological and geomorphic data
                              Life history and habitat of steelhead and coho in Brohm River are not well
       15, and                                                                                                 on-going review in the water licensing approval           collection program as part of the on-
                              known; holding areas, timing of entrance into the river through the canyon,
       June 25,                                                                                                process. In addition, GAS Inc. has committed to a         going review in the water licensing
                              spawn timing and fry emergence, are examples. The comparison of baseline
       2009                                                                                                    long term monitoring program that would allow             approval process.
                              stream flows (in NHC 2009) and possible altered flow conditions with these
                                                                                                               statistically meaningful post diversion cause and
                              critical life-history evaluations are absent. For example, steelhead enter the
                                                                                                               effect relations to be established with ongoing           GAS Inc. commits to a long term
                              Cheakamus watershed starting in Jan/Feb, with numbers gradually increasing
                                                                                                               development and flow withdrawal.                          monitoring program that would allow
                              until peak abundance occurs in late-April, concurrent with spawning and water
                                                                                                                                                                         statistically meaningful post diversion
                              temperatures >6C. The timing of migration and spawning in Brohm are not well Both programs, include data collection and analysis
                                                                                                                                                                         cause and effect relations to be
                              described, and could be different. Access into upper Brohm is through a specific to the following components:
                                                                                                                                                                         established with ongoing development
                              canyon section with associated bedrock-boulder step pools, which are a
                                                                                                                    • hydrology;                                         and flow withdrawal.
                              potential barrier to certain fish species at certain flow/temperature
                              combinations. The proposed reduction of Brohm River discharge in spring may           • geomorphology;
                              affect the numbers of fish entering the river, their migration timing, or both,       • water quality;
                              especially if significant pre-spawning holding occurs in the Cheakamus River          • fish and fish habitat; and
                              with a late migration into Brohm when water temperatures increase above 6C.           • benthic invertebrates.
                              Steelhead smolts migrate downstream during spring freshet, particularly on The proposed programs have been designed
                              high water events. Their migration period is typically April-May, with daily considering recommendations for proposals to
                              spikes often matching short-term peaks in flow. Reduced smolt yield in years withdraw or divert water as discussed in Lewis et al.
                              of low freshet flows has been noted on other south coast rivers such as the (2004) and Hatfield et al. (2007).
                              Keogh on Vancouver Island. Smolt migrations are a critical life-history stage, It may be possible to assess climate change impacts
                              and maintenance of annual maximum smolt production is the best mitigation to with      model       simulations    utilizing  IPCC
                              low marine survival rates which currently hinder south coast steelhead. A (Intergovernmental Panel on Climate Change)
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                        single year of drought induced smolt yield reduction can also affect stream scenarios downscaled to the site with various
                        productivity in subsequent years. How spring smolt production from Brohm weather generators.
                        would be effected by spring water withdrawals remains unexplored, and of
                        serious concern.
                        There is usually a downstream migration of steelhead parr/fry during high
                        spring flows in the Cheakamus River. This likely occurs in the Brohm as well,
                        which is likely responsible for helping seed the lower Cheakamus with parr
                        annually. The relationship between spring fry/parr migration and spring water
                        withdrawals is also unexplored. The relationship between Brohm and
                        Cheakamus steelhead is essentially unknown, but certainly linked and likely
                        codependent to some extent. Reductions in Brohm River fish production
                        would, therefore, reduce other important angling opportunities such as in the
                        Cheakamus River.
                        Steelhead populations across the south coast are at historically low numbers.
                        Many populations, including some in the Squamish watershed considered at
                        extreme conservation concern levels, indication they are below 15% of
                        historical capacity with an elevated risk of extirpation.

                        Coho salmon are historically the second most abundant fish in Brohm River
                        and analysis of their life-history stages in the context of an altered flow regime
                        has also not been investigated.

                        In conclusion, MOE-ESD is concerned that with the complexity of the
                        ecosystem and cumulative effects of a multi- faceted development, changes to
                        fish production cannot be predicted with certainty, and only post-construction
                        change in fish production will be an accurate measure. At a minimum, the
                        proponent should annually monitor salmonid smolt yield from the river, and fall
                        standing stock / fish biomass in an appropriate manner. A baseline, pre-
                        construction data set should be established.

                        One year of contemporary stream flow data is little information with which to
                        evaluate the ecological consequences of such a large development; especially
                        in the context of difficult to predict ‘climate change’ induced future weather and
                        rainfall changes. The ‘low flow’ period in Brohm River is already more than 7
                        months in duration according to NHC (2009). Considering the importance of
                        water discharge, timing, and quality to resources such as fish communities and
                        the ecosystem that supports them, the limited amount of water in the
                        watershed, the unique macronutrient water chemistry, and paucity of fish
                        information in the application, much more effort should be given to evaluating
                        potential biological changes resulting from the proposal.

                        Next Steps:
                        Identify the Species Present and Distribution:
                        Determine which species are or can be expected to

                        Develop a Fish Periodicity Chart for Each Species:
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                           •   Identify each life stage and major life sustaining activity of the species,
                               and the known times when each life-stage or activity is occurring in
                               each stream, lake or wetland. Timing of activities may be different in
                               mainst