The Grand Council of the Crees

Great Whale Conformity Report

Environment Guidelines and conformity report, Great Whale

Posted: 0000-00-00

[Editor's note: One of the most remarkable successes ever won by the Crees of James Bay was the campaign against the building of the Great Whale hydro project, proposed as an addition to the James Bay hydro project, until cancelled by the then-premier of Quebec, Jacques Parizeau. The campaign had two prongs, one a legal and environmental battle, the other a public relations battle. The Crees won both.

This legal and environmental battle was required after the Quebec and Canadian governments tried to do an end-run around the laws for environmental and social protection that they had themselves passed into law as a result of the signing of the James Bay and Northern Quebec Agreement of 1975. The Grand Council of the Crees went to court to insist that the environmental and social impacts of the proposed development must be considered within the aegis of the JBNQA, and they won their case. Thus, the proposer of the project, Hydro-Quebec, was forced to embark on an environmental and social review. For details of this crucial legal decision, see the link Cree Legal Struggle Against the Great Whale Project.

[Hydro-Quebec entered this process convinced that it could all be done within a matter of months, but the process took years, rather than months. The first part of the process was the establishment of a set of stiff guidelines that any environmental review would be required to meet. The provincial and federal administrators of the environmental and social regime established under Sections 22 and 23 of the JBNQA delivered these guidelines to Hydro-Quebec on September 9, 1992. Then came the Hydro-Quebec environmental assessment of the project, a document of more than 5,000 pages, comprised mostly of studies carried out over the previous 20 years.

[Hydro-Quebec delivered this impact statement on August 31, 1993, with an expectation that a response could be cobbled together within 40 or 50 days. The Crees fought this timetable successfully, and five separate committees established under the JBNQA first had to consider whether the impact statement was in conformity with the guidelines.

[These five review bodies jointly submitted a report on November 16, 1994, pointing out major inadequacies in the environmental statement. It became clear with this report that Hydro-Quebec would have to go back to square one and undertake a process of environmental and social evaluation that would take them several years. The day after receiving this report, Premier Parizeau announced the indefinite postponement of the Great Whale project.

[Because of the importance of this process, and its historic significance in terms of environmental assessment in Canada, this web site combines

(a) the guidelines that were considered to be inadequately addressed. These guidelines are printed in smaller type and indented.

(b) the report on the conformity, or lack of it, shown to the guidelines by the Hydro-Quebec environmental impact statement.]

JOINT REPORT ON THE CONFORMITY AND QUALITY OF THE ENVIRONMENTAL IMPACT STATEMENT FOR THE PROPOSED GREAT WHALE RIVER HYDROELECTRIC PROJECT

November 16, 1994

Mr. Jacques Brassard
Provincial Administrator
James Bay and Northern Quebec Agreement
3900 Marly street, 6th floor
Ste-Foy, Quebec
G1X 4E4

Mr. Michel Dorais
Federal Administrator
James Bay and Northern Quebec Agreement
200, Sacre-Coeur Blvd.
13th floor, Fontaine Building
Hull, Quebec
K1A 0H3

Sirs:

Pursuant to Sections 22 and 23 of the James Bay and Northern Quebec Agreement, we are pleased to transmit to you, on behalf of the Review Bodies responsible for the environmental assessment of the proposed Great whale hydroelectric project, our Joint Report on the Conformity and Quality of the Environmental Impact Statement submitted by the Proponent, Hydro-Quebec. This report takes into account the briefs and comments received during a public consultation that extended from February 15 to July 27, 1994.

Sincerely,

Peter Jacobs
Chairman
CQEK

Paul Lacoste
Chairman
COFEX
North d South

Gaston Moisan
Chairman
COMEX

MEMBERS OF THE REVIEW BODIES

(The appointing government of each member is identified in parentheses)

PROVINCIAL REVIEW COMMITTEE (COMEX)

Gaston Moisan, Chairman (Gouvernement du Quebec)

Daniel Berrouard, Biologist, Ministere de l'Environnement

et de la Faune, Gouvernement du Quebec (Gouvernement du Quebec)

Brian Craik, Anthropologist (Cree Regional Authority)

Chief Billy Diamond, Waskaganish First Nation

(Cree Regional Authority)

Clement Tremblay, President, NIRLIQ Inc. (Gouvernement du Quebec)

ENVIRONMENTAL AND SOCIAL IMPACT REVIEW PANEL NORTH OF THE 55th PARALLEL (COFEX-North)

Paul Lacoste, Chairman, former Rector, Universite de Montreal

(Government of Canada)

Claude E. Delisle, Professor, Environmental Engineering,

Civil Engineering Department, Ecole polytechnique de Montreal

(Government of Canada)

Jules Dufour, Professor, Geography and Environment, Departement

des sciences humaines, Universite du Quebec a Chicoutimi

(Kativik Regional Government)

Claude Grenier, Montreal (Kativik Regional Government), Professor, Oceanography, Department of Atmospheric

and Oceans Sciences, McGill University (Government of Canada)

FEDERAL ENVIRONMENTAL ASSESSMENT PANEL (FEAP) OF THE PROPOSED GREAT WHALE PROJECT

Paul Lacoste, Chairman, former Rector, Universite de Montreal

(Government of Canada)

Claude E. Delisle, Professor, Environmental Engineering,

Civil Engineering Department, Ecole polytechnique de Montreal (Government of Canada)

Grant Ingram, Professor, Oceanography, Department of Atmospheric

and Oceans Sciences, McGill University (Government of Canada)

ENVIRONMENTAL AND SOCIAL IMPACT REVIEW PANEL SOUTH OF THE 55th PARALLEL (COFEX-South)

Paul Lacoste, Chairman, former Rector, Universite de Montreal

(Government of Canada)

Philip Awashish, Consultant, Aboriginal Affairs (Cree Regional Authority)

Claude E. Delisle, Professor, Environmental Engineering,

Civil Engineering Department, Ecole polytechnique de Montreal

(Government of Canada)

Grant Ingram, Professor, Oceanography, Department of Atmospheric

and Oceans Sciences, McGill University (Government of Canada)

Andrew J. Orkin, Barrister and Solicitor (Cree Regional Authority)

KATIVIK ENVIRONMENTAL QUALITY COMMISSION (KEQC)

Peter Jacobs, Chairman, Professor of Landscape Architecture, Faculte de l'amenagement, Universite de Montreal (Gouvernement du Quebec) Bernard Arcand, Professor, Anthropology, Departement d 'anthropologie, Universite laval (Kativik Regional Government)

Daniel Berrouard, Biologist, Ministere de l'Environnement et de Ia Faune, Gouvernement du Quebec (Gouvernement du Quebec)

Bertrand Bouchard, Engineer, Ministere de l'Environnement et de Ia Faune, Gouvernement du Quebec (Gouvernement du Quebec)

Neil Greig, Consultant, Makivik Corporafion

(Kativik Regional Government)

Claude Grenier, Montreal (Kativik Regional Government)

Gilles Harvey, Biologist, Ministere de l'Environnement et de la Faune, Gouvernement du Quebec (Gouvernement du Quebec)

David Okpik, Quaqtaq (Kativik Regional Government)

Georges Simard, Geological Engineer, Ministere de l'Environnement et de la Faune, Gouvernement du Quebec (Gouvernement du Quebec)

CHAPTER 1

OVERVIEW AND GENERAL REQUIREMENTS

Introduction

On September 9, 1992, the Provincial and Federal Administrators of the environmental and social protection regime established under Sections 22 and 23 of the James Bay and Northern Quebec Agreement transmitted a set of GUIDELINES to the Proponent, Hydro-Quebec, containing requirements for the preparation of an Environmental and Social Impact Statement for the proposed Great whale River Hydroelectric project.

On August 31, 1993, in response to the GUIDELINES, the Proponent submitted a "Feasibility Study ... containing the Impact Statement on the environment" which was forwarded to the Review Bodies involved in the environmental and social review of the proposed Great Whale Hydroelectric project.1

In response to a request for clarification formulated on November 26, 1993, the Proponent specified that its Environmental Impact Statement (EIS) consists of the Feasibility Study, the Summary, the Table of Conformity, two volumes on methods, as well as a "Report on the Consultation pursuant to the GUIDELINES for the Environmental Impact Statement". Throughout this report, we refer to these documents as the Proponent's Environmental Impact Statement. In February 1994, Cree and Inuktitut versions of the Summary were published. An audiovisual document was distributed during April 1994. These additional documents are also considered to be part of the EIS.

The present report on the conformity and quality of the Proponent's EIS was prepared jointly by the Review Bodies, each acting as an independent agent and exercising its own jurisdiction as set forth in the Memorandum of Understanding (MOU) signed on January 23, 1992 by the governments of Quebec and of Canada, the Crees and the Inuit of Quebec, that provides for the coordination and harmonization of the environmental and social assessment procedures.

The present report reviews the EIS submitted by the Proponent in response to the GUIDELINES.2 The objective of this review is to determine whether the information provided in the EIS is complete and conforms to the general and specific requirements of the GUIDELINES, and is of sufficient and adequate quality to permit a complete evaluation of the proposed project.3 This review takes into account the advice provided during a public consultation that extended from February 15 to July 27, 1994. Ninety (90) briefs totalling more than 2000 pages were received (see Appendix I).

The present report presents an analysis of the EIS provided by the Proponent. All of the requirements4 presented in this report reflect specific deficiencies in content and/or form of the Proponent's EIS in light of the existing requirements of the GUIDELINES.

The present report does not constitute the final report of the Review Bodies on the impacts or acceptability of the proposed project. Once the Proponent's EIS conforms to the general and specific requirements of the GUIDELINES, and is sufficient and of adequate quality to permit a complete evaluation of the proposed project, public hearings will be held, following which a final report on the environmental evaluation of the proposed project will be produced by the Review Bodies.

Major Inadequacies of the Environmental Impact Statement

GUIDELINES paras. 106, 111 and 121

106. The purpose of this document is to set forth guidelines that the

Proponent must follow in presenting the EIS on the proposed Great Whale

River hydroelectric project. It is incumbent upon the Proponent to prepare

a complete EIS that includes sufficient basic data and analyses for a

complete assessment of the anticipated impacts and their repercussions.

111. The proposed Great Whale hydroelectric development project would take place in an intercultural context in a northern environment; at the same time, it represents a choice with respect to the Government of Quebec's energy policy. The environmental impact assessment of the proposed project, whether in biophysical or social terms, must rely on the principles set forth in Sections 22.2.4 and 23.2.4 of the JBNQA, as well as several other principles that are in turn based on the concept of sustainable and equitable development.

121. Evaluation of the proposed project will be based on five fundamental issues that affect ecosystem integrity: 1) the health of all human and animal communities in the region; 2) access to the territory by all human and animal populations; 3) the availability of resources, which requires that they be sufficient in quantity and satisfactory in quality; 4) the maintenance of social cohesion at the local, regional and national levels; and 5) the respect for values.

Referring to Sections 22 and 23 of the JBNQA and to the terms of reference of the Federal Environmental Assessment Panel, the GUIDELINES indicate the importance that the Review Bodies accord to the principles set forth there. In addition to project justification, which is considered an essential step, the GUIDELINES indicated that the evaluation of the proposed project shall consider five major issues:

The EIS submitted by the Proponent adds to the general knowledge of the region of the proposed project. The EIS responds to a number of directives contained in the GUIDELINES fully and completely. Nevertheless, the Proponent's EIS suffers from a number of major inadequacies which prevent a clear definition and prediction of the repercussions of the proposed project to the extent that it becomes extremely difficult to adequately estimate its real costs and benefits. Many intervenors in the process commented on these inadequacies. As submitted by the Proponent, the EIS is presently neither sufficiently complete nor adequate for the decision-making process.

The major inadequacies of the EIS identified in this report are:

Furthermore, the Review Bodies faced numerous difficulties that arose from the structure, size, quantity and diversity of documents that form the

EIS.

Ambiguities Related to Study Area Boundaries and Project Schedule

GUIDELINES paras. 107 to 110,122 to 125 and 131

107. These Guidelines pertain to the proposed project as described in the

Preliminary Information submitted by the Proponent in October 1991.

Additional information contained in the Proponent's Bulletin 5 (November

1991) and in a letter from the Proponent dated February 21, 1992 are

considered part of the preliminary information for the purposes of these

Guidelines. These documents are reproduced in Appendix 2.

108. The proposed project includes the Great Whale hydroelectric installations, the transportation, housing and communication infrastructures and the corridor of the 315-kV collector system needed to transport electricity to the existing distribution system of the La Grande complex at Radisson and Chissibi substations. Any transmission lines beyond that point are expressly excluded from this review process in conformity with the MOU, which defines the project making reference to the out-of-court Declaration of Settlement in the case of Dick et al vs. Paradis et al (October 25, 1991). The transportation infrastructure includes all airports required for the proposed project, including any expansion of the existing airport at Kuujjuarapik/Whapmagoostui or the development of any new airport facilities closer to the proposed GB1 site, as well as temporary airports (including the one proposed for Lac Fagnant), road right-of-ways and corridors reserved for this purpose. The transportation infrastructure also includes any existing or planned marine installations which might be required.

109. The variant that has been selected by the Proponent includes the downstream diversion of the Little Whale River, but leaves intact this river's headwaters and middle reaches, and excludes even the partial development of the Nastapoka River basin. Therefore, for the purposes of this EIS, the proposed Great Whale River hydroelectric project includes the combined development of the Little Whale River and the Great Whale River, but completely excludes the development of the Nastapoka River basin.

110. A schedule shall be presented for each phase of construction. It was stated in Bulletin 5 that the proposed project would be completed between 1993 and 2000. However, at a meeting with the Proponent on April 8, 1992, the review bodies were informed that a new schedule had been adopted whereby GB1 would be commissioned in 2000, GB2 in 2007 and GB3 in 2008. This schedule shall be considered definitive for the purposes of the EIS. Any appreciable change to this schedule should be indicated to the administrators. In that case, the administrators and the review bodies could reconsider the review process. However, the Proponent shall not be considered responsible for any delays due to the public review process.

122. Some of the potential impacts of the proposed project will occur only in the region defined by the drainage basins and estuaries of the Great Whale River and the Little Whale River, along with Manitounuk Sound and the adjacent coastal areas. Others will extend beyond these boundaries. The communities affected by the proposed project are Whapmagoostui, Chisasibi, Radisson, Kuujjuarapik, Inukjuaq and Umiujaq, as well as the community of Sanikiluaq on the Belcher Islands. The Naskapi may also be affected, as their hunting activities extended to the upper part of the drainage basins of the Great Whale and Little Whale Rivers.

123. The Proponent shall define the appropriate extent of the study area, taking into account the scope of the various components under examination.

124. Some potential impacts of the proposed project have regional and national implications and may affect the entire region of Hudson Bay around which other river development projects have already been built. As well, additional projects are anticipated in this region. The cumulative effects of all of these projects on the influx of sediments, nutrients, heat and contaminants (including mercury) into the Bay, on the regional climate, on the food chain and on the quality and even the survival of the marine resources of Hudson Bay are important environmental concerns. The Proponent shall evaluate the extent to which the proposed project will alter the ecosystem of Hudson Bay. The Proponent shall thus describe the cumulative impacts of this proposed project, considering in particular other projects under its purview, such as the La Grande complex, and other existing projects, such as Churchill-Nelson, and those currently undergoing public review, such as the Conawapa project.

125. Some of the potential impacts of the proposed project have global and international implications that extend well beyond the region directly affected by the project. For example, the Proponent shall address its potential impacts on global climatic conditions through the production of greenhouse gases in areas that would be completely or partially submerged, as well as those on migratory birds, which constitute a biological patrimony shared by other regions and countries. The biological heritage contained in the diversity of the flora and the fauna of the region is another pertinent issue. The Proponent shall demonstrate that the proposed project would not cause irreparable damage to rare or endangered flora and fauna of the region and would not contribute to their extinction.

131. Temporal and spatial boundaries must be determined on the basis of the potential impacts on the particular biophysical or social phenomenon being addressed.

The physical description of the proposed project as provided in the EIS corresponds to the project submitted for evaluation. However, the commissioning dates contained in the EIS differ from those which the GUIDELINES consider definitive for the purpose of evaluation. Furthermore, the Proponent submitted several documents to the Technical Information Exchange Group indicating that commissioning dates may vary significantly depending on demand-growth and other possible scenarios; e.g., under some circumstances, the proposed Great Whale project may not be required until after 2031. Moreover, the Proponent's BIS has not included at least one affected local community that was specified in the GUIDELINES into its study area.

The Proponent shall clearly indicate the range of dates within which it plans to commission the complex, and specify the time interval within which it intends to complete construction. Information concerning factors (including uncertainty) that could delay or advance the beginning of construction; as well as those that could delay or lengthen the construction period, should be provided pursuant to the requirements of paragraph 110 of the GUIDELINES.

The Proponent shall comply with the GUIDELINES definition of the areas and people that would be affected by the proposed project, inasmuch as these boundaries may vary according to different impacts and as the affected region extends across administrative boundaries. The Proponent shall include the community of Sanikiluaq in its study area as specified in the GUIDELINES. Furthermore, with respect to particular specified impacts on eastern Hudson Bay including the Belcher Islands, the Proponent shall include a description of this environment and potential impacts on it. where not specified, the Proponent shall define and justify the boundaries that delimit the region that will be affected by the proposed project and explain why the coastal region of eastern Hudson Bay (including the Belcher Islands) or the Naskapi and Montagnais societies should or should not be included.

Treatment of Principal Assessment Criteria

Including Sustainable and Equitable Development

GUIDELINES paras. 112 to 114

112. In its 1989 Development Plan, the Proponent explicitly adopted the concept of sustainable development as defined by the World Commission on Environment and Development (the "Brundtland Report"). This commitment signifies that the proposed project. must be developed in accordance with the carrying capacities of ecosystem and human societies involved.

113. The proposed project must also respect the rights of local communities to determine their future and their own societal objectives: the proposed project must not endanger the durability or quality of resources that form the basis of an existing regional economy that functions in accordance with the precepts of sustainable development. Consequently, one of the elements of the evaluation of the proposed project Will be the appraisal of any potentially irreversible impacts upon local and regional economic development.

114. Project evaluation will be based, in part, on respect for the right of future generations to the sustainable use of the ecosystems within the proposed project area, both for the local population and for society as a whole. This involves preserving the region's flora and fauna, mantaining the quality and capacity of ecosystems and their renewable resources, preserving unique and remarkable sites, conserving cultural diversity, and maintaining and improving the quality of life in the region.

The concept of sustainable and equitable development is central to the GUIDELINES, and is one of the principal criteria for assessment of the proposed project.

The Proponent has presented the advantages of hydroelectric energy over fossil fuels with respect to global warming, but has failed to apply the precepts of sustainable and equitable development as a "principal assessment criterion". In particular, the magnitude and importance of the proposed project's irreversible impacts on ecosystems and human societies in the region, and the sustainable and equitable development issues involved in endogenous regional development, have not been examined adequately.

Many intervenors in the public consultation process were critical of the Proponent's treatment of these issues. They commented that the EIS addresses the questions of sustainable and equitable development from the sole perspective of energy choices and legal rights.

Based on the now substantial literature concerning sustainable and equitable development, the Proponent shall fully discuss the proposed project in the light of the concepts of sustainable and equitable development to which it has chosen to adhere and indicate how it intends to translate these concepts into practice, with reference to: energy choices in the justification of the proposed project; environmental and social impacts; and to measures proposed to avoid, mitigate, compensate or manage the repercussions of the proposed project.

Knowledge of Human Societies Affected

GUIDELINES paras. 119, 126 to 130 and 132 to 135

119. It is the responsibility of the Proponent to choose the most appropriate analytical methods, taking into account the present guidelines, as well as the environmental and social concerns specific to the cultures of the various populations affected in order to identify as accurately as possible the valued ecosystem components.

126. Local residents' knowledge of their biophysical and social milieu is essential to an adequate assessment of the Impacts of a development project. Furthermore, each cultural group has its own conceptual and symbolic system that reflects the group's image of itself and of its communities, its environment and its past and future. Since this

conceptual and symbolic system partly determines the group's reaction to change, it is an intrinsic element of the environment itself and must be thoroughly understood before the impacts of a development project can be assessed. In the case of the proposed Great Whale project, the Proponent must be particularly attentive to the conceptual and symbolic systems and knowledge of the populations affected.

127. Considering this diversity of cultures, it is to be expected that the ecosystem components which are identified and given value may well vary from one culture to another, and, even if they are similar, that the reasons for which they are valued may be different. In the same way, since points of view concerning the proposed project and its impacts are based on different values and knowledge, it is quite likely that they will vary from one culture to another. The Proponent shall take this diversity into account both in its description of the environment and in its impact analysis, through the notion of valued ecosystem components.

128. The reactions of populations to a proposed project, their ability to integrate it into their environment and their propensity to feel alienated by it depend in part on the degree to which they are involved in the decision-making. The Proponent shall therefore establish mechanisms to incorporate the knowledge and opinions of all communities that inhabit the region and plan to continue to do so. These mechanisms shall include consultations related to research that may be required to complete the EIS.

129. The Proponent shall describe the consultation procedures initiated since the announcement of the project, notably those implemented in the affected communities, and the manner in which these consultations have affected the Proponent's decisions with respect to the proposed project.

130. The Proponent shall specify and justify all sampling methods and statistical processes employed in both the biophysical and social milieu. The reliability and scope of the results, the possibility of reproducing the analyses and quality control of laboratory analyses shall be analyzed critically. Ml data based on environmental sampling necessarily involve some variability, which must be determined to assess the reliability and scope of the data. In the EIS, the Proponent shall, for all data obtained from environmental sampling, provide a dispersion or variability coefficient (variance, standard deviation, confidence interval, etc.) and indicate the size of the sample used. Similarly, when using mathematical models, the Proponent shall indicate the prototype used, the accuracy, and the inherent limits of interpretation.

132. Various methods have been developed in the social sciences to gather the knowledge of resident populations. The Proponent shall explain and justify the methods used. Insofar as possible, interviews shall be recorded, transcribed and made accessible for consultation. Those recorded in Native languages shall be translated into French or English. Generally accepted rules of ethics in the social sciences, in particular those which aim to protect people's reputations and the identity of subjects interviewed, shall be respected. If written data concerning people's knowledge or opinions is used, the Proponent shall provide references and shall make the texts publicly available. The Proponent shall also explain the methods used to account for the knowledge, opinions or conceptual and symbolic Systems derived from such interviews and texts.

133. Where essential data are missing and cannot be collected, the Proponent must advise the administrators and the review bodies, who reserve the right to initiate independent research should they deem additional studies necessary or to propose other measures. The Proponent shall evaluate the significance of the absence of data from the study area. The Proponent shall also refer to existing relevant literature carried out in similar conditions elsewhere and shall describe the limits of interpretation imposed by this type of data.

134. Various regional organizations have already conducted studies on the biophysical and social milieu. The Proponent shall describe cooperative arrangements made with these organizations, with specialized research centres or with any other institution or person with recognized expertise in specific research areas pertinent to the study area. Furthermore, the Proponent shall consult the appropriate government agencies and shall provide a report on those consultations.

135. Wherever the Proponent makes use of qualitative criteria to compare various design and development options, to describe the environment, or to assess impacts, each of these criteria shall be defined, their relative importance stated, and the differences between the categories (e.g., desirable, acceptable, unacceptable) indicated. The Proponent shall justify the classification of each criterion.

A significant number of the GUIDELINESaddress the need for the Proponent to gain a thorough understanding of indigenous knowledge and values before assessing the impacts of the proposed project, and then incorporate these concepts into the EIS.

The EIS is based upon a limited knowledge of the societies and cultures directly affected by the proposed project and does not provide a basis for the prediction of the repercussions of the proposed project on these societies. The Proponent's analysis of the impacts of the proposed project on societies affected is based on data which are often obsolete or incomplete. The extent of knowledge of the biophysical environment and the degree of effort made to acquire it have not been matched with respect to the human environment. The knowledge of local communities about their own environment, which would be essential to an adequate project evaluation is, for all practical purposes, absent from the EIS.

The GUIDELINES indicate that particular attention must be given to the conceptual and symbolic systems and the knowledge of the affected communities, both in the description of the environment and analysis of the impacts. Thus, the EIS was to contain a portrait of the environment that each culture could recognize, and an inventory of the elements judged important by each one. This has not been presented.

The GUIDELINES require the integration of such knowledge into the EIS, and to this end, consultation with local populations. However, because consultation with some local communities (pursuant to the GUIDELINES)did not take place prior to the preparation of the EIS, and because of inadequacies in the consultation of others, the knowledge and values of these local populations have not been adequately taken into account in the EIS. For these groups, neither their reality, nor their concerns or aspirations, are clearly recognizable in the EIS.

From the description of the human environment presented in the EIS, it is not possible to assess the widespread effect of the proposed project on the affected societies as a whole, on the crucial issue of the local communities' reaction to the proposed project, on their ability to integrate it into their own development projects; or, conversely, on their tendency to feel alienated by the proposed project.

The Proponent shall comply with the requirements or the GUIDELINES and this report concerning the economic, spiritual and other social or cultural impacts or the proposed project. The Proponent shall describe the human and biophysical environment in which the proposed project would be placed, using appropriate scientific and consultative methodologies developed with the affected local communities, and including descriptions that would be recognized by those societies.

The knowledge and values or each cultural group, including its conceptual and symbolic system, shall be incorporated into all appropriate sections of the documents prepared by the Proponent in response to the requirements of this report.

Approach to the Study of the Combined and

Integrated Effects of the Project

GUDELINES paras. 118, 120, 124, 125 and 136

118. In addition to determining the individual impacts on specific elements of the biophysical and social environment, the EIS shall address the combined and cumulative effects of these impacts on entire sectors of the ecosystem, including the human societies in the proposed project area.

120. The Proponent shall determine the extent to which modification of one ecosystem component will be more significant than that of another. The proposed project would have impacts of varying significance, and even minor impacts on a valued ecosystem component may be more significant than major impacts on a secondary component.

124. Some potential impacts of the proposed project have regional and national implications and may affect the entire region of Hudson Bay around which other river development projects have already been built. As well, additional projects are anticipated in this region. The cumulative effects of all of these projects on the influx of sediments, nutrients, heat and contaminants (including mercury) into the Bay, on the regional climate, on the food chain and on the quality and even the survival of the marine resources of Hudson Bay are important environmental concerns. The Proponent shall evaluate the extent to which the proposed project will alter the ecosystem of Hudson Bay. The Proponent shall thus describe the cumulative impacts of this proposed project, considering in particular other projects under its purview, such as the La Grande complex, and other existing projects, such as Churchill-Nelson, and those currently undergoing public review, such as the Conawapa project.

125. Some of the potential impacts of the proposed project have global and international implications that extend well beyond the region directly affected by the project. For example, the Proponent shall address its potential impacts on global climatic conditions through the production of greenhouse gases in areas that would be completely or partially submerged, as well as those on migratory birds, which constitute a

biological patrimony shared by other regions and countries. The

biological heritage contained in the diversity of the flora and the fauna of the region is another pertinent issue. The Proponent shall demonstrate that the proposed project would not cause irreparable damage to rare or endangered flora and fauna of the region and would not contribute to their extinction.

136. The Proponent shall explain the methodology used to predict the impacts on the biophysical and social environments, and shall validate any model used for this purpose. All studies used in the prediction of impacts must be specified, a data base organized, the original authors identified and the studies made public. All statements based on public consultation shall be justified and the sources and methodology specified. The choice of methodologies and interpretation of results shall be justified in light of current theories, knowledge and standards. The Proponent shall review the theory and practice of cumulative impact assessment and shall justify the methodology proposed.

Social and environmental impacts are not presented in the EIS in a way that would permit an adequate understanding of their combined and cumulative effects. Rather, they are addressed with respect to each physical component of the proposed project. While the framework of the EIS lends itself to an understanding of the direct impacts of each part of the proposed project, an integrated understanding of the combined impacts of the entire proposed project on individual components of the environment is lacking.

Two volumes of the EIS deal with the combined and cumulative impacts of the proposed project. The volume on "Cumulative Impacts" addresses selected elements (e.g., climate, caribou, biodiversity, the influence of fresh water in subarctic marine environments, and the emission of greenhouse gases), but does not address the five integrative issues of the GUfDELINES. The volume on "Key Issues" addresses these integrative issues in part, but does not deal adequately with combined and cumulative effects.

The Proponent's vision of the cumulative effects of environmental impacts remains limited, and is particularly weak in its discussion of the proposed project's cumulative effects on the human environment. The EIS tends to minimize the importance of the cumulative effects of impacts, or to ignore some, by concentrating on questions of scale, proportion and overlap.

Combined and cumulative effects will likely be produced at various levels and scales, from a global to a community level, impacting on both human societies and various components of the biophysical environment, large and small. With regard to proportion, the assertion in the EIS that biophysical impacts on land are proportionate to the surface area affected implies that the land is homogeneous to a degree that does not correspond to reality. Moreover, the fact that the zones of impact do not physically overlap does not preclude the existence of cumulative effects.

Within temporal and spatial boundaries appropriate to the respective impacts, the Proponent shall discuss and predict cumulative effects of biophysical and human impacts establishing links between these effects and the five major issues of the GUIDELINES, listed above.

Project Justification

GUIDELINES paras. 115 to 117

115. Before proceeding to an assessment of the proposed project's environmental impacts, the Proponent shall justify the need for the proposed project and explain its general rationale. It is understood, however, that successful justification of the proposed project would not of itself imply project acceptance. Justification is an essential step in the environmental assessment process.

116. The Proponent, in justifying the proposed project, shall address three interrelated aspects of the energy question. The Proponent shall present detailed energy demand growth forecasts for the next 30 years, followed by an examination of all possible alternatives for meeting this anticipated growth in demand. Then, the rationale for choosing the proposed Great Whale project from among the other energy alternatives must also be demonstrated. The MOU contains a list of subjects that must be addressed by the Proponent for each of these analyses.

117. When analysing the most appropriate means of meeting the anticipated growth in demand, the Proponent shall make a qualitative comparison of the major environmental impacts of the various options. This general comparison does not require in-depth studies of each alternative, nor does it replace the technical and economic justification of the proposed project. Rather, it will be taken into account once the direct impacts of the proposed project have been established by means of this

EIS.

The Proponent's EIS provides much useful information and analysis regarding the justification of the proposed project. It is not possible however, using the data and analyses provided, to determine whether the proposed project is justified or would be required by the dates mentioned in the EIS and whether the best scenario for meeting Quebec's future energy needs includes the proposed project. Complete understanding of the need for the proposed project and of its timetable is hindered by a cursory analysis of the cost-effectiveness of alternative means to meet energy needs and by the lack of a systematic comparison of their environmental and social costs and benefits. The evaluation of the proposed project's justification is further hindered by an inadequate analysis of potential demand management programs and by an incomplete financial analysis, including impacts on rates.

Appreciation of the Uncertainty Associated

with the Proposed Project's Impacts

GUIDELINES paras. 130 to 137

130. The Proponent shall specify and justify all sampling methods and statistical processes employed in both the biophysical and social milieu. The reliability and scope of the results, the possibility of reproducing the analyses and quality control of laboratory analyses shall be analyzed critically. Ml data based on environmental sampling necessarily involve some variability, which must be determined to assess the reliability and scope of the data. In the EIS, the Proponent shall, for all data obtained from environmental sampling, provide a dispersion or variability coefficient (variance, standard deviation, confidence interval, etc.) and indicate the size of the sample used. Similarly, when using mathematical models, the Proponent shall indicate the prototype used, the accuracy, and the inherent limits of interpretation.

131. Temporal and spatial boundaries must be determined on the basis of the potential impacts on the particular biophysical or social phenomenon being addressed.

132. Various methods have been developed in the social sciences to gather the knowledge of resident populations. The Proponent shall explain and justify the methods used. Insofar as possible, interviews shall be recorded, transcribed and made accessible for consultation. Those recorded in Native languages shall be translated into French or English. Generally accepted rules of ethics in the social sciences, in particular those which aim to protect people's reputations and the identity of subjects interviewed, shall be respected. If written data concerning people's knowledge or opinions is used, the Proponent shall provide references and shall make the texts publicly available. The Proponent shall also explain the methods used to account for the knowledge, opinions or conceptual and symbolic Systems derived from such interviews and texts.

133. Where essential data are missing and cannot be collected, the Proponent must advise the administrators and the review bodies, who reserve the right to initiate independent research should they deem additional studies necessary or to propose other measures. The Proponent shall evaluate the significance of the absence of data from the study area. The Proponent shall also refer to existing relevant literature carried out in similar conditions elsewhere and shall describe the limits of interpretation imposed by this type of data.

134. Various regional organizations have already conducted studies on the biophysical and social milieu. The Proponent shall describe cooperative arrangements made with these organizations, with specialized research centres or with any other institution or person with recognized expertise in specific research areas pertinent to the study area. Furthermore, the Proponent shall consult the appropriate government agencies and shall provide a report on those consultations.

135. Wherever the Proponent makes use of qualitative criteria to compare various design and development options, to describe the environment, or to assess impacts, each of these criteria shall be defined, their relative importance stated, and the differences between the categories (e.g., desirable, acceptable, unacceptable) indicated. The Proponent shall justify the classification of each criterion.

136. The Proponent shall explain the methodology used to predict the impacts on the biophysical and social environments, and shall validate any model used for this purpose. All studies used in the prediction of impacts must be specified, a data base organized, the original authors identified and the studies made public. All statements based on public consultation shall be justified and the sources and methodology specified. The choice of methodologies and interpretation of results shall be justified in light of current theories, knowledge and standards. The Proponent shall review the theory and practice of cumulative impact assessment and shall justify the methodology proposed.

137. The Proponent shall support all analyses, interpretations of results and conclusions with an extensive review of the appropriate literature, providing all references required and indicating the public availability of all works consulted, when appropriate. Any contribution based on traditional knowledge used shall also be specified and sources identified. The Proponent shall also define all technical terms used in the EIS and include these in a glossary.

The analysis of environmental impacts, both with respect to the biophysical environment and the human environment, must adequately state the degree of uncertainty in the data on which predictions have been based. Study methods, particularly sampling and Statistical methods used to establish a basic level of knowledge are the foundation of the reliability of these studies and of the scope of the conclusions that can be drawn from them.

Although the Proponent attached to the EIS a document on methods used which demonstrates that most of the data were collected and analysed according to standard practice, the body of the EIS does not systematically refer to uncertainties related to sampling nor does it provide indices of variability for each particular data set (see Appendix II). It is therefore difficult to establish the degree of certainty or uncertainty that should be attached to much of the descriptive information in the EIS, and therefore to many of the predictions of anticipated impacts of the proposed project.

References in the EIS to previously published studies are frequently either incomplete (e.g., caribou), selective (e.g., on benthos in reservoirs) or absent (e.g., predators of beavers). References in the EIS to supporting documents or to previous studies carried out by or for the Proponent are often either non specific, or are difficult or impossible to verify (see Appendix II). In addition, the multitude of overlapping bibliographies in the EIS caused considerable difficulty.

The EIS contains a total of 112 separate reference lists, including a "Bibliography" volume which lacks many of the references included in other lists. Thus, attempts to inquire into the quality of the data on which the conclusion in the EIS are based is impeded by the difficulty of finding the necessary methodological information. Consequently, it is difficult to assess the quality and validity of the data, inventories, analyses and knowledge which form the basis of the descriptions of the biophysical and social environments, and of the evaluation of impacts contained in the

EIS.

The Proponent is referred to paragraphs 130 to 137 of the GUIDELINES and is required to conform with these requirements in forwarding new information for review.

Mitigation Measures and Project Management

GUIDELINES paras. 601 to 634 and 701 to 713

601. The Proponent shall present mitigative measures for the impacts of the proposed project. The Proponent shall also identify the nature and scope of the residual impacts that will occur in spite of these measures and propose, where necessary, a program of compensatory measures.

602. It is essential that mitigative measures be planned in advance, and not be instituted reactively. Before construction work on the proposed project begins, the Proponent shall develop a proactive plan for mitigative and compensatory measures that would be implemented during the construction and operation phases of the complex.

603. A detailed description of the Proponent's policy concerning mitigation and compensation shall be presented, including its rationale and an analysis of mitigation and compensatory measures undertaken with respect to the La Grande projects. In particular, if funds have been set aside (whether as capital or as operating costs) for mitigation and compensation, the Proponent shall distinguish between funds which were destined for mitigation and for compensation, and shall explain how these figures were arrived at. The Proponent shall evaluate the effectiveness and efficiency of the mitigative and compensatory measures for the La Grande projects and shall report on the level of satisfaction of the affected populations with regard to those measures. The Proponent shall also refer to other projects in northern environments (Churchill, Churchill-Nelson, etc), as well as to relevant literature available, in order to demonstrate that the mitigative and compensatory measures proposed reflect the state of the art in the field.

604. Furthermore, the Proponent's policy concerning mitigation and compensation shall be compared with that of other major Canadian utilities that are undertaking hydroelectric development in a northern environment. The Proponent shall refer to other projects in northern environments (Churchill Falls, Churchill-Nelson, etc.), as well as to the relevant literature available in order to demonstrate that the mitigative and compensatory measures proposed reflect the state of the art in this field, and are respectful of Native populations.

605. In keeping with the requirements outlined in paragraph 128, the Proponent shall consult with the Native populations and ascertain their needs with regard to developing mitigative and compensatory measures for the proposed project. A concrete mitigation and compensation program should reflect these consultations.

MITIGATIVE MEASURES:

606. The objective of mitigative measures is to lessen or alleviate a project's negative environmental impacts. To this end, the Proponent shall present all such measures, as well as the preventive and corrective actions proposed during all phases of the proposed project. Particular attention shall be paid to minimizing the impacts on Category I and II lands.

607. The Proponent shall provide an indication of the costs, timing and mode of implementation of these mitigative measures, and shall identify the parties responsible for their implementation, as well as the contractual obligations of the contractors and sub-contractors hired to carry out specific measures.

608. The Proponent shall also report on the experience concerning the organization of remedial work activities and propose an institutional framework appropriate to the proposed project. The proposed institutional framework shall take into account the central role of Native peoples who will be affected by the proposed project.

609. The review of mitigative measures by the Proponent shall include, but not be limited to, the following aspects and general categories: health and well-being; safe access to land and resources; drinking water quality and supply and other municipal infrastructures; valued or sacred sites; socio-economic impacts; employment and contractual opportunities for Native peoples; hydrological management, restoration and project management.

HEALTH AND WELL-BEING:

610. The Proponent shall identify the groups that would be most affected by the proposed project and shall consult with members of those communities to determine ways to reduce or eliminate any impacts on health and personal and community well-being.

611. The Proponent shall indicate how the collaborative work with existing health-care agencies will be established and shall ensure that community members (particularly those concerned with health-related matters) may participate in the decision-making process.

612. In the case of mercury, the Proponent shall suggest a social intervention strategy and shall identify the resources required to implement and periodically review it. In this context, the Proponent shall propose, among others, a strategy for ongoing dialogue and consultation between the Proponent and the affected population as well as those government agencies involved. The Proponent shall address problems of language or comprehension in implementing information programs for users of these resources.

SAFE ACCESS TO LAND AND RESOURCES:

613. The Proponent shall indicate how the free movement of Native peoples will be maintained, should the proposed project be approved, in order to ensure access to the territories, including replacement of access routes for fishing, hunting and trapping during construction phases when access will be restricted; and the possibility of maintaining rivers, lakes and reservoirs as traditional transportation routes for Native peoples, both in summer and winter.

614. In addition, the Proponent shall indicate the specific measures to be taken to ensure that Native activities can be pursued in safety. Where waterways become partially or totally unsuitable for travel due to reduced or increased water flow, the Proponent shall specify remedial and compensatory measures to be implemented.

615. The Proponent shall examine the measures to be taken to limit negative impacts on migratory birds, considered as a resource for southern and northern populations.

DRINKING WATER AND OTHER MUNICIPAL

INFRASTRUCTURES:

616. The Proponent shall indicate how an acceptable and adequate drinking water source both in quality and supply for Kuujjuarapik/Whapmagoostui will be ensured, in collaboration with these communities. In this regard, the Proponent shall present the various options and indicate the advantages and disadvantages of each one while describing the work required and the environmental impact. The Proponent shall also identify any other agencies involved and indicate the extent of the Proponent's participation in the implementation of the measure taken to guarantee that the communities will have a viable and sufficient source of drinking water to satisfy their current and future needs.

617. The Proponent shall also propose mitigative measures to be undertaken concerning other municipal infrastructures (e.g., solid waste and wastewater) that could be affected by the proposed project.

VALUED OR SACRED SITES:

618. In. consultation with the communities concerned, the Proponent shall identify the location of burial sites that could be disturbed by the proposed project, and shall design a program to deal with their possible relocation. In addition, the Proponent shall discuss measures to be undertaken for the preservation of historical, sacred, cultural, archaeological and natural sites and the recovery of materials. The Proponent shall also discuss the best way to use the results of various studies to enhance knowledge of the history and prehistory of the territory in order to ensure that this knowledge is made available to Native groups.

619. Measures the Proponent intends to undertake regarding the aesthetic and recreative enhancement of areas which may or may not be affected by construction work, including those used for hunting and fishing, shall be indicated. These measures shall include the possible deforestation of sectors to be flooded for purposes of aesthetics or wildlife management and/or the removal of wood residue after impoundment. The Proponent shall also examine the possibility of selecting corridor pathways in such a way that the power lines would be as little visible as possible from sites of special interest.

SOCIO-ECONOMIC IMPACTS, EMPLOYMENT AND

CONTRACTUAL OPPORTUNITIES FOR NATIVE PEOPLES

620. The Proponent shall describe the most appropriate strategies for the development of education programs designed and carried out by Native peoples to heighten awareness of the proposed project's impacts, the social changes that may occur, and the mitigative measures that might be taken to minimize the impacts of the proposed project.

621. The Proponent shall outline policies concerning the employment of Native peoples and the use of Native enterprises by the Proponent and by contractors engaged for the construction and operation of the proposed project.

622. Measures the Proponent intends to take to ensure that a substantial number 6f Natives have employment opportunities and to ensure that Native enterprises are involved in the construction and operation of the proposed project shall be identified. This shall include but not be limited to: a clear policy concerning preferential employment and contractual allocations to Natives; the measures the Proponent intends to include in the tender documents to ensure that contractors hire Native workers and subcontract to Native enterprises; the number of jobs which the Proponent and contractors would guarantee to the Native population, both in the construction phase and in the operation of the proposed project; and an indication of the value of contracts which the Proponent and contractors would guarantee to Native enterprises.

623. The experience of the Proponent during the construction and operation of the La Grande project shall be presented, with emphasis on the effective participation of Native people in construction work and the value of and interest shown in training programs designed to develop local manpower for the long-term jobs that were created. The Proponent shall take into account the reports prepared by the James Bay Employers' Association.

624. Employment barriers to Natives shall be identified and specific corrective measures proposed. These barriers shall include but not be limited to the use of French in the workplace, restrictions resulting from collective agreements, employment regulations in the construction sector, and the training requirements of the Native population.

HYDROLOGICAL MANAGEMENT AND ECOSYSTEM MAINTENANCE:

625. The Proponent shall discuss policies and commitments regarding the management and control of water levels in rivers where flows are to be decreased, in order to maintain viable ecosystems. The measures aimed at regulating or mitigating the effects of backflow and flooding along banks in areas where flows are to be increased shall also be discussed. A review of erosion control measures and other measures shall also be provided. The Proponent shall carry out the same type of analysis regarding reservoirs.

626. The Proponent shall explain plans for the construction of dikes or dredging to restrict flooding and shall present the impoundment schedule, including the uncertainty inherent in such a schedule. The possible environmental benefits of these plans shall be outlined.

627. In reservoirs, and in the Lac Bienville area in particular, the Proponent shall discuss plans to control water levels via containment measures and shall outline mitigating measures where waterfowl and other resources are vulnerable to this type of development.

628. With regard to impacts on fish and other wildlife, the Proponent shall address at least the following:

1. protection and development of aquatic habitats;

2. opening of new fishing areas;

3. formulation and evaluation of methods for implementing an intensive harvest program, prior to filling the reservoirs and forebays upstream, to enable the recovery and relocation of wildlife;

4. a comparative and detailed assessment of mitigative strategies designed to control the production of methylmercury and its bio-accumulation in fish, waterfowl and marine mammals;

5. development of spawning beds, taking into account reservoir operations and the various species concerned, specifying design and location criteria;

6. implementation of measures to allow for fish transport through the turbines and to control fish mortality;

7. formulation of a reservoir management policy designed to ensure the protection, diversity and productivity of fish stocks in the reservoirs. To this end, the Proponent shall discuss links between reservoir design and operation criteria on the one hand and fish community structures and reproductive strategies on the other; the Proponent's analysis shall include a clear description of the constraints inherent in managing reservoirs and containment bays as well as an explanation of the areas of uncertainty that should be considered in developing these strategies;

8. establishment of an environmental studies program designed to improve the level of information available on the freshwater seal population of the Lacs des Loups Marins;

9. recovering wood debris from reservoirs; and

10. maintenance of minimum discharge.

RESTORATION AND PROJECT ADMINISTRATION:

629. With regard to clean-up measures, restoration of degraded areas and resources and project administration, the Proponent shall develop strategies that address the following:

1. clean-up of sectors that could be flooded and which include waste items, particularly barrels, that could pose a threat to the environment;

2. periods when construction must be modified in order to protect fish spawning, waterfowl migration, caribou migration, etc.;

3. the proposed restoration program and the various methods available for restoring and redeveloping sites which were stripped or otherwise disturbed by construction activities;

4. if temporary roads prove necessary, the Proponent shall indicate the re-naturalization modes selected. The Proponent shall also indicate the measures to be implemented for decommissioning these roads and other infrastructures and for restoring the affected watercourses;

5. the administrative status of permanent roads, during and after construction; the Proponent shall indicate which department or organization will control and maintain these roads and control access to the territory;

6. the possibility of adjusting work schedules to accommodate traditional hunting activities, especially in Manitounuk Sound;

7. long-term responsibility for the implementation of the mitigative measures should project infrastructure or other types of equipment cease to be under the Proponent's control; and

8. clean up and renewal programs related to material and waste at the end or during the construction periods and operation.

RESIDUAL IMPACTS AND COMPENSATORY MEASURES:

630. Residual impacts are those physical, social and economic impacts for which no mitigative measures can be established or that remain even after implementation of mitigative measures, including the environmental impacts of such major installations as dams, dikes, access infrastructures, and transmission line corridors which permanently alter the natural environment.

631. The Proponent shall identify the nature and scope of all residual impacts of the proposed project regarding both the construction and operation phases of the complex, referring to the same criteria used to identify the original impacts in order to facilitate comparison between the two groups of impacts. The Proponent shall present residual impacts in the form of an overview that will enable compensatory measures to be identified.

632. There is often a fine line between mitigative and compensatory measures. Some mitigative measures identified above may also be described as compensatory measures. It shall be the Proponent's responsibility to distinguish one from the other in the presentation of the

EIS.

633. The Proponent shall clearly describe its policy concerning compensating the Native population for the construction and operation of the proposed project, as well as for its impacts. The Proponent shall indicate how this policy would be applied with respect to the proposed project and in particular shall identify which persons or groups would be compensated.

634. The Proponent's policy regarding compensation for the Native population with respect to any unforeseen impacts of the proposed project discovered after mitigation and compensatory measures had already been determined shall also be indicated.

701. If the project is approved and implemented, the Proponent shall be responsible for mitigating, compensating and managing any impacts that might arise. Some of these effects will have been predicted in the EIS; others may only be determined through experience. The Proponent shall thus describe how impacts will be determined, validated and responded to over successive stages of the project's implementation. Action programs shall provide for surveillance of practices and procedures during the construction phase; monitoring of biophysical, social and cultural conditions at critical stages of implementation; and long-term management of the project and its impacts throughout the life of the project.

702. The surveillance, monitoring and long-term management programs involve varying degrees of collaboration with certain agencies, organizations and authorities other than the Proponent. The Proponent shall identify the participants involved in various processes during the life of the project, the protocol and institutional frameworks necessary for their coordination, the threshold for triggering action for all monitoring requirements, and shall indicate how and by whom this action can be activated. The Proponent shall ensure that those concerned, notably the Inuit and the Cree, participate in the proposed mechanisms, and shall facilitate the circulation of collected information.

703. Actions contemplated for the operational phase of the proposed Great Whale project should be informed by and make reference to the experience gained through the La Grande project. The Proponent shall submit an assessment, along with comments from the Natives, of the environmental monitoring performed for the first phase of the La Grande complex, including an evaluation of how the results of this monitoring enhanced the understanding of the ecosystems, and how the information produced was linked to action with respect to specific remedial or compensatory measures, and specific project management decisions.

704. Surveillance, monitoring and long-term management programs shall be designed with sufficient flexibility so they may be modified in light of new information and unforeseen events.

SURVEILLANCE:

705. Environmental surveillance involves the general supervision of project construction to ensure that the conditions of authorization and all environmental laws, regulations and codes are respected.

706. The Proponent shall identify specific surveillance measures to be implemented, the environmental code to be applied, as well as the contractors' obligations arising from environment-related provisions in their contracts.

707. The Proponent shall describe the measures to be taken to ensure that on-site personnel are well-informed with respect to Native rights and traditional lifestyles.

708. A detailed description of the Proponent's operating manual shall be provided. The Proponent shall also describe in detail the process to be employed in the surveillance of activities involving the use of explosives, including the control measures designed to ensure this surveillance, the management procedures for hazardous products and waste and for fire surveillance, and the emergency intervention measures to be used during and after construction.

MONITORING:

709. Environmental monitoring refers to the study of conditions both during and after construction so as to determine whether or not environmental impacts are as anticipated. The objectives of the monitoring program are to seek a better understanding of the nature of impacts; to help improve methods of anticipating the impacts of future development projects; and to assess the effectiveness of the measures and the need for changes in operating procedures. The knowledge gathered by the Proponent shall be applied to improve mitigative or compensatory measures, operating procedures and the long-term management plan. The Proponent shall thus describe how all of the impacts predicted in response to Chapter 5 of these Guidelines, as well as any unanticipated impacts that might arise, will be monitored.

710. In addition, should the project be approved, the environmental monitoring program shall complete the gathering of the baseline data required to describe original environmental conditions and shall contribute to the study and management of cumulative impacts generated by major hydroelectric developments.

711. The proposed monitoring program shall reflect the experience gained through the La Grande projects and other comparable hydroelectric complexes and subsequent efforts to monitor their impacts. This proposal should include descriptions and, where appropriate, explanations of the changes made to the methodology used in the La Grande (1975) complex environmental monitoring program.

LONG-TERM MANAGEMENT:

712. The Proponent shall indicate how the proposed project and its impacts will be managed over time; which agencies and organizations will be involved in particular processes at various times in the life span of the project; and how measures prescribed at the time of the submission of the impact study will combine with adaptive responses in the future to ensure that the project remains consistent with sustainable and equitable development efforts in the region.

713. The Proponent shall identify how the operation, utilization, development, possible rebuilding and eventual dismantling of certain installations will be handled in accordance with the needs of the Proponent, the Native people and other users of the territory. Accordingly, the Proponent shall indicate whether some of the installations, including all of the access infrastructures, may be used as they are or may be converted to other purposes, by other proponents or by the Native communities, or if they must be dismantled at the end of their useful life. The proposed means of restoration of the area that could be affected by the proposed project shall also be presented.

The EIS presents a discussion of a set of measures in the areas of mitigation, short-term management, surveillance and monitoring. Most of the measures concerning the biophysical environment are site-specific and are based on the experience acquired at the La Grande complex. However, there is no general appraisal of the environmental monitoring and mitigation at the La Grande complex, preventing an evaluation of their effectiveness. Furthermore, the use in the EIS of empirical data acquired at the La Grande complex is not consistent, preventing a systematic evaluation of their appropriateness for the Great Whale complex.

For those empirical conclusions stemming from the experience acquired at the La Grande complex which it chooses to apply to the Great whale Complex, the Proponent shall indicate why that knowledge is applicable to the region; for those it chooses not to apply, it should indicate why that knowledge is not applicable. Lists of impacts that would be addressed by these measures, of those impacts presumed to be entirely or partially mitigated, and of residual impacts that would remain after mitigation should be presented.

The discussion in the EIS of long-term management does not address the need for a management strategy and plan for the territory, including the conservation of the northern environments and development of the territory. As one example, transportation infrastructures, such as roads and airports, will open the territories of Northern Quebec, resulting in irreversible impacts. The eventual transfer of the Proponent's responsibilities with regard to roads, airports, or any other infrastructure of a permanent nature is therefore of critical concern.

The Proponent shall provide evidence of consultation or collaboration with local populations, government agencies, or with other sources of knowledge (i.e., researchers, NGOs, Universities), whether in the area of transportation, health, regional development, resources. The Proponent shall demonstrate how consultation processes with the local populations and other concerned groups will ensure that their views, values and goals are incorporated into the mitigation and monitoring measures and into the long-term management of the proposed project.

Public Review of the Proposed Project and Presentation of the EIS

GUIDELINES paras. 101 to 106 and 138 to 141

l01. These guidelines are issued for the preparation by the Proponent, Hydro-Quebec, of an Environmental Impact Statement (EIS) for the proposed Great Whale River hydroelectric project. "Environment" is meant to include both the biophysical and social milieu. The expression "Environmental Impact Study" is therefore equivalent to the expression "Environmental and Social Impact Statement" as mentioned in the James Bay and Northern Quebec Agreement (JBNQA).

102. These guidelines have been prepared by four environmental assessment review bodies - the Evaluating Committee, the Kativik Environmental Quality Commission, the Federal Review Committee North of the 55th Parallel and the Federal Environmental Assessment Review Panel. Each of them has the mandate to issue guidelines for the EIS of the proposed Great Whale River hydroelectric project. However, these bodies, while working independently, have coordinated and harmonized their efforts in accordance with the Memorandum of Understanding (MOU) signed on January 23, 1992 (Appendix 1).

103. In accordance with Sections 22 and 23 of the JBNQA, Chapter II of the Environment Quality Act and the federal Environmental Assessment and Review Process Guidelines Order, the Proponent must produce an EIS in conformity with these guidelines. The MOU confirms this requirement. The EIS must comply with all the provisions of the Regulation Respecting Environmental and Social Impact Assessment and Review Procedure Applicable to the Territory of James Bay and Northern Quebec (c.Q-2, r.11), as well as all other applicable laws and regulations.

104. These guidelines include all questions addressed to the Proponent by the bodies listed above. They also incorporate other issues that were raised during public consultations, as well as in the aforementioned MOU. Each review body will, in its report, recommendation or decision, address those matters that fall within its jurisdiction.

105. The Provincial Review Committee, the Kativik Environmental Quality Commission, the Federal Review Committee North of the 55th Parallel, the Federal Review Committee South of the 55 th Parallel and the Federal Environmental Assessment Review Panel will evaluate whether the EIS is complete and in conformity with these guidelines. Following public hearings, the review bodies will determine the acceptability of the proposed project, and if it is found to be acceptable, under what conditions. These decisions or recommendations shall be transmitted either to the administrators or directly to the appropriate agencies, according to the mandate of the respective bodies.

PURPOSE OF THE GUIDELINES AND PROJECT DEFINITION:

106. The purpose of this document is to set forth guidelines that the

Proponent must follow in presenting the EIS on the proposed Great Whale

River hydroelectric project. It is incumbent upon the Proponent to prepare

a complete EIS that includes sufficient basic data and analyses for a

complete assessment of the anticipated impacts and their repercussions.

ORGANIZATION OF THE GUIDELINES:

138. These guidelines require the Proponent to justify the proposed project (Chapter 2), to describe the biophysical and social environment (Chapter 3), to describe the proposed project and variants (Chapter 4), to predict the changes and impacts that would result from it (Chapter 5), to describe the mitigative measures that the Proponent proposes to undertake if the project is approved, along with any compensatory measures for residual impacts (Chapter 6), and to describe the management and monitoring of the project over time, including measures to enforce compliance with the terms that may be set out in the authorization (Chapter 7).

PRESENTATION OF THE EIS:

139. The Proponent shall provide an EIS which is complete, including references to scientific works and to the Proponent's sectorial studies. The EIS shall respect the structure of these Guidelines. All scientific and sectorial studies shall be rendered current and shall be numbered and dated prior to their submission to the review bodies for examination. Maps, other than those used for orientation and context, shall be contained in a separate volume. The EIS shall be supplemented by a series of complementary documents providing technical and scientific support and containing appropriate bibliographic references. The Proponent shall prepare and incorporate in the EIS a complete and detailed annotated bibliography of all studies and reports carried out in relation to the proposed project since 1975, and shall make such studies and reports available to the review bodies.

140. The Proponent shall submit a table of conformity in an appendix, showing where each requirement of these Guidelines has been satisfied.

141. The EIS shall be published simultaneously in French and English. The complete document or an abridged version of it shall be made available in Cree and Inuktitut, in written and audiovisual format. The abridged version shall be sufficiently detailed to permit eyaluation of the proposed project by the Cree and the Inuit. Maps should indicate common and accepted place-names usually referred to by the local populations in their own language, in addition to the French and English names.

The Proponent's EIS will be a key tool in the Review Bodies' and the public's consideration of the proposed project. The extent to which it is complete, current and accessible is therefore of great importance.

The EIS is a voluminous document, in which precise information is often difficult to locate. The compartmentalized structure of the study, the sequential treatment of details, the fact that discussions of impacts are spread throughout the document, and the complexity or lack of precise references to support studies, make consulting the work ponderous and complex. The sheer mass of documents and their disparate numbering system further compounds the task - a point emphasized by many participants in the consultation process.

The form, structure and content of the EIS that will result from the present conformity and quality review are of critical concern to the Review Bodies, particularly as they affect the ability of the public to participate in the process during the project evaluation stage of the environmental review.

The Proponent shall respond to all the specific requirements of this report. However, in order to avoid the production of an additional quantity of volumes containing lists of specific answers that would have to be considered in conjunction with the numerous volumes already submitted, the Proponent is required to submit a single document or set of documents jhat will render the EIS current, complete and accessible. The document or set of documents shall incorporate and integrate responses to this Report with those already tabled in response to the GUIDELINES. This document or set of documents shall become the principal reference during the project evaluation stage of the environmental review.

Consequently, in the document or set of documents that will be submitted, the Proponent is directed to present, in an integrated manner, responses to the requirements of the GUIDELINES and to the present Chapter, while answering the specific requirements contained in Chapters 2-7.

Where the quantity or depth of technical detail or the amount of necessary data justify such an approach, the Proponent may include technical appendices in its responses to specific requirements of this report.

The Review Bodies stress the importance they accord to an integrated environmental analysis which brings together specific impacts and examine their cumulative effects on particular elements of the ecosystems or societies. In responding to the requirements of the present report, the Proponent shall apply the principal assessment criteria, and focus on the main integrative issues of the GUIDELINES.

The resulting document or set of documents shall follow the structure and sequence of the previously issued GUIDELINES and this report. The preparation of seven appropriately sized volumes, one for each chapter of the GUIDELINES and this report, would be an appropriate manner for the Proponent to meet this requirement.

The document or set of documents shall be produced in French and English, along with a summary in all four languages used in the study area and a culturally appropriate audiovisual presentation of the Proponent's information. All should be released simultaneously.

The document or set of documents shall contain a single full and appropriate list of references. References shall be specific and shall include all previous sectoral studies whose results are used or discussed.

A new Table of Conformity that is accurate and complete shall be provided, with appropriate referencing to the requirements of both the GUIDELINES and the present conformity report.5

1. Pursuant to the Memorandum of Understanding signed on January 23, 1992, by the governments of Quebec, Canada, the Cree and the Inuit of Quebec (MOU), these Review Bodies are: the Provincial Review Committee (COMEX; referred to in the James Bay and Northern Quebec Agreement as Provincial Environmental and Social Impact Review Committee); the Kativik Environmental Quality Commission (KEQC); the Federal Environmental and Social impact Review Panel North of the 55th Parallel (COFEX-North); the Federal Environmental and Social impact Review Panel South of the 55th Parallel (COFEX-South); and the Federal Environmental Assessment Panel (FEAP) of the proposed Great Whale project (see paragraph 105 of the GUIDELINES).

2. The GUIDELINES were prepared by four Review Bodies, namely the Provincial Evaluating Committee (COMEV), KEQC, COFEX-North and FEAP (see paragraph 102 of the GUIDELINES).

3. On July 26, 1994, the Proponent released a report that it had commissioned on its EIS. In that report of July 1994, the Proponent's EIS was evaluated independently of the GUIDELINES upon which this present conformity report is based.

4. Pursuant to the laws and regulations under which they function, it should he noted that the four Review Bodies constituted according to the provisions of the James Bay and Northern Quebec Agreement (COMEX, KEQC, COFEX-North, and COFEX South) make recommendations to the Provincial and Federal Administrators regarding any requirements of the Proponent and procedures for the present environmental review. All references in this report to requirements of the Proponent should be intererested accordingly. Pursuant to the laws and regulations under which it functions, the Federal Environmental Assessment Panel (FEAP) addresses any requirements under the GUIDELINES and this report directly to the Proponent.

5. For the purpose of clarity, the requirements of this Chapter have not been numbered. For the convenience of the process, the Proponent may in its table of conformity, refer to the requirements of Chapter 1 of this report using numbers 1.01 through 1.17.

CHAPTER 2

PROJECT JUSTIFICATION

The justification of the proposed project involves, first, assessing the need for additional energy resources, and then comparing the various supply-or demand-side resources that could be developed to satisfy it. A least-cost analysis was to demonstrate that the best solution for meeting the anticipated demand growth includes the Great Whale project, not only for the demand growth scenario judged most likely, but also for other plausible scenarios. Moreover, the Proponent was to provide a comparative analysis of the externalities of the different energy resources available, on a quantitative basis, insofar as possible, or on a qualitative basis, where not possible. These analyses are not developed to a sufficient degree in the EIS to permit evaluation of whether or not the conclusions are well founded.

As for the data and other information on which these analyses were to be based, three areas in particular are deficient. First, the costs of generating technologies other than hydroelectricity are not presented in sufficient detail to permit a rigorous least-cost analysis. Second, the discussion of ways to reduce energy demand which are cost-effective in comparison to new generating stations is incomplete. Finally, a financial analysis which would make it possible to understand the economic impacts of different resources choices under different plausible scenarios is not presented in sufficient detail.

The following requirements of this Chapter are addressed to the Proponent to provide the Review Bodies with the information needed to complete their analysis of the Proponent's justification of the proposed project.

2.01 An unavoidable problem in any energy planning analysis concerns updates. Planning data change constantly, and some updates are inevitably necessary. Most of the data contained in the justification section of the EIS date from 1992. The response to the present report shall include all updates which have been carried out. Later in the process, it will be essential that updated information be made available to the Review Bodies from time to time.

2.02 Throughout the project justification section, provide references to technical documentation when appropriate, and make these documents available to the Review Bodies.

Introduction

GUIDELINES paras. 201 to 212

201. The justification of the proposed project must address in detail the following six issues related to energy planning, namely:

1. load forecasting and analysis;

2. alternative solutions to satisfy the anticipated demand;

3. system-planning issues;

4. the evaluation of different equipment program scenarios;

5. alternative designs of the proposed project (major project variants);

6. financial forecasting and rates analysis, including the analysis of different scenarios and rate structures.

202. Prior to evaluating the potential environmental impacts of the proposed project, the Proponent must first demonstrate that there is a need for new or additional electrical generating capacity and energy resources, and that the best scenario for meeting that need includes the proposed project. This involves first assessing the need, and then comparing the various resources that could be developed to satisfy it. These alternatives include the construction of new generating capacity and purchases from neighbouring systems (supply-side resources), as well as the implementation of new programs to reduce demand growth (demand-side resources). The Proponent shall present an overview of the energy policy adopted by the Government of Quebec. The Proponent shall in particular present the objectives of this policy with respect to electricity, and shall then explain how the proposed project fits into this context and into the Proponent's development plan.

203. The Proponent is asked to provide basic information regarding load forecasts, supply- and demand-side resources, overall system characteristics and financial parameters. This information shall be combined and analyzed in such a way as to determine the best sequence of resource acquisition for meeting projected electrical energy needs.

204. The documentation provided shall include all information and material necessary to assure a high standard of expert review, including data, assumptions, sources, models and methodologies used, which shall be transparent and reproducible. Financial information shall be presented in constant dollars of a single reference year.

205. The analysis shall cover two time periods. The planning period

covers the years 1992-2022. The historic period includes the years 1970-

1991.

206. The Proponent shall carry out a least-cost analysis regarding the selection of supply- and demand-side resources to meet its load forecasts. These shall be based on forecasts both for capacity and energy needs (paragraphs 213 to 222) and a description of all available supply- and demand-side resources (paragraphs 223 to 251), together with the operational information needed to compare the projects (paragraphs 252 to 258).

207. Direct and indirect costs per unit of capacity and energy must be specified for each resource. Combining this information, the Proponent shall order the various supply-side and demand-side resources in order of increasing cost, both for capacity and for energy.

208. Costs related to transmission losses and reserves shall be apportioned among supply-side resources, except for certain reserve provisions, which should be included in demand-side costs. Furthermore, the Proponent may choose to add a percentage to the effective cost of supply-side alternatives for the purpose of favouring energy conservation and efficiency.

209. The Proponent shall determine the optimal sequence of resource acquisitions for each demand scenario, explicitly addressing the role of uncertainty in forecasting future loads and in the choice and operation of future resources. The Proponent shall explain the system optimization models used and their application to the selection of resource acquisitions, as well as the methods and models used to address uncertainty. Detailed sensitivity analyses with regard to changes in supply and demand assumptions shall be provided.

210. Other factors may play a role in the selection of resources, such as potential planning risks or benefits related to fuel diversification or planning flexibility. The Proponent shall explain how its system optimization procedures take such factors into account.

211. The analysis described above will demonstrate the least-cost solution to each demand-growth scenario, but does not take into account any factors which are "external' to the Proponent's balance sheet. Such external costs, or "externalities," include social and environmental impacts as well as broader effects such as job creation and economic stimulation. Some of these externalities, whether related to supply- or demand-side resources, lend themselves well to quantification, others not. The Proponent shall present a series of tables comparing the impacts of each supply- and demand-side resource discussed in paragraphs 223 to 251 for each potential positive and negative externality. To the greatest extent possible, the Proponent shall make this comparison on a monetary or quantitative basis; however, for those impacts which do not lend themselves to quantification, the comparison shall remain qualitative.

212. The costs and benefits associated with power production are seldom incurred by people from the same geographic region and cultural group. In order to evaluate the extent of this potential inequity, the Proponent shall compare the costs and benefits of project development or non-development for the Native populations and the population of southern Quebec.

According to the EIS, the Proponent prepares an installation plan by comparing the various generation expansion programs on the basis of total present value of costs. While this process is described, its application in the case of the proposed Great whale project is not fully explained.

2.03 Provide the most recent comparative analysis of generation expansion programs corresponding to various demand scenarios and various means of meeting demand. For each scenario, provide the in-service dates for each resource and total discounted revenue requirements, broken down into each of the components mentioned in section 7.3.3 of Part I, Book 2, Volume 1 of the EIS, and describe the steps taken to ensure that the particular resource combinations evaluated represent the least-cost combinations for each strategy under consideration.

2.04 In order to determine whether or not the least-cost solution to meeting the future energy demand includes the Great whale project, provide scenarios relying more heavily on conservation, gas-fired resources, cogeneration, wind, and purchases from neighboring utilities and from private producers within Quebec. Include different combinations of cost-effective energy efficiency programs, to ensure that demand-side resources are treated in a similar manner to supply-side resources. For some scenarios which include the Great Whale project, evaluate the impact of removing it from the generation expansion program. Provide detailed result, including present value system cost, for each scenario.

2.05 For each of these scenarios, evaluate present value system cost for high, medium and low demand growth. Using the probability distribution associated with the load forecast, determine the expected present value system cost for each scenario.

A key element in modern energy planning, specifically addressed in paragraph 209 of the GUIDELINES, is the need to maximize the robustness of the selected resource strategy - to find the strategy which permits the system to respond at least cost to a wide range of possible future events. The EIS does not contain sufficient information or analysis to permit an appreciation of the robustness of the selected strategy, which includes the Great Whale project, or of alternative strategies. While a full range of possible load growth scenarios is included in the load forecast, the analysis of resource needs presented is based exclusively on the medium load growth scenario.

2.06 Provide a system analysis that demonstrates the flexibility of different types of generating resources to adapt to the uncertainties identified in the EIS (load growth, runoff, market development, demand-side management penetration rates, interest and inflation rates) at least cost and at lowest risk.

2.07 Provide sensitivity or Scenario analyses demonstrating the robustness of the various resource acquisition sequences for variations in all key parameters, including economic growth, load growth, inflation,

interest and exchange rates, runoff and penetration of energy efficiency programs. Results shall be described in terms of both system costs (revenue requirements) and energy balance (changes in anticipated surplus or deficit, and system reliability).

2.08 As noted earlier, documents released at the Technical Information Exchange Group (outputs from the NEPTUNE model) indicated that the need dates for the Great Whale project could range from 2001 to later than 2031, depending on the load growth scenario. Provide a detailed analysis of the range of possible need dates for the Great Whale project, explaining all assumptions. This range shall reflect all uncertainties recognized in the load forecast, in the export and other market development programs, etc.

2.09 Explain how system optimization procedures evaluate and account for risks or benefits related to fuel diversification or planning flexibility.

2.10 Provide an analysis of a full range of possible load growth paths once construction has begun. The analysis shall include best- and worst-case scenarios, taking into account the full range of uncertainty concerning load growth described in the EIS. For each scenario, indicate dates of decisions taken (construction start, speed-up, slow-down), the dates of commissioning of GB 1, GB 2 and GB 3, the total construction costs and unit costs, taking into account the costs of any speed-ups or delays, the expected energy balance on commissioning, and the economic impacts of any surplus or deficit, and all assumptions used.

2.11 Evaluate the impact of conservation and energy efficiency programs on the flexibility and robustness of the resource plans, and explain why the selected level of demand-side resources is considered optimal.

2.12 List and describe the input and output variables of the NEPTUNE model, described in Chapter 2 of Methods, Volume 1. Provide NEPTUNE outputs (energy statistics, costs and revenue) for each scenario examined in responding to the present report specifying all assumptions and input variables.

Externalities

GUIDELINES paras. 211 and 251

211. The analysis described above will demonstrate the least-cost solution to each demand-growth scenario, but does not take into account any factors which are "external' to the Proponent's balance sheet. Such external costs, or "externalities," include social and environmental impacts as well as broader effects such as job creation and economic stimulation. Some of these externalities, whether related to supply- or demand-side resources, lend themselves well to quantification, others not. The Proponent shall present a series of tables comparing the impacts of each supply- and demand-side resource discussed in paragraphs 223 to 251 for each potential positive and negative externality. To the greatest extent possible, the Proponent shall make this comparison on a monetary or quantitative basis; however, for those impacts which do not lend themselves to quantification, the comparison shall remain qualitative.

251. For each supply- and demand-side resource, the Proponent shall provide a characterisation and qualitative estimate of its externalities, both positive and negative. For the proposed Great Whale River hydroelectric project, these will be drawn from the analyses required in Chapter 5 of these guidelines. For other resources, they shall be determined according to the best information available to the Proponent. For each resource, the Proponent shall also provide a description of the social and economic impacts on Quebec as a whole, including job creation (including the nature, type and number of direct, indirect and induced jobs generated, their duration, which groups are most likely to benefit from these jobs, and where they will occur), macro-economic effects (e.g., degree of economic stimulation, effects on public access to credit) and independence from out-of-Quebec energy sources. For thermal generating technologies, description of externalities shall include potential negative impacts related to air emissions and discharge of heated water, as well as any other adverse environmental effects. For major purchases, and to the extent that such purchases are tied to specific resources, the Proponent shall provide information on those resources and characterize their externalities.

It is clear from other documents prepared by and for the Proponent that considerable progress has been made following the submission of the EIS toward a systematic analysis of the externalities of the various supply- and demand-side resources available to meet new energy demands.

2.13 Provide a comparative analysis of the different resources discussed in the EIS. Summarize this analysis in tabular form.

a) To the greatest extent possible, make this comparison on a monetary or quantitative basis; however, for those impacts which do not lend themselves to quantification, the comparison may remain qualitative.

b) The methodology used for this comparison shall be explained, and its selection over other accepted methodologies shall be justified.

c) For the Great Whale project specifically, because its impacts are not summarized in the EIS in a way that could be used as inputs in an externality analysis, provide an integrated synthesis table of its environmental impacts, including social impacts and cumulative effects on Hudson Bay and the Belcher Islands.

d) For hydroelectric resources in general, the analysis of the environmental impacts of hydroelectric projects shall include all their major environmental and social impacts.

e) With respect to thermal power plants, it is not entirely clear which cost and emission data in the EIS refer to plants with emission-control equipment and which do not, and which thermal efficiency is used for this purpose. This comparative analysis of externalities shall include thermal resources with the most advanced and available technology and the one with the fewest impacts. Analysis of new facilities shall take into account the emissions of facilities they directly displace.

2.14 Provide analysis of greenhouse-gas emissions of the various types of energy resources, including most recent assessments of emissions from thermal technologies and hydroelectricity. Discuss approaches used by other utilities to mitigate or otherwise address the emission of greenhouse gases, in particular that of greenhouse gas offsets.

2.15 The EIS states that "the total project cost already makes provision for environment-related externalities." Explain to what extent mitigation and compensation programs effectively internalize external costs of hydroelectric developments.

2.16 Present a more systematic analysis of the economic spinoffs of all resources analyzed in the EIS, including energy efficiency resources and analyze the economic advantages for Quebec as a whole of the various energy resources under consideration. This analysis shall include direct and indirect jobs, value added and jobs for each main Sector of the economy, imports, and government revenue, and shall take into account the possibility that manufacturing of equipment for other supply-or demand-side resources might also take place in Quebec, if the demand were sufficient. It shall also address the potential positive economic impacts of cogeneration on the host industries. It shall also provide detailed information concerning jobs sustained for wood-burning cogeneration plants. Finally, it shall include a quantitative analysis of the economic and employment impacts of changes in electricity price.

2.17 The GUIDELINES require the Proponent to determine the optimal sequence of resource acquisitions. Describe how the results of the externality analysis were integrated into the least-cost analysis, and present the results of this process. If consideration of externalities has altered the preferred sequence of resource acquisitions from that dictated by purely technical and economic considerations, this shall be clearly indicated, and the rationale fully described.

Load Forecast

GUIDELINES paras. 213 to 222

LOAD FORECASTING:

213. The assessment of need for new electrical generation begins with load forecasting. Load forecasting involves projecting economic growth and technological changes, sector by sector, to predict future needs for electrical energy. Traditionally, load forecasts are broken down into three major sectors: residential and farm, general and institutional, and industrial, and into several scenarios, ranging from low to high growth. The Proponent shall present an analysis of the factors influencing consumption and changes in consumption patterns in each sector, as detailed in paragraphs 215 to 218.

214. Other elements of the load forecast depend not only on a detailed analysis of economic variables, but also on decisions made by the Proponent and on energy policy, which is determined by the Government of Quebec. Such elements include future export and risk- and profit sharing contracts. These shall therefore be addressed separately, and the scenario analyses presented in subsequent sections shall explicitly account for their contribution to demand.

Current commitments:

215. The Proponent shall provide its most recent domestic load forecasts, both for power and for electricity. These forecasts shall include regular needs and existing export and risk- and profit-sharing contracts, including capacity options. The forecasts shall be broken down into at least three scenarios (high, medium and low), and the relative probabilities of each scenario shall be estimated for each sector (industrial, general and institutional, residential and farm).

216. The Proponent shall provide data for both the planning period and the historic period, with descriptions of all econometric and end-use models used to predict power and electricity demand for each sector, including the methodology and theoretical bases that underlie each model as well as an assessment of their strengths and weaknesses. An explanation of the input variables and assumptions for each sectoral model shall also be provided.

217. The Proponent shall present the most recently available forecasts for residential and farm, general and institutional, and industrial sectors. The Proponent shall also provide recent forecasts from neighbouring utilities (Ontario, New Brunswick, New York and New England) and agencies such as the Northeast Power Coordinating Council (NPCC) or the National Electric Reliability Council (NERC) and, where their forecasts differ substantially from the Proponent's, explain the reasons for the differences.

218. The documentation of the Proponent's forecasts shall include the following information:

1. information on penetration and saturation for each major end use (e.g., space heating, water heating, electrical motors, electrolysis, smelting and refining, cooling and lighting), including expected technological developments (new end uses and electro-technologies) and their effects on demand;

2. the most recent forecast of load factors and load duration curves, with a discussion of how they are determined, the projected change, and the factors responsible for this change;

3. assumptions concerning weather-sensitive load, taking into account the best available estimates of local and global climatic trends during the planning period;

4. macro-economic indicators, including GDP, inflation, interest and exchange rates. If the estimates are from a third party, the Proponent shall identify the source;

5. demographic projections, including the variables used in the models;

6. assumptions concerning any anticipated sales of surplus energy within Quebec over the planning period;

7. a discussion of price elasticity in the Proponent's markets, how the load forecasts take into account anticipated changes in rate levels and structures over the planning period;

8. identification of market segments where there is competition with other energy providers, and an analysis of the impacts of price variations on sales within these markets;

9. determinants of demand and growth for each subgroup of the industrial sector forecast, with documentation and rationale of the explanatory variables selected, addressing specifically the pulp and paper industry (describing major categories of output and pulping methods) and the energy-intensive industries (including industry price, production and profit levels and the timing of new production capacity additions);

10. an analysis of the Proponent's electrotechnologies program, including external forecasting sources utilized and discussing its penetration and its impacts on overall demand and industry costs; and

11. a description of the effects of any energy efficiency programs other than those of the Proponent and of any existing or anticipated appliance or building codes, to the extent that they are included in the load forecast.

Additional demand:

219. The Proponent shall indicate the impact of a range of export and risk- and profit-sharing contract levels and scenarios on load forecasts.

220. The Proponent shall assess relevant export markets and existing and anticipated export contracts and opportunities, and any scenarios which have been developed regarding export loads; explain the criteria used to determine whether to enter into new export contracts and/or renegotiate existing contracts; and provide projected annual sales figures (energy and capacity) and expected revenues for all negotiated or anticipated exports. The Proponent shall also explain the comparative advantages of export of surplus and firm energy, providing a detailed economic analysis concerning the costs and benefits of each.

221. The Proponent shall explain its financial framework for analysing the impacts of export commitments on system planning and discuss the effects of the scenarios described above on resource acquisitions.

222. The Proponent shall then present and explain any anticipated additional risk- and profit-sharing contracts, including an analysis of the expected impacts of recent U.S. trade rulings on the risk- and profit-sharing contract program.

2.18 Much of the discussion of load forecasting in the EIS does not cover the full planning period, but deals only with the period 1992-2010. The load forecast and all discussions of future loads shall cover the entire planning period (1994-2022), and shall indicate expected needs for both energy and capacity for each year and for each scenario. Whenever this is not possible, explain the reasons why a shorter planning horizon was used.

2.19 Provide a table showing updated forecasts of energy needs over the full planning period (1994-2022). The breakdowns shall be annotated, including full explanations of all "other" categories. Indicate regular domestic needs, existing export contracts, existing risk- and profit-sharing contracts, additional anticipated firm and non-firm exports, reserves and losses, and any other elements which contribute to total energy requirements.

2.20 Present low and high load growth scenarios for each sector, with detail and analysis equivalent to that provided for the medium growth scenario. Provide the probabilities of occurrence that loads will fall between the low and the high-growth scenarios for each year of the planning period.

2.21 Conduct and present a sensitivity analysis of the load forecast performed with respect to the following parameters: economic and demographic growth, oil and natural gas prices, and interest and exchange rates. Show how the medium, low and high load forecast presented in the EIS will vary if the parameters exhibit extreme behavior.

2.22 With regards to both end-use and econometric models, describe how they are calibrated, and with what data.

2.23 Provide a discussion of how the effect of existing energy efficiency programs other than those of the Proponent are accounted for in the load forecast.

2.24 Discuss any actions that the Proponent intends to take in the coming years to promote and facilitate the adoption of improved building codes and energy efficiency standards. Should these efforts prove successful, describe the effects they would have on energy needs.

2.25 Compare forecasts of macro-economic indicators used in the EIS with those of other standard sources, such as Statistics Canada and the Bank of Canada.

2.26 Discuss how meteorological variability is accounted for in system planning. Provide data and weather-adjusted loads for the historic period.

2.27 The discussion of price elasticity in the EIS is not adequate to permit an understanding of how electricity consumption changes in response to changes in its price, or how changes in the relative price of electricity and natural gas would affect market share and hence electric loads. Provide a detailed discussion of cross-elasticity between electricity and natural gas, and discuss the impact on load growth of different price scenarios for electricity and natural gas.

2.28 Using short- and long-term price elasticity data, illustrate the effects on load growth of a variety of possible rate-growth scenarios and of the planned changes in the rate structure to reduce cross-subsidization.

2.29 Provide additional details of the load forecast in the industrial sector. In particular, two aspects need to be further detailed. First, estimate the electricity needs predicted for developing energy intensive industries such as liquid hydrogen. Second, estimate the amount of energy required or liberated by future growth or decline (competitiveness) of energy intensive metal refining and smelting industries, including that of aluminum.

2.30 The notes to the table on the "World primary aluminum consumption and capacity after 1991" (Part 1, Book 2, Volume 2, Table 2.10) indicate that the data on world consumption and current capacity exclude China and the former Soviet bloc. Complete this table including capacity and consumption for China and the former Soviet bloc. Indicate to what extent the opening of these markets or the development of new capacity in these countries could change the forecasts of aluminum demand given in that table. Indicate the effects of these changes on the competitiveness and the development of the aluminum sector and the effect on Quebec energy demand.

2.31 For those aluminum producers under the existing risk- and profitsharing contracts, provide a range of projections of production levels and profit levels, and their implications on the timing of new production capacity additions. Discuss the likelihood of the capacity options in the risk- and profit-sharing contracts being exercised.

2.32 Provide up-to date forecasts from neighboring utilities and agencies, and explain any significant differences from the forecasts for Quebec. For each potential export market (New York State, New England, New Brunswick and Ontario), discuss future energy needs, expected supply costs and the opportunities for new exports, with references, for the full planning period. Describe expected annual export sales and revenues for the entire planning period, for firm and non-firm power and energy, according to several plausible scenarios. Describe each of the various types of short-term transactions referred to in the EIS and analyse their economic consequences and their implications with respect to resource needs.

2.33 According to the EIS, the construction of facilities would not be advanced to supply export markets without signed agreements. Discuss the relationship between export objectives and the required in-service dates for the Great Whale project and its components.

2.34 Analyze the relative costs and benefits for the Native populations and the population of Southern Quebec of accelerating the Great Whale project to meet export objectives.

2.35 In order to understand the role of surplus energy sales in Hydro-Quebec's total sales revenue, describe the level of non-firm energy sales for each year of the historic period (1980-1993), indicating the average price obtained each year, and the variables that affect energy surpluses.

2.36 Update table 8.1 of Part I, Book 2, Volume 2 of the EIS, and provide the amount of firm (guaranteed) energy for each year Update all other elements of the discussion of exports to take into account the cancellation of the 800 MW contract with NYPA.

Supply-Side Resources

GUIDELINES paras. 223 to 238

RESOURCES:

223. Alternatives for meeting new demand include both supply-side and demand-side resources. Supply-side resources include hydroelectricity (including the proposed project, other hydroelectric projects, including mini-dams and run-of-the-river projects, intensified use of developed river systems such as the La Grande, Manicouagan, St. Lawrence, etc.), thermal (fossil, biomass and nuclear), purchases from neighbouring areas (including Labrador) as well as from private producers in Quebec (including cogeneration), and other technologies, including wind, solar, geothermal. Demand-side resources include various strategies for load management and conservation, including those that involve rate design, incentives or other pricing structures.

Supply-Side Resources:

224. In order to permit comparison of a wide variety of supply-side alternatives, the Proponent shall provide general financial information such as forecasts of discount rates, financial costs, inflation and risk premiums, explaining all hypotheses and assumptions.

225. The Proponent shall provide detailed information (broken down by unit where relevant) concerning the cost, operations and timing for each of the supply-side resources mentioned in the preceding paragraph, as follows:

Energy:

1. installed power (MW), projected annual firm and non-firm electricity output (GWh), and seasonal output pattern, including specific determinants for each resource (e.g., runoff projections for hydro projects, wind strength and persistence projections for wind projects), including data, assumptions and supporting studies; and

2. availability factor, load factor and transmission losses expressed in units of capacity and energy.

Costs:

3. capital costs (direct overnight costs and financing costs during construction, broken down into generation and transmission components) and total in-service cost, allowing comparison with other resources;

4. fixed and variable operations and maintenance costs, including assumptions for waste disposal, where relevant;

5. real levelized cost per kilowatthour and per kilowatt (broken down into capital, operations and maintenance and fuel costs, when applicable), with detailed explanation of the methodology for determining that cost, and the impact of each resource addition on the total real levelized cost per kilowatthour and per kilowatt of electricity produced;

6. sensitivity analyses concerning costs as a function of the successive changes in the main assumptions underlying the calculations (inflation, wage increases, basic cost of each project, etc.) and other factors described above;

7. expected mitigation and compensation costs; and

8. a full description and basis for project schedules, including in-service and retirement dates, an analysis of schedule constraints, and factors and uncertainties affecting project schedules and potential feasibility.

Hydroelectricity:

226. The Proponent shall explain its methodology for hydroelectricity operations planning. If firm output is established by a system-wide analysis, the Proponent shall include the analysis, including models, data, and an explanation of the methodology.

227. The Proponent shall explain its policy and plans concerning the development of small-scale hydroelectric resources and the expansion and rehabilitation of existing hydroelectric facilities. This shall include a calculation of the province-wide potential for such development, according to different economic assumptions.

228. The Proponent shall present the effects on the per kilowatt and per

kilowatthour costs and on system planning of high, medium and low

runoff scenarios during the analysis period. The low runoff scenario shall

include conditions like those experienced in the La Grande region from

1984-1991.

229. For the entire hydroelectric system (including Churchill Falls), and specifically for the river basins affected by the proposed project, the Proponent shall explain and document the historical and expected value runoff (with energy equivalents) for each river basin. Documentation shall include any studies and materials used to determine probability distributions and other analyses concerning runoff variability. The Proponent shall also provide an analysis of long-term variability from historic runoff data, taking into account the best available information concerning long-term climatic trends'.

230. The Proponent shall present the implications of each design option within the selected variant of the proposed project with respect to energy and capacity output and operational characteristics such as inter-annual storage. If the Proponent anticipates substantial (multi-year) delays between distinct phases of the project, each intermediate stage shall also be considered an alternative for the purposes of this economic analysis, in order to evaluate the economic viability of the project in the event that later phases are not completed. Costs shall be specified per kilowatthour and per kilowatt, and shall be broken down into their generation, infrastructure, collector system and transmission components.

231. For each design option, the Proponent shall provide the information described in paragraph 225, where applicable, for each station within the project.

Thermal and other generating technologies:

232. The Proponent shall provide information including capital costs and heat rate (efficiency) for all thermal generating technologies under consideration, including fossil fuels, nuclear and biomass; price forecasts (per gigajoule or BTU), including purchase of reserves (when appropriate) for oil, natural gas and other fuels; and descriptions of specific pollution- control and other environmental protection technologies, including costs and impacts on emissions and other environmental effects.

233. The Proponent shall also provide studies concerning the cost, potential, and reliability for each potential resource; a survey of current and anticipated technological innovations for each technology, and their impacts on cost, capacity, utilization factors and reliability; and explicit assumptions concerning resource cost and availability of each option over the planning period, as called for in the studies and surveys mentioned above.

234. These studies shall summarize experience gained from major wind and solar projects in North America and elsewhere, and discuss their applicability to Quebec's geographic and operational context. The Proponent shall in particular discuss the issues involved in integrating wind energy into the existing system.

235. Analysis of new technologies shall be as rigorous as that of other resources. The degree of uncertainty in the supply characteristics of each type of installation shall be characterized, and the system-wide implications of integrating projects of various sizes and types shall be evaluated.

Purchases:

236. From within Quebec. The Proponent shall provide estimates for its purchases from Quebec independent producers, including type and location of resource and purchase duration, as well as an explanation of the Proponent's relevant policies.

237. Cogeneration. The Proponent shall describe its current policies concerning cogeneration, specifying what types of cogeneration can be integrated into the existing system; shall estimate the cogeneration potential, by sector and by type of industry; and shall provide an analysis of current and forecasted market potential for each one.

238. From outside Quebec. The Proponent shall describe all potential purchases from outside Quebec. For each one, the Proponent shall state the provenance, the estimated size (in energy and capacity) and duration, including commencement and/or termination dates, as well as any other relevant information.

2.37 The EIS compares different technologies for generating electricity and concludes that hydroelectricity is the most advantageous. Other technologies are considered back-up facilities. Discuss how and why this strategy would be consistent with an energy policy based on integrated resource planning.

2.38 Provide a comparative table showing, when applicable, the following information for all supply-side resources that the Proponent considers could play a role in meeting Quebec's energy needs during the planning period:

a) capital costs (in nominal and constant dollars) broken down into generation, transmission, infrastructure, pollution-control, mitigation and compensation components, and financing costs during Construction;

b) expected annual expenses, broken down into fuel costs, operations and maintenance (O&M) costs, overhead, and annualized expenses for major repairs; and

c) real and nominal levelized energy cost, including all capital and annual expenses.

2.39 Discuss how the role that natural gas could play in meeting Quebec's energy needs is assessed. Provide a detailed analysis of the costs of different types of generating facilities fueled by natural gas (combined-cycle baseload plants, single cycle peaking plants), including effects on costs of recent developments in gas turbine technology and possible system benefits resulting from integrating them into a hydro-based system. High, medium and low fuel price scenarios, and the corresponding unit costs for the electricity produced shall be compared with those of other forecasters. Provide the background studies leading to the determination of the levelized unit cost for a CCGT of 6 cents per kWh in 1992 dollars presented in the EIS. For gas price forecasts, provide data in dollars per gigajoule, in addition to or instead of the units used (cents/m3).

2.40 When several variants of a resource are presented, involving different degrees of emission control, describe each one fully, providing tables clearly indicating NOx and S02 emissions and estimated unit costs. Provide information concerning the costs of similar resources in neighboring utility systems or those used in their planning so that they can be compared to the costs given in the EIS.

2.41 Wind potential is not well defined and questions relating to the integration of wind energy into the grid are not fully addressed. Furthermore, it appears that costs of wind energy have recently changed and an update of wind costs and potentials is thus essential. Provide estimates of the wind potential in Quebec and of the expected evolution of costs over the next 10 to 20 years.

2.42 Discuss the likelihood that other technology, such as solar and fuel cell, would become cost-effective during the planning period.

Purchases

2.43 Explain the Proponent's current policies concerning cogeneration, including the amounts of cogenerated electricity the Proponent intends to purchase, and justify these amounts. Discuss the purchase price offered to private producers (discussed in Volume 4, section 13.3.6) in relation to the concepts of avoided costs, generic marginal costs and long-range avoided costs.

2.44 The possibilities of energy purchases from neighboring systems are addressed only cursorily in the EIS. Update present and anticipated market conditions regarding possible purchases of electricity from each neighboring system, including probable market prices for energy and capacity, based on the assessment of future energy needs and expected supply costs in neighboring jurisdictions. Analyze the use of purchases from neighboring systems to provide energy reliability to the system.

Demand-Side Resources

GUIDELINES paras. 239 to 251

Demand-Side Resources:

239. Part of the need for power and energy can be met by appropriately reducing or managing demand. Programs to reduce demand for peak power capacity (peak demand management) and energy (conservation) are hereafter referred to jointly by the term "demand management". Such programs may include dual energy and other types of fuel switching, alternate rate structures, and other strategies, including incentive programs to promote the development, acquisition and adoption of energy-efficient equipment, materials and practices, public education campaigns, interruptible power contracts, and regulations, norms and standards.

Current and planned demand management programs:

240. The Proponent shall describe its current demand management policy, targets, and existing and planned programs, with cost, anticipated capacity and energy savings and expected penetration rates (year-by-year) for each program, including descriptions of existing and potential interruptible power contracts, throughout their projected effective duration.

241. The Proponent shall describe all programs that have been evaluated but have not been implemented, giving the reasons for their rejection or for delay in their implementation. The Proponent shall describe the economic tests used to evaluate demand management programs, including those rejected.

242. The Proponent shall estimate annual program expenses, explain the basis used to establish appropriate spending levels, describe the proportion of expenses to be borne by various parties and the basis for annual savings estimates, and discuss the basis for setting annual targets and the possibility of modifying demand management programs to achieve higher levels of savings.

Estimating demand management potential:

243. The Proponent shall provide estimates of the technical, cost-effective, and achievable demand management potential for the duration of the planning period by end use, sector and demand scenario, along with the studies forming the basis of such estimates. Also, the Proponent shall evaluate the potential for all types of interruptible power contracts, including a discussion of their use elsewhere in North America.

244. For all measures which form part of the technical but not the costeffective potential, the Proponent shall estimate probable changes in the cost of these measures for the duration of the planning period, indicating if and when a measure would become cost-effective.

Other demand-side resources:

245. The Proponent shall describe all other reasonable measures that could be adopted for reducing demand for power and electricity, including potential and planned system improvements to reduce transmission and other losses. For each one, the Proponent shall specify the cost, the technical and cost-effective potential, the useful life, the amount of energy saved per typical client and the number of potential clients.

246. For each measure, the Proponent shall describe reasonable approaches for promoting its adoption. These approaches include, among others, information and advertising, standards, norms and regulations, technical and financial assistance, rate structures and levels, direct subsidies, and any other relevant approach. For each approach, the Proponent shall then identify and characterize the obstacles preventing or limiting its adoption.

247. For each approach, the Proponent shall identify a range of plausible programs of differing durations and funding levels. Upper and lower estimates of the penetration rate for each program shall be provided, along with explanation of the factors affecting it. The expected energy and capacity savings for each program shall be estimated, and nominal and real levelized cost per kilowatthour and per kilowatt calculated, with capital costs amortized as for supply-side resources.

248. For each program, the Proponent shall identify all positive and negative interactive (or cross-) effects, explaining and justifying in detail how these effects are accounted for in calculations of demand management potential, and shall compare the electricity and power currently used, identify the cost of the relevant measures (by kilowatthour and by kilowatt saved), and the percentage of projected usage that would be saved by each measure, for each type of end use. These programs, or reasonable groupings thereof, shall be treated as demand-side resources for the purposes of the least-cost analysis called for in paragraph 206.

249. Fuel switching. The Proponent shall describe existing dual energy programs, assess other possible approaches to using other fuels to reduce peak capacity and energy demand, including promoting the use of natural gas and solar energy for space- and water-heating needs, and summarize the costs and demand savings of these programs.

250. Rate structures. Changes in rate structure can create or eliminate incentives for conservation in a significant way. The Proponent shall describe a broad range of rate structures, including a survey of those used in other North American and European jurisdictions. For each one, the Proponent shall estimate the impact on energy and capacity demand, and shall describe program and any other costs. The discussion should address, among others, increasing block consumption charges (for each sector), time-of-use rates, capacity-related hookup charges, domestic capacity charges, and optional marginal rate pricing.

Externalities:

251. For each supply- and demand-side resource, the Proponent shall provide a characterisation and qualitative estimate of its externalities, both positive and negative. For the proposed Great Whale River hydroelectric project, these will be drawn from the analyses required in Chapter 5 of these guidelines. For other resources, they shall be determined according to the best information available to the Proponent. For each resource, the Proponent shall also provide a description of the social and economic impacts on Quebec as a whole, including job creation (including the nature, type and number of direct, indirect and induced jobs generated, their duration, which groups are most likely to benefit from these jobs, and where they will occur), macro-economic effects (e.g., degree of economic stimulation, effects on public access to credit) and independence from out-of-Quebec energy sources. For thermal generating technologies, description of externalities shall include potential negative impacts related to air emissions and discharge of heated water, as well as any other adverse environmental effects. For major purchases, and to the extent that such purchases are tied to specific resources, the Proponent shall provide information on those resources and characterize their externalities.

The techno-economic potential, defined as the amount of energy that could be saved at a cost less than or equal to the cost of energy from the Great Whale project, is evaluated in the EIS at 27.6 TWh/year. The Proponent forecasts energy savings for the year 2000 of 9.3 TWh. The following questions are meant to better define the energy efficiency potential evaluated by the Proponent at 9.3 TWh.

2.45 Discuss how a higher goal in energy efficiency could be achieved by adopting a more aggressive strategy. Explain the conclusion that 60% is the optimal level for utility financing of energy efficiency measures, and that it will lead to a penetration rate of 34% over 10 years. In light of recent experience in other jurisdictions and in light of the Proponent's experience with the ECOKILO program, discuss other strategies, including higher levels of financing or other program modifications, which could achieve greater levels of success. For each one, estimate the changes in program cost, net energy savings and real levelized unit cost of the energy saved. Provide an analysis of what means would be necessary to exploit all or most of the techno-economic potential within 20 years.

2.46 Describe how the Proponent intends to meet the stated objectives of energy savings up to the year to 2010. Provide estimates of the technical, techno-economic and achievable potentials for each demand scenario, broken down by sector and end use. Provide the studies forming the basis for the estimates of these potentials.

2.47 Specify the avoided costs for each type of end use or service, used in determining the techno-economic potential, including methodology used.

2.48 Provide a list of energy efficiency programs now in force or in preparation for each sector to achieve the goal of 9.3 TWh in energy savings and the cost forecasts of the energy efficiency project. For each program, indicate its cost, anticipated capacity and energy savings and expected penetration rates.

2.49 The EIS notes repeated declines in successive estimates of future energy savings (Part 1, Book 2, Volume 3, Table 3.9). For programs which have been in place for several years, compare the initial projections with the energy savings actually achieved, on a year-by-year basis, and provide detailed explanations of the differences.

2.50 Provide a program-by-program breakdown of the projections presented in the EIS (Part 1, Book 2, Volume 3, Tables 3.9 and 3.10), and extend this analysis to the entire planning period, or as a minimum to 2010. Indicate how these projections vary in response to different load-growth scenarios.

2.51 Provide a list of measures which could reasonably be expected to become part of the techno-economic potential in the near future; i.e., those which are now only slightly more expensive than the avoided cost, and/or where costs are clearly declining.

2.52 Describe how the rate neutrality test described in Volume 4, section 3.2, has affected the choice of energy efficiency programs. What programs, if any, which pass the total resource cost test, have been ruled out because they fail the rate neutrality test? For each such case, indicate the program's techno-economic potential and real levelized unit cost. Explain how the rate of neutrality criterion is consistent with Orientation 17 of the Proponent's Development Plan.

2.53 To what extent could the promotion of natural gas and solar energy for space and water-heating needs fulfill the peak capacity and energy demand? Summarize the costs and potential demand savings of such programs.

2.54 Document and quantify the conclusions that, except for a few specific sectors, substitution of electricity with fossil fuels is not very interesting for Quebec, using all available information on the comparison of the installation and operating costs of various energy sources. Provide an analysis concerning the most economical approach to space and water heating in Quebec, comparing the cost (equipment and energy) of heating with electricity, with natural gas and with oil for the residential, commercial and institutional sectors. Use an approach based on social profitability to make these calculations, taking into account the fact that rates billed to the clients do not always reflect the real cost of the resources involved in the production of energy, due to inter-financing between sectors.

2.55 Estimate the impact on energy and capacity demand of the different rate structures described in the EIS. Estimate the costs incurred in setting up such rate structures.

2.56 Evaluate the potential for all types of interruptible power contracts. Explain the relationship between this potential and the objectives discussed in Part 1, Book 2, Volume 3, Table 5.2.

2.57 For existing interruptible power contracts, provide descriptions of their terms and of the quantitative estimates of the resulting capacity savings on a year-by-year basis. Provide similar information regarding any planned expansion of the interruptible power program, and discuss the possibilities for expanding these programs beyond their current and planned limits, indicating to what degree additional capacity savings could be achieved.

System Planning

GUIDELINES paras. 252 to 258

SYSTEM PLANNING:

252. Understanding the Proponent's system planning is crucial to assessing requirements for new supply. System planning assumptions and criteria, which are routinely developed to guide short-and long-term planning and operations, include reserve provisions and hydraulic operational parameters.

253. For each year of the planning period, the Proponent shall provide: the total energy and capacity sales (broken down into firm Quebec, surplus Quebec, firm exports, surplus exports, and energy reserve margin, if applicable); the total energy and capacity supply, broken down by source, including existing hydro plants, existing thermal plants, new generation by project, purchases, and exceptional operating measures, with a full description of measures and effects; and the other inputs and outputs to the hydro system, such as runoff, reservoir drawdown/refilling and spillage (as in the Electrical Energy Balance Sheet in the Proponent's Development Plan).

254. Reserve provisions are needed to meet equipment outages, system emergencies, and periods of low precipitation. The Proponent shall explain how reserve margins affect system operations and the costs and selection of resources. The analysis of reserves should include a review of basic planning policy and reserve standards and requirements imposed by government bodies. Also, the Proponent shall provide information regarding current reserves and its assumptions concerning required capacity reserve margins (for each year of the planning period), as well as a probability analysis concerning loss of load, which establishes overall reserve requirements.

255. The Proponent shall also provide the basis for the criteria established for reserve margins, including any studies and guidelines established by either the NPCC or the NERC, its assumptions concerning the load carrying capabilities of each resource, or quantification of the impact of each type of resource on reserve margins, and an analysis of the effect of additional demand- and supply-side resources on the required reserve margins.

256. All operating agreements and commitments with neighbouring utilities, agencies such as NERC and any other private producers shall be identified, as well as the system emergency rules for domestic and export loads.

257. Losses shall be specified for each sector and on an aggregate basis for the risk- and profit-sharing and export contracts. For both energy and capacity, the Proponent shall provide information concerning total losses and high voltage transmission losses by diurnal and seasonal loadings.

258. The Proponent shall also indicate the probability and severity of power outages due to accidents, sabotage or natural disturbances, the measures taken or under consideration to prevent or minimize them, and the costs of these measures.

2.58 Provide a detailed technical characterization of the existing generating system, including any projects now under construction, and indicating the following information for each one: installed capacity, contribution to peak demand, average annual energy and capacity factor, along with a description of the usual pattern of use (baseload, seasonal peak, daily peak, etc.). All existing purchase and operating agreements shall be described in the same terms, when applicable. List the principal reservoirs in the Proponent's system and the total storage for each. To the extent possible, indicate for each one its contribution to the seasonal reserve of 55 TWh and the inter-annual reserve of 85 TWh described in the EIS, and explain how these figures are determined.

2.59 Marginal costs for energy and capacity, a key parameter in the optimization process described in the EIS, are not provided, although they are discussed in Part 1, Book 2, Volume 3, section 13.2. Provide generic marginal costs for power and energy used for differential cost analysis, and an explanation of their derivation and use.

2.60 Discuss the likely or plausible effects of global warming on inflows into the Proponent's hydro-based system, making reference to the most recent and authoritative scientific reports available, and, to the extent possible, indicate to what extent ongoing global climate change could influence the productivity of the hydroelectric system in general and the need of Great whale complex in particular. Include a description of the sources and methodologies used.

2.61 Following the adoption of the NEPTUNE planning model in 1990, Hydro-Quebec changed its approach to reducing costs related to below-average runoff (energy reliability). Under this new approach, an analysis is made of the economic impacts of different levels of energy reserves, and the optimal level is determined. Construction of planned facilities is then advanced to yield an annual energy surplus of the selected amount with respect to projected needs. The size of this reserve thus has a direct effect on the need dates for new equipment, including the proposed Great Whale project. The description in the EIS of the analyses on which it is based are not sufficiently detailed to permit their evaluation. Provide additional explanation of the analysis of energy reserves, including documentation of the methodology used and all assumptions, including the cost of the exceptional measures, the anticipated prices for surplus sales, the criteria used to trigger exceptional measures and surplus sales, and the assumed cost of energy reserve resources. Update this analysis if appropriate. Discuss the economic impacts of falling short or of exceeding the optimal reliability criterion by different degrees.

Financial Parameters

GUIDELINES paras. 259 to 264

FINANCIAL PARAMETERS:

259. While it is understood that the responsibility for establishing rates belongs to the Government of Quebec, the information shall include all costs and other financial information in sufficient detail to permit calculation of revenue requirements and anticipated rates.

260. The Proponent shall submit a financial model bringing together variables such as demand, rates, sales, revenues, borrowing, investment, interest, amortization and net worth.

261. The Proponent shall also present a detailed review of the financial parameters used, including the most recent version of Parametres economiques et energetiques de planification a'long terme, and any other related documents.

262. Financial forecasts. For each of the high, low, and medium demand scenarios as described in paragraphs 215 to 222, the Proponent shall provide a financial forecast for the full planning period and shall indicate the probability of each scenario occurring.

263. The Proponent shall also provide: revenue and energy sales for each

sector including overall information concerning risk- and profit-sharing

and export contracts; financial information of the type provided in Tables

13 through 16 of the General Report (follow-up of the Development Plan 1990-1992, Horizon 1999 as of December 31, 1991) for the full planning period; and best- and worst-case scenarios based on financial parameters (interest rate, inflation, exchange rate, etc.).

264. Rate forecasts. The Proponent shall provide estimates of rates, volume of sales, total revenues and revenue variability (across scenarios by category of customer); an analysis of consistency between the volume of sales (TWh) and sales revenues assumed in the financial forecast and the electricity prices assumed in the load forecast; and the impact of high, low and medium demand scenarios on year-by-year increases in the Proponent's regular rates for the planning period, taking into account the investments required to meet future demand, explaining all assumptions.

While many elements which would contribute to a full understanding of the financial implications of different scenarios have been provided, sensitivity analyses indicating the financial impacts of changes in economic parameters and best- and worst-case scenarios are not provided.

2.62 Provide projections for each year of the planning period (1994-2022) for each line item in the statement of operations and balance sheet in the Proponent's Annual Report as well as any other information needed to compute the financial ratios. The expected average cost of debt shall also be provided. The projections shall include revenue from sales of electricity, broken down into firm sales in Quebec, surplus in Quebec, firm export and surplus export, and sales volume for each of these categories; energy requirements for each year, broken down as in the Annual Report; aggregate sales revenue and volume for the risk-and-profit-sharing contracts, and average unit revenue (average rate) and average unit expenditure (average cost) for each year, broken down as in the Annual Report.

2.63 For the purpose of allowing a clear and consistent analysis, provide information for a range of plausible scenarios including, as a minimum, the low and high demand growth scenarios and a range of plausible circumstances concerning runoff, market development, interest rates, inflation rates and exchange rates. The information shall be sufficient to permit determination of the financial implications of best- and worst-case scenarios based on different combinations of these parameters.

2.64 Specifically, include an evaluation of the financial risks associated with the following three conditions once construction has begun:

2.65 For each of these scenarios, provide the commissioning dates of each powerhouse of the Great Whale complex, the unit cost of the electricity from each one and, when appropriate, the anticipated surplus or the backup facilities to be built. The Construction start date, in-service date and total Capital cost (in nominal dollars) of each new major facility (generation or transmission) in the Scenario that underlies the projected financial results shall be provided.

CHAPTER 3

DESCRIPTION OF THE BIOPHYSICAL AND SOCIAL ENVIRONMENTS

Three principles were to guide the Proponent's description of the environment, to provide baseline conditions in relation to which the prediction of biophysical and social impacts of the proposed project would be evaluated. These were: the differing ways of defining and understanding the environment according to each of the affected cultures, the valued ecosystem components for each culture, and a justification for the spatial and temporal boundaries fixed for the study of each component. The valued ecosystem components of each culture have not been clearly identified. The knowledge that the indigenous societies have of their environment is not sufficiently incorporated into the descriptions and analysis presented in the EIS. Moreover, there are ambiguities concerning the definition of boundaries of the study area.

With regard to social environment in particular, the diverse aspects of social organization and symbol systems in the Native communities, although partially discussed and described in the EIS, are not addressed in a global, integrated fashion. The factors underlying social cohesion are not discussed in a way that allows an understanding of the potential consequences of changes in any of them. The symbolic aspects of the relationships these societies have to the land, as well as their relevance to social organization, and the repercussions of changes in these relationships are not discussed. Factors governing certain social dynamics and the question of ties between distinct Native communities or between Native and non-Native communities are not discussed adequately.

Many of the following questions require the incorporation of the knowledge and understanding of the indigenous societies into the response. The need to provide a portrait of the environment that each cultural group could recognize, and an inventory of the elements judged important by each one, remains to be fulfilled.

The following requirements of this Chapter are addressed to the Proponent to provide the Review Bodies with descriptions of the affected biophysical and social environments that are complete and adequate.

Physical Environment

GUIDELINES paras. 311 to 324

PHYSICAL ENVIRONMENT:

Climate:

311. Climatic changes. In order to study the climatic changes which could result from the Project, and the influence of the present climate on operating conditions, the Proponent shall provide detailed descriptions of the past and current climates of the Great Whale, Little Whale and Nastapoka river basins.

312. Climatic parameters. In addition to conventional climatic parameters related to temperature, precipitation and wind, this description shall include a detailed study of the particular climatic conditions observed in the region, especially for zones with high risk of fog and other microclimates.

313. Vegetation. The description of the climate shall include an appraisal of the length of the growing season and of ground-frost conditions, and shall include an analysis of the relationship between surface vegetation and regional climatic conditions.

Geology:

314. Geological study. The Proponent shall provide a geological study of the region in order to provide baseline data on the geochemical background of certain trace metals, to establish the structural context and the possible levels of induced seismicity, and to determine the geological conditions that affect the physico-chemistry of lakes and soil and the productivity of plant communities.

315. Geochemical study. The geological study shall include a geochemical study of the bedrock, principally aimed at establishing background levels and regional variations of trace metals such as mercury, copper, lead, cadmium, arsenic and zinc.

316. Seismicity. The Proponent shall establish the current seismicity level as indicated by available seismograph records, as well as the paleoseismicity of the region using recognized geophysical and geological methods. All possibly significant regional faults must be identified, either by geological or geophysical means or by remote sensing.

317. Mineral claims. In addition, the Proponent shall locate existing claims and identify known resources and mineral showings and indicate, as much as possible, their potential for economic development.

Geology of surficial deposits:

318. Map. In order to identify potential erosion zones, to establish background levels and regional variability of potentially toxic trace metals in the drift, and to determine the natural conditions partly responsible for controlling the physical chemistry of the lakes, the Proponent shall provide a geological map of the surficial deposits and the geomorphology of the region.

319. Geotechnical study. The surficial geological map shall point out the location of areas prone to erosion, slope instabilities and other mass movements. Where appropriate, the Proponent shall gather and provide pertinent geotechnical data necessary to properly assess the erosion or mass movement problems.

320. Drift geochemistry. The geological study of the surficial deposits will include a drift geochemical survey to establish current background levels and regional variability of trace metals such as mercury, copper, lead, cadmium, arsenic and zinc in the fine portion of the sediments.

Exceptional sites:

321. The Proponent shall provide an inventory of all sites particularly representative of the milieu or exhibiting unique physical or biological features in the region of the proposed project. The surficial geological map shall indicate the special sites or landforms that warrant protection because they are unique or remarkable, according to the residents of the region and others. The uniqueness of any sites which might be submerged or altered as a result of development shall be described. The stranded shorelines around Lac Fagnant and the terraces along the Great Whale River are examples of such features.

Soils, peatlands and permafrost:

322. Soils. In order to assess the capacity of the environment to support surface vegetation and possible re-vegetation, the Proponent shall describe the soils in the study area. This description shall include but not be limited to the order and the main groups of soils in the study area, as well as the thickness, geographical distribution, productivity, and organic content of the soils.

323. Peatlands. The Proponent shall pay particular attention to peatlands, and shall map their distribution and thickness (estimated or measured). Their geochemical characteristics shall also be established, particularly with regard to their content of potentially toxic trace metals (mercury, copper, lead, zinc, arsenic and cadmium).

324. Permafrost. The Proponent shall provide a map of the distribution of the permafrost in the study area. In particular, the Proponent shall provide a map of the distribution of the palsa bogs and permanently frozen parts of peatlands in the regions that could be flooded as a result of the proposed project, and shall determine the extent, depth, and ice content of the permafrost. The Proponent shall assess the amount of ice that could be melted as a result of flooding and the levels of metal that could be released as a result of melting.

3.01 The climatic data provided in the EIS indicate patterns of temperature and precipitation over the entire 70 900 km2 study area, as obtained primarily from the application of a mathematical model to data obtained from few monitoring stations over a period of 29 years. These data lack sufficient resolution to permit small post-development changes in meteorological conditions to be discerned. In order to establish a useful baseline description of meteorological conditions, provide a synthesis of data recorded from the RGB-93001, RGB-93002 and LBV-93003 meteorological stations.

3.02 Describe and map the spatial and temporal occurrence of fog along the Hudson Bay coast, and of fog associated with the inland water bodies which would be affected by the proposed project, especially Lac Bienville.

3.03 Indicate the suitability of the soil for revegetation in those regions where revegetation is expected to be employed as a mitigative measure.

Aquatic Environment

GUIDELINES paras. 325 to 337

AQUATIC ENVIRONMENT:

Freshwater environment:

Hydrology and hydraulics:

325. Hydrology. For each watercourse that will be disturbed, the Proponent shall provide an analysis of the annual hydrological regime, including data on frequency, volume, and duration of flood and dry-weather discharges.

326. Ice. The Proponent shall determine the most likely dates of the fall freeze and the spring thaw, and their annual variability for zones downstream from the turbines, and shall also describe the types of breakup, types and locations of ice jams, the extent of flooding associated with ice jams, and the relationship between coastal ice and river ice.

327. Hydraulics. In order to examine the quality and productivity of habitats that will be destroyed or affected by river diversion, the Proponent shall provide a map of the watersheds and the relevant hydraulic characteristics of each section of each river. The Proponent shall make use of these characteristics to determine the appropriate residual flow that should be maintained in order to protect major aquatic habitats.

Physical chemistry of surface water:

328. The Proponent shall define the physical and chemical properties of the surface waters of the study area, including but not limited to the thermal regimes of northern rivers and lakes and the main factors governing them, and the physical and chemical characteristics of test-case lacustrine and riparian environments, in which the selection of parameters, the number and location of sampling sites, and the frequency of sampling will be determined. This portrait should be representative of the annual cycle and of the interannual variability used for analysis.

329. The Proponent shall present the following parameters and discuss the methods used for analysis and sampling: conductivity, pH, bicarbonates, minimum and maximum temperature, dissolved oxygen, transparency, colour, turbidity, suspended matter, total phosphorus, total Kjeldahl nitrogen, nitrites and nitrates, silica, total inorganic and organic carbon, tannins and lignines, chlorophyll and pheopigments, calcium, sodium, potassium, magnesium, manganese, iron, chlorides, sulphates and appropriate trace metals known to be potential contaminants. The description shall also include the identification and concentration of other contaminants, when appropriate.

330. The Proponent shall specify, on an annual basis, the factors which determine the chemical composition of rivers and lakes on the Canadian Shield and shall indicate the factors which regulate or control physical and chemical variables such as alkalinity, organic carbon and metals in the environment under study.

331. The Proponent shall evaluate changes taking place with respect to each contaminant and the sources thereof (airborne or others) in the area under study, so as to be able to understand and predict any cumulative or synergetic impacts.

Biological characteristics:

332. Plankton communities. The Proponent shall describe the composition of phytoplankton and zooplankton communities at different times of year to establish a succession profile for the major taxonomic groups. The Proponent shall also submit data on the available indices of primary productivity and shall discuss the reliability of these data in relation to on-site activity. The Proponent shall determine the zooplankton biomass in lacustrine and riparian ecosystems and shall explain the relative importance of different taxonomic groups in the productivity of the aquatic ecosystem and in energy transfers with adjacent ecosystems.

333. Benthic communities. The Proponent shall enumerate the major benthic groups in the lacustrine and riparian ecosystems of the study area and shall describe their relationship with the physical variables affecting their number and distribution.

334. Macrophytic vegetation. The Proponent shall provide a seasonal portrait of the distribution, location and composition of each aquatic plant community and shall discuss its importance as shelter or food for fauna.

335. Fish populations. The Proponent shall present a complete list of species encountered in the territory under study and shall indicate their preferred habitats, particularly their spawning areas. The Proponent shall provide an inventory of fish habitats in the area and shall indicate the geographic distribution of each species by season. The Proponent shall identify those factors which limit the distribution and population of those species of interest for Native diets and for sports fishing. The concentrations of contaminants in edible parts of fish shall be measured to provide baseline information.

336. Dynamics of fish populations. The descriptions of fish populations shall include the principal parameters of the population dynamics and the factors governing their abundance, notably: growth curves, physiological indices, and the relationship between length and weight; structure of the communities according to age and sex; age of sexual maturity and the reproductive cycle; fertility; estimates of mortality due to natural causes and to fishing; the diet of each species; interspecies relationships that control fish abundance and their communities, spawning grounds, hatchery zones, and migration routes, minimum oxygen requirements and temperature preference; and finally, the main fish parasites which influence the growth and survival of the most abundant species, with their life cycles and the factors currently limiting their geographic distribution.

337. Freshwater seals. The Proponent shall review existing knowledge of the genetic status, abundance; diet, recruitment, geographical distribution, preferred habitats, breeding season and mortality factors of freshwater seal populations. Special emphasis shall be placed on the population in the Lacs des Loups Marins, given its confinement there and its dependence on these lakes. The Proponent shall also discuss the limiting factors that maintain this population at its present level, and indicate how its environmental studies program will add to knowledge of this species.

3.04 Indicate the existing hydraulic characteristics of the river sections which would be affected by the proposed project. Give sufficient detail so that these characteristics can be used to establish the type, quality and productivity of the fish habitats which would be affected by modification of river flow.

3.05 Describe the existing ice regime (e.g., freeze and thaw dates, ice thickness, interannual variation) for those continental waters where it would be modified by the proposed project, especially those areas which would lie downstream from the power houses of the project and the points of diversion of river sections.

3.06 In order to evaluate the natural range of variation of a number of parameters, discuss how the physical and chemical properties of the surface waters of the study area vary from year to year.

Plankton, Benthic, and Macrophytic Communities

GUIDELINES paras. 332 to 334

332. Plankton communities. The Proponent shall describe the composition of phytoplankton and zooplankton communities at different times of year to establish a succession profile for the major taxonomic groups. The Proponent shall also submit data on the available indices of primary productivity and shall discuss the reliability of these data in relation to on-site activity. The Proponent shall determine the zooplankton biomass in lacustrine and riparian ecosystems and shall explain the relative importance of different taxonomic groups in the productivity of the aquatic ecosystem and in energy transfers with adjacent ecosystems.

333. Benthic communities. The Proponent shall enumerate the major benthic groups in the lacustrine and riparian ecosystems of the study area and shall describe their relationship with the physical variables affecting their number and distribution.

334. Macrophytic vegetation. The Proponent shall provide a seasonal portrait of the distribution, location and composition of each aquatic plant community and shall discuss its importance as shelter or food for fauna.

3.07 Provide a survey of the zooplankton at sites which are representative of those watercourses which would be affected by the project, and for the most abundant taxa indicate the relative abundance and biomass, and seasonal variation in each. Discuss also how the downstream transfer of planktonic organisms contributes to the productivity of estuaries, and indicate the importance of the various taxa involved in this transfer.

3.08 Data provided concerning the distribution and abundance of benthic invertebrates lack sufficient taxonomic resolution to be considered an accurate determination of baseline conditions. Representativity of the surveys provided is questionable. In addition, the relation between benthic invertebrate abundance and the factors which regulate it, is restricted to depth and velocity. In order to provide adequate baseline information, provide the following: a) an explanation of the representativity and use of the surveys presented for assessing impacts and of the design of future monitoring programs; b) provide higher taxonomic resolution and c) discuss other regulating factors in addition to depth and velocity.

3.09 In the discussion of benthic fauna in the text of the EIS, data are, in some cases, pooled together for the entire study area. This ignores differences among the fauna of different riverine and lacustrine habitats. Discuss the degree to which the data presented in the EIS are representative of the rivers and lakes which would be affected by the proposed project.

3.10 Statements relating benthic invertebrate density to water depth are based solely upon data collected in lakes during late August. Discuss the degree to which these data can be considered representative of conditions throughout the year.

3.11 Provide a list of the species composition of representative aquatic macrophyte communities, and discuss seasonal variation in community composition. Provide a discussion with supporting data to illustrate the importance of the various types of aquatic macrophyte communities to fish and wildlife in those waters which would be affected by the proposed project.

Freshwater Fish

GUIDELINES paras. 335 and 336

335. Fish populations. The Proponent shall present a complete list of species encountered in the territory under study and shall indicate their preferred habitats, particularly their spawning areas. The Proponent shall provide an inventory of fish habitats in the area and shall indicate the geographic distribution of each species by season. The Proponent shall identify those factors which limit the distribution and population of those species of interest for Native diets and for sports fishing. The concentrations of contaminants in edible parts of fish shall be measured to provide baseline information.

336. Dynamics of fish populations. The descriptions of fish populations shall include the principal parameters of the population dynamics and the factors governing their abundance, notably: growth curves, physiological indices, and the relationship between length and weight; structure of the communities according to age and sex; age of sexual maturity and the reproductive cycle; fertility; estimates of mortality due to natural causes and to fishing; the diet of each species; interspecies relationships that control fish abundance and their communities, spawning grounds, hatchery zones, and migration routes, minimum oxygen requirements and temperature preference; and finally, the main fish parasites which influence the growth and survival of the most abundant species, with their life cycles and the factors currently limiting their geographic distribution.

3.12 Provide an account of the biotic factors (e.g., prey availability, competition) and abiotic factors (e.g., water temperature and oxygen content, current velocity, substrate type, etc.) which presently delimit the habitats occupied by key fish species (i.e.., those of interest to Native and sport fishermen) in the waters of the study area, and indicate, in map form if possible, the general area and extent of the different habitats occupied by each species in waters which would be affected by the proposed project. This account shall consider seasonal variation in habitat use, and include a clear distinction between known habitats and those whose locations have been inferred.

3.13 whenever such information is available, provide data concerning the variables which control population dynamics (e.g., sex ratios, seasonal reproductive cycles, fertility, mortality factors and rates, diet, longevity, fertility, and age at sexual maturity) of lake trout, lake whitefish, northern pike, brook trout, lake cisco, and suckers. Present results of any pertinent study concerning juvenile fish.

3.14 Assess the influence of various factors (e.g., type of gear, location of fishing sites, time of year) on the size and composition of fish catches. Make reference to studies in which seasonal variation in fish catches was examined. Where data are lacking or are limited, discuss the implications of the lack of data and expand upon what would be needed to fill the gaps.

Estuaries and Marine Environments

GUIDELINES paras. 338 to 351

Estuaries and marine environments:

338. The study area for this section includes the estuaries of the Great Whale and Little Whale rivers, Manitounuk Sound and the eastern coastal areas of Hudson Bay, particularly the areas near the Nastapoka, Ducks and Belcher Islands.

Physical characteristics of estuaries:

339. The Proponent shall present up-to-date information on the characteristics of estuaries likely to be altered by the proposed project. Temperature and salinity gradients, brackish areas, mixing zones, tidal currents, average tide levels (high and low), as well as plume characteristics shall be identified as a function of river flow under natural conditions, with and without ice cover. All other hydrodynamic information required to understand the dynamics of the estuaries under study is also to be provided, including coverage, type, thickness and duration of ice cover. The Proponent shall describe the distribution and stratigraphy of post-glacial sediments present in the coastal and deep water areas of all estuaries affected by the project, and shall pay special attention to the configuration of the sand spit at the mouth of the Great Whale River and the configuration of the Little Whale River estuary. The effect of the wave regime, river flow, and littoral drift on the configuration of sand banks at the mouths of the estuaries shall also be examined.

340. The suspended sediment load and bed load at the mouths of estuaries shall also be determined as a function of river flow and tidal conditions.

341. The Proponent shall present a physical and chemical portrait of estuarine waters by referring to the parameters listed in paragraph 329, as well as the salinity and density of the water.

Biological characteristics of the estuaries:

342. The Proponent shall describe the estuarine processes linked to primary and secondary productivity, specifying their role with respect to the ecology of invertebrates and fish and in the recruitment of anadromous fish populations. Up-to-date information shall be provided on the concentration of nutrients and on their importance to the wildlife frequenting the estuaries on a regular or periodic basis. The Proponent shall also investigate the role played by the mix of nutrients with respect to the biological productivity of fish at the larval stage and in the recruitment of anadromous fish.

343. Maps shall be provided showing the abundance and distribution of sublittoral vegetation at the mouth and on the banks of the estuaries. With regard to fish populations, the Proponent shall present data on the major species of anadromous fish in those estuaries which are likely to be modified. The following main points shall be discussed: the geographic distribution and abundance of the various species present (whitefish, speckled trout, etc.) as well as their spawning ground; insofar as possible, the identification of distinct populations; the reproductive strategies and limiting factors affecting annual migration cycles (salinity, temperature, water levels, ice and freshwater wintering); and the environmental factors affecting egg maturation and larval survival.

344. The Proponent shall establish growth curves for the varidus species

present and shall evaluate mortality rates, both natural and due to fishing.

Data on age at maturity and fecundity shall also be presented, as well as

a discussion of variability in recruitment levels from year to year.

345. The Proponent shall present data on marine mammals in the estuaries, particularly the beluga, such as their abundance, recruitment, seasonal distribution, reproduction factors, preferred habitat, annual variability and migratory patterns. The Proponent shall provide a critical analysis of current knowledge of the estuarine environments of the Nastapoka, Great Whale and Little Whale rivers as habitat for belugas. The Proponent shall also take into consideration the population trends of belugas and their status in Hudson Bay.

Physical and biological characteristics of the marine environments:

346. The Proponent shall present an analysis of the physical (temperature, salinity, circulation, ice conditions, etc.) and chemical oceanography of Manitounuk Sound, covering, in particular, the mixing processes that determine residence times for waters in the Sound and, insofar as they may be significantly affected, for coastal waters between the Great Whale and Little Whale river estuaries. Nutrient and sediment transport under natural conditions and the composition of the sublittoral vegetation of the Sound and the Hudson Bay coastline shall also be discussed and the ecological significance of naturally occurring ice-free zones shall be evaluated.

347. The Proponent shall review current knowledge of the following topics: bathymetry; primary and secondary productivity and the factors which govern them; the composition and abundance of benthic fauna; the composition, abundance and life cycles of fish species and marine mammals; probable freeze and thaw dates and the nature and extent of freshwater plumes, including salinity and temperature profile.

348. The Proponent shall present current information on the distribution and ecology of the various species of marine mammals in Manitounuk Sound and in the southeastern part of Hudson Bay, focusing on the significance of the movement of marine mammals and fish between the area affected by the proposed project and the adjacent areas where these resources are exploited by the local population.

349. The level of contamination in marine mammals shall be evaluated, in order to obtain the baseline information necessary in the event that the proposed project proceeds.

350. The Proponent shall present information on the geographic distribution, abundance, diet, preferred habitat, mortality factors, reproductive factors, known contaminant levels and importance of marine invertebrates to Native diets.

351. The Proponent shall also present information on the geographic distribution, abundance, diet, preferred habitat, breeding grounds, recruitment, mortality factors, reproductive factors, contaminant levels, incidence of disease, age structure, genetic status, migratory patterns and sensitivity to disturbance of beluga whales.

3.15 Anadromous populations of whitefish and brook trout are an important source of food for local Native communities. Describe the diet and recruitment of the key species of anadromous fish in the Great Whale and Little Whale estuaries, and discuss the importance of the estuaries to the recruitment of coastal anadromous fish populations.

3.16 Provide information concerning the variability in fish catches from year to year during the survey of the estuaries.

3.17 Determining the extent to which anadromous fish migrate between estuarine waters and the waters of the Hudson Bay, is important in evaluating potential cumulative effects of various impacts. Provide a discussion of what is currently known about the movements of anadromous fish between Great Whale and Little Whale River estuaries and other regions of Hudson Bay.

3.18 In the EIS, the current state of knowledge concerning the factors which influence the productivity of estuaries in the region is not clearly presented, particularly regarding interannual variability in productivity. Describe the relationships among the physical and biological components in estuaries, focusing on those factors affecting fish production. In the latter case, it would be particularly appropriate to incorporate traditional ecological knowledge.

3.19 Indicate abundance, population structure, fecundity and longevity of the marine mammal species which frequent Manitounuk Sound.

3.20 Indicate the approximate age and sex ratios of the eastern Hudson Bay beluga population. Provide data on the numbers of males, females, and juvenile belugas that are harvested by Natives, and on the frequency of reproduction of beluga females. Discuss how the Inuit harvest affects this population.

3.21 Quantify the abundance of sea urchins, blue mussels, and other important invertebrate species in the marine and coastal environment in areas that would be affected by the project, with specific reference to Manitounuk Sound.

3.22 Discuss the distribution of fish and marine mammal populations which frequent the Belcher Islands and Manitounuk Sound, including the degree to which populations are shared between the two areas.

3.23 Provide information concerning the composition and distribution of sublittoral vegetation communities in Manitounuk Sound and along the Hudson Bay coast, in those areas which would be affected by the proposed project.

3.24 Provide a complete and up-to-date discussion on primary and secondary productivity in southeastern Hudson Bay.

3.25 Provide a description of the physical and biological characteristics of the waters of the areas near the Nastapoka, Duck and Belcher Islands, such that sufficient information is available to provide a background against which impacts of the proposed project could be assessed.

3.26 No data are provided for the water temperatures in estuaries during the winter ice-covered season. Indicate the temperatures of different sections of the estuaries of the Great Whale and Little Whale Rivers during the winter.

3.27 Provide measurements of nitrates, nitrites, tannins, lignins, calcium, sodium, potassium, magnesium, manganese, iron, and chlorides in the estuaries of the Great Whale and Little Whale Rivers.

3.28 Provide descriptions of the methods used to acquire data concerning the physico-chemistry of estuaries. Specify the models used to predict salinity, as well as those used to verify model accuracy. Indicate which data were derived using models and which were derived from observations.

3.29 Provide information concerning Manitounuk Sound's low water volume. Use this information to establish the residence times of water in the Sound, and the importance of daily tidal cycles in relation to the amount of water in the Sound. Discuss the influence of wind on water circulation in Manitounuk Sound. Indicate the role presently played in coastal oceanography by mixing processes in the Sound. Include a discussion of the structure and physical properties of coastal ice under different conditions.

Contamination by Mercury and Trace Metals

GUIDELINES paras. 324, 329, 335, 349, and 352 to 356

324. Permafrost. The Proponent shall provide a map of the distribution of the permafrost in the study area. In particular, the Proponent shall provide a map of the distribution of the palsa bogs and permanently frozen parts of peatlands in the regions that could be flooded as a result of the proposed project, and shall determine the extent, depth, and ice content of the permafrost. The Proponent shall assess the amount of ice that could be melted as a result of flooding and the levels of metal that could be released as a result of melting.

AQUATIC ENVIRONMENT:

Freshwater environment:

Hydrology and hydraulics:

329. The Proponent shall present the following parameters and discuss the methods used for analysis and sampling: conductivity, pH, bicarbonates, minimum and maximum temperature, dissolved oxygen, transparency, colour, turbidity, suspended matter, total phosphorus, total Kjeldahl nitrogen, nitrites and nitrates, silica, total inorganic and organic carbon, tannins and lignines, chlorophyll and pheopigments, calcium, sodium, potassium, magnesium, manganese, iron, chlorides, sulphates and appropriate trace metals known to be potential contaminants. The description shall also include the identification and concentration of other contaminants, when appropriate.

335. Fish populations. The Proponent shall present a complete list of species encountered in the territory under study and shall indicate their preferred habitats, particularly their spawning areas. The Proponent shall provide an inventory of fish habitats in the area and shall indicate the geographic distribution of each species by season. The Proponent shall identify those factors which limit the distribution and population of those species of interest for Native diets and for sports fishing. The concentrations of contaminants in edible parts of fish shall be measured to provide baseline information.

349. The level of contamination in marine mammals shall be evaluated, in order to obtain the baseline information necessary in the event that the proposed project proceeds.

MERCURY CONTAMINATION:

352. The Proponent shall review the current state of knowledge and all pertinent literature on the biological, geological and chemical mercury cycle in northern climates. This part of the study should focus on exchanges between the atmosphere, surface water, and the terrestrial environment, and on the timeframe and characteristics of soil decomposition. It should also explain the physical, chemical and biological factors which govern them, as well as the inherent particularities of the study area.

353. The Proponent shall review the current state of the available knowledge on the bioaccumulation and toxicity of methylmercury with respect to fish, mammals and avifauna, and its sublethal effects on growth, survival and reproduction.

354. The Proponent shall provide an evaluation of the available analytical methods to determine the proportion of inorganic and organic mercury compounds, including methylmercury, in the environment. This evaluation shall deal with the various systems used for classifying types 6f mercury compounds and their significance. The Proponent shall also discuss operational constraints that affect the taking and storing of samples, as well as the limits of detection and reproducibility. The substrata analyzed should include at least organic and inorganic soils, water, and biological tissues, mainly from fish, birds and vegetation.

355. The Proponent shall determine current contamination levels and bioaccumulation rates for the various species of fish and marine mammals of each drainage basin affected by the proposed project, including marine and estuarine ecosystems. This study should specifically examine at least two piscivorous and two non-piscivorous species. The Proponent shall provide the models used, which shall take into account the half-life of methylmercury in the flesh of fish inhabiting reservoirs. The Proponent shall define the model(s) selected and justify its (their) choice. These reference data shall be measured in order to permit monitoring of future changes in mercury levels. The Proponent shall also determine the degree of bioaccumulation of methylmercury in the principal marine mammals in Hudson Bay and in piscivorous birds, as well as the distribution of organic mercury in the edible tissues and organs. If freshwater seals are included in the sampling, the study of mercury contamination shall include these animals.

356. Finally, the Proponent shall provide a study of mercury bioaccumulation downstream from hydroelectric projects, indicating the likely role of various bioassimilation pathways and the factors that govern the extent of this phenomenon.

3.30 Provide an updated review of the literature concerning mercury in the environment, and include a discussion of the current state of knowledge of biogeochemical pathways of mercury in the marine environment.

3.31 With respect to the estuarine and marine environments, discuss mercury sources, distinguishing between long-range transport of airborne mercury and influxes of mercury originating from inland waters. With respect to inland waters, discuss as well mercury sources, distinguishing between airborne and geological mercury sources.

3.32 Provide references or quantitative data to support the discussion in the EIS concerning the increase in mercury levels in lake sediments over the last 60 years.

3.33 Discuss the food chain for the organisms in Manitounuk Sound, from plankton through to marine mammals, indicating quantitatively how methylmercury might accumulate at each step in the chain.

3.34 Indicate the rates of methylmercury bioaccumulation in the tissues of important piscivorous animal species, including marine mammals. Quantify the levels of methylmercury in the tissues of piscivorous birds in the study area, either from actual measurements, or by applying a conversion factor to measurements of total mercury levels.

3.35 In light of the limited number of samples taken, justify the reliability of methylmercury estimates in the natural freshwater and marine biota (including that of Hudson Bay in the vicinity of the Belcher Islands). Provide additional data concerning methylmercury levels in marine mammals, or describe the ratio of total mercury to methylmercury in these animals.

3.36 Provide details of the work carried out at La Grande concerning downstream mercury transfer, including a quantitative comparison of methylmercury levels found in whitefish upstream and downstream from the powerhouses. Discuss the ways in which forage fish contribute to downstream mercury transfer, and quantitatively evaluate the extent to which it would occur downstream from the reservoirs of the proposed project.

3.37 Discuss the Current state of knowledge on the sublethal effects of mercury on fish, birds and terrestrial mammals.

3.38 The flooding of peatlands and permafrost areas could result in the release of large amounts of trace metals (e.g., lead, aluminum, zinc, arsenic) into reservoirs. Indicate the trace metal composition of peatlands and permafrost in those regions which would be flooded by the proposed project.

3.39 Quantify the concentrations of trace metals in the inland waters of the study area, and discuss the factors which regulate trace metal levels in northern freshwater systems. Discuss the evolution of the levels of contaminants (e.g., trace metals, organochlorine insecticides) in the waters of the study area, as well as any potentially synergistic relationships among contaminants.

3.40 Using available data, indicate the current levels of trace metals in the flesh of those fish species which are consumed by the human inhabitants of the study area. Indicate the concentrations of these contaminants which are considered dangerous to human health.

3.41 From the available information, discuss trace metal levels in marine mammal tissue.

Upland and Wetland Ecosystems

GUIDELINES paras. 357 to 373

UPLAND AND WETLAND ECOSYSTEMS:

357. Upland vegetation and ecotones must be analyzed in terms of their indigenous plant communities (rare species, typical plant communities, area of distribution, limiting factors, etc.) and as animal habitat.

358. Plant communities. The Proponent shall describe the composition, distribution, controlling factors and dynamics of the most common plant communities, their soil and moisture requirements, and the role played by disturbances such as forest fires, and their role in supporting wildlife. Particular attention shall be paid to the dwarf willow (salix spp.) stands used by ptarmigan in winter for feeding and shelter.

359. Wetland habitats. The Proponent shall classify the different types of wetland habitats based on plant communities and on drainage system type, in order to define the habitats that might be lost. Certain areas are of particular importance: Lac Bienville, the lower Coats and the Geoffroy River valleys, the Lac Paimpont region, and areas around Lac Kakupis and Lac Elizabeth.

360. Forest ecosystems. The Proponent shall describe the age structure of the region's forest ecosystems, using representative samples. The Proponent shall produce a map indicating plant communities in the study area and the distinctive physiographic seres in all sites affected by the proposed hydroelectric developments. Discussion of these physiographic seres shall include the type of bedrock, surficial deposits, drainage classes, soils, gradients (in degrees), and plant communities representative of the ecosystem by altitude class.

361. Rare species. The Proponent shall then discuss plant communities of interest to the region: rare plants, exceptional, endangered or regionally significant populations, range extensions, special habitats, and areas used by Native peoples where species of interest (for food, medicine, etc.) are found. These populations are to be localized and described using the remote sensing studies of the last twenty years, where appropriate.

362. Regeneration and reclamation. The Proponent shall examine current conditions to determine the regeneration rates of ecosystems in northern regions which have previously been disturbed by fire. The Proponent shall present current knowledge concerning the growth and regeneration of the main forest species and concerning reforestation of the region's spruce and pine forests. The Proponent shall especially take into consideration the experience acquired in the course of reclamation work carried out at the La Grande complex and elsewhere, and shall explain to what extent such work might be suitable for the region of the Great Whale complex.

363. Burnt-over land and fires. One probable consequence of opening the territory is the increased risk of forest fires. To evaluate the impact of fires, the Proponent shall describe the areas that have burnt over the past 30 years. This evaluation shall include maps of burnt-over areas, the origin and date of the fires (if known), and the current status of the area (including any regeneration problems) and its use by wildlife and humans. This can be done making use of available remote sensing studies.

364. Wildlife habitats. An assessment shall be made of the quality and the quantity of available wildlife habitats, and particularly of those riparian and wetland habitats which could be lost or significantly affected by the proposed project, notably through the creation and operation of reservoirs. While riparian and wetland habitats may merit special focus, all habitats important for avifauna of any sort, for caribou (and other mammals) and for significant fish species must also receive special attention. The Proponent shall therefore determine the composition, diversity, and richness of wildlife species associated with these habitats, and shall also evaluate the wildlife productivity of each vegetation group for the region as a whole. Special attention shall be given to the factors most likely to affect the distribution of animals throughout the region.

365. Land animals. The Proponent shall describe the wildlife and its habitat in order to assess likely losses in number and biomass and in harvesting by all users, should the project proceed. For key species of birds and mammals (including caribou), the Proponent shall provide estimates of the following: body condition, age and sex ratios, habitat use, age of maturity, reproductive rates and success, mortality factors and rates of mortality. Key species shall be identified on the basis of, among other things, their abundance and their importance to the Native harvest, including that of the Naskapis and other Native groups.

366. Caribou. The Proponent shall present existing knowledge of the density and distribution of caribou and their population cycles over the past decades, and of the habitats used by this species during the course of one full year, including the migratory routes and birthing grounds used and their location with respect to the areas affected by the proposed project. The study shall include seasonal as well as year-to-year variations. The Proponent shall distinguish between the Lac Bienville herd (animals native to this region) and the Riviere George and Riviere aux Feuilles herds; which are used by the Naskapis, and shall specify how each herd uses the area proposed for development for migration, feeding and calving, and how the herds interrelate in terms of population dynamics. The Proponent shall outline the limiting factors (birthing grounds, habitats, predation, availability of food, poaching, resource development, hunting, climate, etc.) that have or could have an effect on caribou numbers and thus their density and distribution within the specific context of the study area.

367. Fur-bearing animals and other mammals. The Proponent shall provide and analyze inventories on the population dynamics, rate of exploitation, density, distribution, limiting factors and preferred habitats of the beaver, muskrat, mink, otter, wolverine, wolf, marten, red fox, arctic fox, fisher, black bear, polar bear, snowshoe hare, Arctic hare, musk ox and moose in the study area. Consideration shall also be given to any marine mammals, such as seals and belugas, likely to be found in brackish and fresh water. For species with a regular population cycle, the Proponent shall interpret data on population density and habitat use in light of the stage of the population cycle.

Birds:

368. The Proponent shall provide an inventory and analysis of current bird populations (local and migratory), evaluating the number, distribution and life-cycle of bird species, especially waterfowl species of interest to Native peoples, and shall study their productivity and the factors governing it. The Proponent shall also provide an inventory of migratory birds of special interest to birdwatchers and hunters of North America.

369. Current information shall be presented on the use by waterfowl of the east coast of Hudson Bay, including the Belcher Islands, especially Manitounuk Sound, paying special attention to the elder duck. In addition, the importance of eelgrass beds, particularly to the Brent, shall be examined. The territory under study shall include the area from Long Island to the Nastapoka River estuary, as well as any other sector where resources could be affected.

370. In the Lac Bienville area, particular attention shall be paid to the Canada Goose, the Surf Scoter and the Black Scoter. Most importantly, the factors likely to affect the reproductive success of these last two species shall be discussed.

371. Ice-free zones at the foot of rapids in the rivers within the study area are extremely important to certain avian species. The Proponent shall locate and identify these zones and describe them in terms of the number of species that use them, their respective abundance, and their importance as a determining factor in the ecology of each species.

Vulnerable, rare, or threatened species and ecological reserves:

372. From the standpoint of ensuring the diversity of species in the study area, the Proponent shall discuss the preservation of vulnerable, rare, or threatened species in the area concerned, as well as that of relevant plant communities and fragile ecosystems. This process will require input from various agencies, both provincial (ministere de l'Environnement [MENVIQ] and ministere des Loisirs, de la Chasse et de la Peche [MLCP]) and federal (Environment Canada), as well as from the Native communities. The Proponent shall consult with them concerning flora, plant communities, land and marine mammals, fish and birds. Current information shall then be discussed, and any inventories deemed necessary by government authorities in order to permit a decision on the proposed project shall be performed. The Proponent shall present the current and anticipated protection programs which are or will be in effect in this area.

373. The Proponent shall provide a map showing all projected installations and the seven sites in the vicinity which are under consideration by the relevant government agencies as potential ecological or natural reserves. These sites are: Lac Bienville, Lac Burton and Riviere Roggan, Lac a' l'Eau Claire, Lac Guillaume-Delisle, Pointe Louis XIV, and Lacs des Loups Marins. The map should allow the assessment of potential modifications to these natural systems.

3.42 Describe the floral richness and composition of each major type of plant community in the areas which would be affected by the proposed project. Describe the dynamics of the main types of plant communities in the study area especially those communities which occur as successional stages during the transformation of a post-burn barren area into a mature spruce forest. Describe the faunal richness and composition associated with each main plant community type, and quantify the relative importance of the main plant community types as wildlife habitat and food.

3.43 Identify those areas and plants within the region that would be affected by the proposed project where Native people now frequently harvest plants used for food or medicine.

Caribou

GUIDELINES para. 366

366. Caribou. The Proponent shall present existing knowledge of the density and distribution of caribou and their population cycles over the past decades, and of the habitats used by this species during the course of one full year, including the migratory routes and birthing grounds used and their location with respect to the areas affected by the proposed project. The study shall include seasonal as well as year-to-year variations. The Proponent shall distinguish between the Lac Bienville herd (animals native to this region) and the Riviere George and Riviere aux Feuilles herds; which are used by the Naskapis, and shall specify how each herd uses the area proposed for development for migration, feeding and calving, and how the herds interrelate in terms of population dynamics. The Proponent shall outline the limiting factors (birthing grounds, habitats, predation, availability of food, poaching, resource development, hunting, climate, etc.) that have or could have an effect on caribou numbers and thus their density and distribution within the specific context of the study area.

3.44 Provide a more complete review of the published literature and available data (including results obtained from community consultations and traditional ecological knowledge, identified as such) concerning the density and distribution of caribou in Northern Quebec, their population cycles over the past decades, the various types of habitats used by caribou populations during the course of the year, and the location and extent of these habitats (with emphasis on the areas to be affected by the proposed project). Provide data concerning caribou population dynamics. Any variability or uncertainty inherent in the data or conclusions of cited papers shall be clearly indicated.

3.45 Provide a quantitative assessment of the body condition of the caribou which utilize the study area, and discuss the various interacting factors which affect caribou body condition

3.46 Based upon the most recent data available, indicate the degree to which an exchange of individuals occurs among the Lac Bienville, Riviere George, and Riviere aux Feuilles caribou herds during the winter period when they occupy the same range.

Furbearers and Other Mammals

GUIDELINES para. 367

367. Fur-bearing animals and other mammals. The Proponent shall provide and analyze inventories on the population dynamics, rate of exploitation, density, distribution, limiting factors and preferred habitats of the beaver, muskrat, mink, otter, wolverine, wolf, marten, red fox, arctic fox, fisher, black bear, polar bear, snowshoe hare, Arctic hare, musk ox and moose in the study area. Consideration shall also be given to any marine mammals, such as seals and belugas, likely to be found in brackish and fresh water. For species with a regular population cycle, the Proponent shall interpret data on population density and habitat use in light of the stage of the population cycle.

3.47 Where such data has not been provided in the EIS, provide estimates of abundances of the key species of mammals, excluding caribou, which are of importance to communities within the project area, or which inhabit areas that would be affected by the proposed project. Indicate the level of harvest and monetary value of the furbearers and meat to Natives.

Birds

GUIDELINES paras. 368 to 371

Birds

368. The Proponent shall provide an inventory and analysis of current bird populations (local and migratory), evaluating the number, distribution and life-cycle of bird species, especially waterfowl species of interest to Native peoples, and shall study their productivity and the factors governing it. The Proponent shall also provide an inventory of migratory birds of special interest to birdwatchers and hunters of North America.

369. Current information shall be presented on the use by waterfowl of the east coast of Hudson Bay, including the Belcher Islands, especially Manitounuk Sound, paying special attention to the elder duck. In addition, the importance of eelgrass beds, particularly to the Brent, shall be examined. The territory under study shall include the area from Long Island to the Nastapoka River estuary, as well as any other sector where resources could be affected.

370. In the Lac Bienville area, particular attention shall be paid to the Canada Goose, the Surf Scoter and the Black Scoter. Most importantly, the factors likely to affect the reproductive success of these last two species shall be discussed.

371. Ice-free zones at the foot of rapids in the rivers within the study area are extremely important to certain avian species. The Proponent shall locate and identify these zones and describe them in terms of the number of species that use them, their respective abundance, and their importance as a determining factor in the ecology of each species.

3.48 Provide data concerning the biology of key bird species of interest to Native people, bird-watchers, and non-Native hunters where such information has not been provided. In particular, indicate population trends and geographic distribution in the study area. Indicate trends linking prevailing meteorological conditions and other environmental factors with nesting phenology and success. Provide information concerning the use of the study area by migrant and wintering birds, including a map of migration routes. Discuss population estimates for the years during which surveys were conducted, in light of long-term population trends.

3.49 Maps provided in the EIS which indicate densities of geese, black scoters, and surf scoters in the study area lack sufficient resolution to provide the reader with any more than a very coarse indication of how the numbers of these birds vary in the vicinity of Lac Bienville. Provide a review of available knowledge concerning the factors which influence the reproductive success of black and surf scoters, and discuss why the Lac Bienville area represents such a good breeding habitat for these birds. Provide data concerning the average brood size and nesting success of Canada geese and, for black and surf scoters, the physical condition of pre-nesting females and the reactions of brooding females to human disturbance.

3.50 Identify locations of ice-free zones associated with rapids in the waterways of the affected area, the bird species that use them, and their importance to avian ecology (especially that of the harlequin duck).

Vulnerable, Rare or Threatened Species

GUIDELINES para. 372

372. From the standpoint of ensuring the diversity of species in the study area, the Proponent shall discuss the preservation of vulnerable, rare, or threatened species in the area concerned, as well as that of relevant plant communities and fragile ecosystems. This process will require input from various agencies, both provincial (ministere de l'Environnement [MENVIQ] and ministere des Loisirs, de la Chasse et de la Peche [MLCP]) and federal (Environment Canada), as well as from the Native communities. The Proponent shall consult with them concerning flora, plant communities, land and marine mammals, fish and birds. Current information shall then be discussed, and any inventories deemed necessary by government authorities in order to permit a decision on the proposed project shall be performed. The Proponent shall present the current and anticipated protection programs which are or will be in effect in this area.

3.51 Describe and map the locations of fragile valued ecosystems within the regions affected by the proposed project.

3.52 Present descriptions and precise locations of rare plant species mentioned in the EIS, specifying the methods used in collecting the data.

3.53 Identify potential reproductive habitats of the harlequin duck outside the study area, and provide relevant data to support the assumption that the known population is underestimated.

3.54 Define the specific limits of the hunting territories used by golden eagles which have been seen in the study area.

Communities Affected by the Project

GUIDELINES paras. 374 to 385

COMMUNITIES AFFECTED BY THE PROJECT:

374. The Proponent shall update the economic, social and cultural profile of the affected northern communities (KuujjuarapiklWhapmagoostui, Chisasibi, Radisson, Umiujak, Inukjuak and Sanikiluaq) concentrating mostly on the second half of the twentieth century (1950 to date) and highlighting the determining evolutionary factors for every community, paying particular attention to current characteristics that make the communities more or less open to changes.

375. The Proponent shall review existing information pertaining to the demographics of the Northern environment in order to present a demographic profile of each community that might be affected by the development of the proposed Great Whale River hydroelectric complex. This profile should include possible future scenarios for demographic dynamics, making clear the limitations inherent in forecasting the demographic characteristics of each community.

376. The Proponent shall describe the economy of each community. Notwithstanding the present activities and future opportunities for employment and for the production of goods and services by Natives for their specific needs, this profile shall deal specifically with the evolution since the 1950s of the hunting, fishing, and gathering economy, as well as other traditional and commercial activities, taking into account the institutional structure introduced by the JBNQA. The Proponent shall draw a historic and current portrait of land use (1950-1975 and 1975-1990) in the area affected by the proposed project. Traditional and modern land use in the study area including Belcher Islands by Natives and non-Natives shall be clearly identified. Areas which are considered of particular interest to government bodies or other groups interested in the protection and development of the region (parks, reserves, conservation areas, sites or watercourses of interest for recreation or tourism, etc.) will be identified and justified with respect to the objectives of the Natives and non-Natives.

377. In addition, the Proponent shall study the influence of current transportation systems on the cost and availability of goods and services in the communities, shall identify present methods of transportation (on land and water) for accessing the territory and hence for gathering activities, and the degree to which they are used, and the costs of using the current system. Bodies of water in whole or in part used by Natives and non-Natives shall be identified, and a detailed description of the type and density of navigation on those waters shall be provided.

378. In addition to economic activities and transportation Systems, the Proponent shall discuss the various ways the land is used and occupied (for subsistence, recreation, therapeutic or religious purposes, etc.) and shall study their relationship with the social structures and symbol systems of the Natives.

379. In so doing, and because the proposed project would take place within the framework of various land tenure systems established under the JBNQA and other laws that might apply, the Proponent shall indicate how the proposed project would take into account the land tenure systems applicable to the various land categories, including the land along Hudson Bay and Manitounuk Sound. Moreover, the Proponent shall describe in detail any changes the project could cause to the land tenure systems. To better define these changes, the Proponent shall provide the history of the land tenure system in the study area. This description will take into account changes made both prior to and subsequent to the signing of the JBNQA in 1975.

380. Special attention shall be paid to the use of land along Manitounuk Sound and the Great Whale, Little Whale and Nastapoka river estuaries in relation to the distribution of resources, and to their use by the inhabitants of Kuujjuarapik and Whapmagoostui and other populations. This review shall outline the current situation and future prospects, taking into account the social structures, spiritual values, harvesting levels, and the importance of traditional foods. The Proponent shall seek to learn about the possible solutions and alternatives under consideration by the Natives themselves, should access to the territory be substantially modified.

381. The Proponent shall provide an overall assessment of current archaeological knowledge of the study area, including a detailed description of the methodology used in its program to identify potential archaeological sites. The assessment of the archaeological surveys shall include a description and an interpretation of archaeological sites that have already been excavated. These shall be interpreted in the context of the prehistory of Quebec and particularly Northern Quebec.

382. This archaeological and historical study will require close collaboration with numerous specialists, including those of the archaeology service of the Ministere des Affaires culturelles, the Cree Regional Authority and the Avataq Cultural Institute.

383. The Proponent shall study the quality of life of the communities, paying particular attention to mortality and morbidity, suicide rates, and all matters related to conjugal and family violence. The Proponent shall also describe the importance of traditional food sources and their availability in the diet of the communities in relation to food sources from the South. Furthermore, on the basis of available data, the Proponent shall establish a portrait of local health, using the principal diseases that provide indices of public health (in particular, diabetes, neoplasm and infectious diseases). The Proponent shall indicate the period over which the study of health-related problems in the region will take place. Finally, on the basis of available data, the Proponent shall discuss the extent and significance of substance abuse.

384. The Proponent shall pay particular attention to social organization and symbol systems. These include such aspects as relationship to the land, social cohesion and dynamics (as opposed to the breakdown of the social organization), ties to other Native and non-Native communities, social identity, self-esteem, systems for explaining and accepting changes, common visions of the future, etc.

385. The Proponent shall analyse perceptions of the proposed project in the communities, in relation to their own visions of the future.

3.55 The description of the human environment in the communities affected by the project is inadequate, and the Proponent is redirected to respond to GUIDELINES paragraphs 374 to 385 in the description of the social environment. This shall be done in an integrated fashion, based on a comprehensive use of the literature and the results of adequate study and consultation in conjunction with the affected peoples.

3.56 Describe and justify the methods used in acquiring knowledge of the societies and cultures of the indigenous inhabitants of the area.

3.57 Provide future scenarios for the demographic evolution of each of the communities affected, including migration to the South, and address all of the demographic indicators of the populations or segments of the population, which would most likely be affected by the project.

Access to the Territory and to Resources

GUIDELINES paras. 376 to 378

376. The Proponent shall describe the economy of each community. Notwithstanding the present activities and future opportunities for employment and for the production of goods and services by Natives for their specific needs, this profile shall deal specifically with the evolution since the 1950s of the hunting, fishing, and gathering economy, as well as other traditional and commercial activities, taking into account the institutional structure introduced by the JBNQA. The Proponent shall draw a historic and current portrait of land use (1950-1975 and 1975-1990) in the area affected by the proposed project. Traditional and modern land use in the study area including Belcher Islands by Natives and non-Natives shall be clearly identified. Areas which are considered of particular interest to government bodies or other groups interested in the protection and development of the region (parks, reserves, conservation areas, sites or watercourses of interest for recreation or tourism, etc.) will be identified and justified with respect to the objectives of the Natives and non-Natives.

377. In addition, the Proponent shall study the influence of current transportation systems on the cost and availability of goods and services in the communities, shall identify present methods of transportation (on land and water) for accessing the territory and hence for gathering activities, and the degree to which they are used, and the costs of using the current system. Bodies of water in whole or in part used by Natives and non-Natives shall be identified, and a detailed description of the type and density of navigation on those waters shall be provided.

378. In addition to economic activities and transportation Systems, the Proponent shall discuss the various ways the land is used and occupied (for subsistence, recreation, therapeutic or religious purposes, etc.) and shall study their relationship with the social structures and symbol systems of the Natives.

3.58 Provide an analysis of the evolution of land use practices since the

1950's, for the communities affected, and describe the traditional Native harvesting activities and practices. This analysis shall include maps of traditional travel routes and hunting, fishing and trapping areas, and shall also analyse how these activities are organized as well as their economic, social and spiritual relevance.

3.59 Define and locate sites that warrant protection because they are unique or remarkable or because they have a particular cultural value for the Native communities.

Health of the Communities

GUIDELINES para. 383

383. The Proponent shall study the quality of life of the communities, paying particular attention to mortality and morbidity, suicide rates, and all matters related to conjugal and family violence. The Proponent shall also describe the importance of traditional food sources and their availability in the diet of the communities in relation to food sources from the South. Furthermore, on the basis of available data, the Proponent shall establish a portrait of local health, using the principal diseases that provide indices of public health (in particular, diabetes, neoplasm and infectious diseases). The Proponent shall indicate the period over which the study of health-related problems in the region will take place. Finally, on the basis of available data, the Proponent shall discuss the extent and significance of substance abuse.

3.60 Examine the health of the communities, extending this discussion beyond the use of statistical measurements. Provide a qualitative portrait of the health of the communities, identifying links between social problems and their causes. In doing so, integrate relevant literature (including Sante Quebec's 1992 study of aboriginal health in Northern Quebec).

3.61 For the communities which would be affected by the project, provide complete information concerning illnesses which serve as indices of public health, such as diabetes, cancers (neoplasms), and infectious diseases, and provide statistical data concerning substance abuse, by age group. Provide statistical data on conjugal and familial violence in the communities affected by the project and compare the rates of mortality, suicide, accidents and social problems in these communities with those in the rest of Quebec, using existing studies.

3.62 Evaluate the consumption of traditional food sources relative to the consumption of foods imported from the South, and discuss the relationship between each type of food and indices of individual and community health. Complete this discussion with data gathered from consultation with the affected communities.

3.63 Using information obtained at La Grande, as well as other applicable research, provide information concerning neurotoxic or other effects of methylmercury on children, pregnant women and breast-feeding infants.

Archaeology and History

GUIDELINES paras. 381 and 382

381. The Proponent shall provide an overall assessment of current archaeological knowledge of the study area, including a detailed description of the methodology used in its program to identify potential archaeological sites. The assessment of the archaeological surveys shall include a description and an interpretation of archaeological sites that have already been excavated. These shall be interpreted in the context of the prehistory of Quebec and particularly Northern Quebec.

382. This archaeological and historical study will require close collaboration with numerous specialists, including those of the archaeology service of the Ministere des Affaires culturelles, the Cree Regional Authority and the Avataq Cultural Institute.

3.64 Provide a synthesis and discussion of the archaeological work that has been undertaken in the territory, including the results of archaeological site surveys.

3.65 Complete the systematic inventory of the burial sites by carrying out appropriate consultations with the local population.

3.66 Specify the nature of the collaboration undertaken for archaeological studies with Cultural Affairs, the Cree Regional Authority and the Avataq Cultural Institute, and incorporate the results of pertinent studies carried out in this context by these organizations.

CHAPTER 4

PROJECT DESCRIPTION

The Great Whale hydroelectric complex is designed in such a way as to add 3 212 MW of power to the Proponent's system and generate 16.2 TWh of energy on average per year. A description of the complex, the associated infrastructures required, and the proposed collector system, is essential to an understanding of the effects of the proposed project. In particular, this description must include all information necessary to allow a reasonable comparison between the different design and development variants and options for the proposed project.

While the Proponent has provided a large amount of information about the complex and its components in the EIS, which permits a general understanding of the project, some specific information required in the GUIDELINES is missing. In particular, additional information is required on costs and design options and development variants, including those related to various construction schedules. Additional information is specifically required for the assessment of the impacts of locating the GB 1 tailrace canal in Manitounuk Sound and for a clear understanding of the choices underlying the proposed design of the Bienville Reservoir.

As for the associated infrastructures such as camps, waste disposal sites, waterway crossings, quarries and borrow pits, the degree of detail provided is generally insufficient for an adequate understanding of the process by which these infrastructures and their locations were selected. In the event that the project is authorized, this information will have to be provided to the Committees and Commissions for review. Associated procedures such as emergency plans and management of hazardous wastes and products will also have to be defined in greater detail.

The following requirements of this Chapter are addressed to the Proponent to provide the Review Bodies with a description of the proposed project that is complete and adequate.

Costs of the Project and Schedules

GUIDELINES paras. 407 and 412

407. The Proponent shall provide a detailed schedule for each phase of the construction of the selected project, clearly indicating all required flexibility. When appropriate, impacts related to possible variation in the schedule shall be evaluated. Any eventual authorization shall be based on a project with well defined dates. As described in paragraph 110, any significant change in the planned schedule could therefore justify a new public review by the review bodies or a new authorization by the administrators. The Proponent shall also indicate the costs of each project component.

HYDROELECTRIC COMPLEX:

412. The Proponent shall provide a detailed description of all work required for project construction including the following subjects:

1. time of the year, frequency and amplitude (maximum and minimum levels) of water level fluctuation ranges for all water bodies;

2. the maximum and minimum surface areas of reservoirs and forebays, with detailed maps, and residence time of water masses;

3. volume and description of debris in flooded areas, and their disposal methods;

4. flow rates (maximum, minimum and average) in the sections of the rivers affected, with detailed maps showing the areas affected and seasonal variations in water levels;

5. the types of dikes and dams, with their locations mapped;

6. maximum and minimum operating levels;

7. a description of the generating stations, with emphasis on the information required to understand and evaluate the project;

8. turbine types, maximum gross head and maximum quantity of turbined water;

9. the height and amount of backfill;

10. the dimensions and types of the spillways, with the number of gates, and the maximum capacity;

11. the dimensions, orientation and position of the tailrace canal and related structures;

12. diversion works;

13. a complete construction schedule based on each plausible set of hypotheses;

14. a schedule of costs for each phase of construction; and

15. the life span of the dams and dikes, the security factors used in their design, and their safety over the long term.

4.01 Provide the total cost of the project, broken down by component (hydroelectric complex, transportation infrastructure, collector system, and related infrastructure) and by year of expenditure, as well as any other costs attributable to the Great Whale project, including all necessary modifications to the transmission system south of Radisson and all prior expenditures for environmental and engineering studies. Costs shall be provided in nominal and constant dollars, using a single reference year. The total investment in current dollars required to build the Great Whale complex shall also be given, taking into account inflation and interest payments until the end of construction. Finally, calculations of the real levelized unit cost of the Great Whale project, with annotations, shall be provided.

4.02 What are the major uncertainties affecting construction cost estimates, and how have they been incorporated into those estimates?

4.03 Evaluate in detail the degree of flexibility of the project schedule once construction has started. To what extent can construction be accelerated or delayed at various stages of completion, and at what cost?

4.04 Evaluate the impacts of extending the construction period by two to four years on the need for temporary structures such as the Lac Fagnant airport, winter roads and construction camps. Discuss in turn the economic, social and environmental repercussions of such an extension.

Design Options

GUIDELINES paras. 414 to 421

Design options:

414. The Proponent shall provide a description of each design option and its environmental repercussions, and shall explain the reasons for the choices made. The Proponent shall indicate whether any of the design options are to be revised or specified in greater detail before the commencement of the construction work. The following design options are based on impact studies submitted in the early 1980s. Any new design options that have been considered or are under consideration shall also be discussed.

415. Location of the GB1 generating station. The Proponent shall compare the economic, environmental and technical implications of locating the GB1 generating station in the Lebel, Domanchin or Great Whale river valleys.

416. Optimization of forebays (GB1, GB2, GB3 and Bienville). The Proponent shall describe the relationship between operating criteria for the forebays and the conditions necessary for managing fish habitats, and shall demonstrate how environmental considerations will affect the selection of minimum and maximum operating levels.

417. Spillways. The location of spillways shall take into account the design options for all structures in the proposed complex. In particular, a study shall be presented comparing the consequences of locating the GB1 spillway on Manitounuk Sound or on the Great Whale River. This study shall identify the main environmental, technical and economic issues related to both options, with emphasis on (a) maintaining controlled flow in the river, and (b) managing water levels in this area.

418. Load factors. The Proponent shall define the principal consequences related to the choice of load factor for the selected project. The Proponent shall devote particular attention to effects on ice conditions and the freshwater/ saltwater mix in Manitounuk Sound, as well as to the chemical, sedimentological, and biological impacts of modifications to circulation and exchange mechanisms.

419. GB1 generating station tailrace canal. In preliminary studies of the Great Whale complex in the early 1980s, the Proponent stated that the exchange of fresh water and salt water in Manitounuk Sound would depend on the location and geometry of the GB1 generating station tailrace canal as well as its vertical and horizontal positioning. The design of the tailrace canal thus requires environmental optimization, based on a profound understanding of the physical, chemical, sedimentological and biological oceanography of Manitounuk Sound. Technical documentation explaining the range of plausible scenarios with regard to tailrace design must be provided. The Proponent shall discuss the hydraulic and environmental criteria that have been used to demonstrate the relationship between tailrace design and environmental objectives. This analysis shall also take into account studies on the formation, break-up, and composition of the ice, and of polynyas. The Proponent shall pay particular attention to the choice of dimensions and shape of the tailrace canal, its horizontal and vertical position in relation to sea level and to pycnocline in Manitounuk Sound, and the rate of discharge into the local marine environment. Special attention shall be paid to the following environmental considerations: stratification density, local erosion, turbidity, sedimentology, primary production, ice conditions and the destruction of eelgrass beds and benthic organisms. In addition, consideration shall be given to the impact of the design of the tailrace canal on Native use of Manitounuk Sound. The Proponent shall also pay particular attention to blasting requirements for the various tailrace designs under study. The criteria for the use of explosives shall be established and justified, and detailed control procedures shall be presented. The Proponent shall formulate a formal blasting protocol that indicates what level of collateral damage is acceptable and prescribes under what conditions the blasting program shall be suspended and reconsidered.

420. Protection of Lac Kakupis. The Proponent shall study the possibility of protecting Lac Kakupis completely, for instance by raising water levels in Lac Elizabeth so as to channel the diverted waters into the Riviere Coats. Problems related to dredging the shallows shall also be considered.

421. The Bienville reservoir. The Proponent shall report on studies concerning the maximal dimensions of the Bienville reservoir, as mentioned in the information provided by the Proponent. The possibility of modifying the dikes and limiting the extent of the flooded areas in the region near Lac Bienville shall also be taken into account. In this regard, the advantages of reducing flooding in the Lac Bienville region and the disadvantages of raising water levels in the GB3 and Paimpont regions shall be compared.

4.05 The comparative analysis that has led to favouring the option of locating the GB 1 powerhouse in the Domanchin valley over the option involving a chain of three generating stations on the downstream section of the Great Whale River has shown the clear economic advantages of the former. However, a comparative analysis of the environmental and social effects of these two options is not presented in sufficient depth. Since most of the impacts on Manitounuk Sound could be avoided by locating the powerhouses on the Great Whale River, provide a more detailed comparison of the social and environmental impacts of these two options on the lower Great Whale River and on Manitounuk Sound.

4.06 Describe the effects of an increase or a decrease in the load factor of the complex on the amplitude and frequency of reservoir drawdown and on spillage. Discuss in turn the effects of these changes on environmental impacts in Manitounuk Sound and in affected river sections. Finally, discuss the effects of such changes on the operation of existing generating facilities and on the need for additional resources in the energy network of the Proponent.

Guaranteed Flow

GUIDELINES para. 417

417. Spillways. The location of spillways shall take into account the design options for all structures in the proposed complex. In particular, a study shall be presented comparing the consequences of locating the GB1 spillway on Manitounuk Sound or on the Great Whale River. This study shall identify the main environmental, technical and economic issues related to both options, with emphasis on (a) maintaining controlled flow in the river, and (b) managing water levels in this area.

4.07 The EIS does not specifically address the issue of costs and benefits associated with guaranteed flow. Specify the economic and environmental costs and benefits for varying levels of guaranteed flow downstream from each diversion structure or powerhouse.

Spillways

GUIDELINES paras. 412 and 417

412. The Proponent shall provide a detailed description of all work required for project construction including the following subjects:

1. time of the year, frequency and amplitude (maximum and minimum levels) of water level fluctuation ranges for all water bodies;

2. the maximum and minimum surface areas of reservoirs and forebays, with detailed maps, and residence time of water masses;

3. volume and description of debris in flooded areas, and their disposal methods;

4. flow rates (maximum, minimum and average) in the sections of the rivers affected, with detailed maps showing the areas affected and seasonal variations in water levels;

5. the types of dikes and dams, with their locations mapped;

6. maximum and minimum operating levels;

7. a description of the generating stations, with emphasis on the information required to understand and evaluate the project;

8. turbine types, maximum gross head and maximum quantity of turbined water;

9. the height and amount of backfill;

10. the dimensions and types of the spillways, with the number of gates, and the maximum capacity;

11. the dimensions, orientation and position of the tailrace canal and related structures;

12. diversion works;

13. a complete construction schedule based on each plausible set of hypotheses;

14. a schedule of costs for each phase of construction; and

15. the life span of the dams and dikes, the security factors used in their design, and their safety over the long term.

417. Spillways. The location of spillways shall take into account the design options for all structures in the proposed complex. In particular, a study shall be presented comparing the consequences of locating the GB1 spillway on Manitounuk Sound or on the Great Whale River. This study shall identify the main environmental, technical and economic issues related to both options, with emphasis on (a) maintaining controlled flow in the river, and (b) managing water levels in this area.

4.08 Month-by-month simulation, as used in the EIS, has a tendency to underestimate the maximum daily discharge at the various spillways. For the GB 1 spillway, provide an estimate of the maximum daily discharge and their frequencies.

GB 1 Tailrace Canal in Manitounuk Sound

GUIDELINES paras. 412 and 419

412. The Proponent shall provide a detailed description of all work required for project construction including the following subjects:

1. time of the year, frequency and amplitude (maximum and minimum levels) of water level fluctuation ranges for all water bodies;

2. the maximum and minimum surface areas of reservoirs and forebays, with detailed maps, and residence time of water masses;

3. volume and description of debris in flooded areas, and their disposal methods;

4. flow rates (maximum, minimum and average) in the sections of the rivers affected, with detailed maps showing the areas affected and seasonal variations in water levels;

5. the types of dikes and dams, with their locations mapped;

6. maximum and minimum operating levels;

7. a description of the generating stations, with emphasis on the information required to understand and evaluate the project;

8. turbine types, maximum gross head and maximum quantity of turbined water;

9. the height and amount of backfill;

10. the dimensions and types of the spillways, with the number of gates, and the maximum capacity;

11. the dimensions, orientation and position of the tailrace canal and related structures;

12. diversion works;

13. a complete construction schedule based on each plausible set of hypotheses;

14. a schedule of costs for each phase of construction; and

15. the life span of the dams and dikes, the security factors used in their design, and their safety over the long term.

419. GB1 generating station tailrace canal. In preliminary studies of the Great Whale complex in the early 1980s, the Proponent stated that the exchange of fresh water and salt water in Manitounuk Sound would depend on the location and geometry of the GB1 generating station tailrace canal as well as its vertical and horizontal positioning. The design of the tailrace canal thus requires environmental optimization, based on a profound understanding of the physical, chemical, sedimentological and biological oceanography of Manitounuk Sound. Technical documentation explaining the range of plausible scenarios with regard to tailrace design must be provided. The Proponent shall discuss the hydraulic and environmental criteria that have been used to demonstrate the relationship between tailrace design and environmental objectives. This analysis shall also take into account studies on the formation, break-up, and composition of the ice, and of polynyas. The Proponent shall pay particular attention to the choice of dimensions and shape of the tailrace canal, its horizontal and vertical position in relation to sea level and to pycnocline in Manitounuk Sound, and the rate of discharge into the local marine environment. Special attention shall be paid to the following environmental considerations: stratification density, local erosion, turbidity, sedimentology, primary production, ice conditions and the destruction of eelgrass beds and benthic organisms. In addition, consideration shall be given to the impact of the design of the tailrace canal on Native use of Manitounuk Sound. The Proponent shall also pay particular attention to blasting requirements for the various tailrace designs under study. The criteria for the use of explosives shall be established and justified, and detailed control procedures shall be presented. The Proponent shall formulate a formal blasting protocol that indicates what level of collateral damage is acceptable and prescribes under what conditions the blasting program shall be suspended and reconsidered.

4.09 The EIS presents a discussion of the design and excavation of the tailrace canal. However, the absence of certain details precludes a clear definition of the state of reference and an adequate understanding of the anticipated impacts on the biophysical environment of the Sound. The ecological criteria used in the design are not specified. Thus it is difficult to see the relationship between the design of the structure and the ecological objectives. Present the environmental criteria used in the design for the GB 1 tailrace canal and explain why all variants for its location are limited to the same bay at the mouth of the Kuugaapik stream.

4.1O For all major excavation works in the Manitounuk Sound area, indicate the volumes of underground, underwater and surface excavation required, and describe the proposed methods of excavation. Identify all proposed sites for the temporary stockpiling or permanent disposal of excavated materials, and specify the types and volumes of materials in question. Describe the methods that would be used for the excavation of the overburden and rock in parts of the tailrace canal where the hydraulic dredge might prove inadequate.

4.11 Describe the sedimentological and geochemical changes that could be induced in Manitounuk Sound as a result of undersea disposal of dredged materials, and specify the ecological criteria which favour undersea disposal over other possibilities. Specifically, with regard to sediment dispersal, provide information about the selection of methods used to calculate the future velocity of the currents in the Sound. Describe the geochemistry of the dredged sediments in the area of the tailrace canal with indications of the sampling stations, analytical methods used and potential toxicity.

Reservoirs

GUIDELINES paras. 412, 413, 416 and 421

412. The Proponent shall provide a detailed description of all work required for project construction including the following subjects:

1. time of the year, frequency and amplitude (maximum and minimum levels) of water level fluctuation ranges for all water bodies;

2. the maximum and minimum surface areas of reservoirs and forebays, with detailed maps, and residence time of water masses;

3. volume and description of debris in flooded areas, and their disposal methods;

4. flow rates (maximum, minimum and average) in the sections of the rivers affected, with detailed maps showing the areas affected and seasonal variations in water levels;

5. the types of dikes and dams, with their locations mapped;

6. maximum and minimum operating levels;

7. a description of the generating stations, with emphasis on the information required to understand and evaluate the project;

8. turbine types, maximum gross head and maximum quantity of turbined water;

9. the height and amount of backfill;

10. the dimensions and types of the spillways, with the number of gates, and the maximum capacity;

11. the dimensions, orientation and position of the tailrace canal and related structures;

12. diversion works;

13. a complete construction schedule based on each plausible set of hypotheses;

14. a schedule of costs for each phase of construction; and

15. the life span of the dams and dikes, the security factors used in their design, and their safety over the long term.

413. The information provided shall be sufficient to permit a full understanding of the operation of and the operational links between all reservoirs. It shall also include the frequency and intensity of the flows to the spillways for all reservoirs and clearly explain how they are to operate. The Proponent shall identify all permanent and temporary facilities.

416. Optimization of forebays (GB1, GB2, GB3 and Bienville). The Proponent shall describe the relationship between operating criteria for the forebays and the conditions necessary for managing fish habitats, and shall demonstrate how environmental considerations will affect the selection of minimum and maximum operating levels.

421. The Bienville reservoir. The Proponent shall report on studies concerning the maximal dimensions of the Bienville reservoir, as mentioned in the information provided by the Proponent. The possibility of modifying the dikes and limiting the extent of the flooded areas in the region near Lac Bienville shall also be taken into account. In this regard, the advantages of reducing flooding in the Lac Bienville region and the disadvantages of raising water levels in the GB3 and Paimpont regions shall be compared.

4.12 Flooded areas of the diverted sections of the Alpha and Beta River basins are only connected to the Bienville Reservoir by very narrow links. This suggests the possibility of diking the northwest rim of the Bienville Reservoir in such a way as to preserve these two rivers in their natural state. Evaluate the technical, economic and environmental advantages and disadvantages of diverting the Alpha and Beta Rivers into the Bienville Reservoir.

4.13 The EIS presents the option of raising the water level behind the dam at GB 3 to 396 m (GB 3-Bienville combined) as a viable and desirable alternative, and states its economic and environmental advantages. Among the advantages are the reduced size of the Bienville Reservoir; however, this would increase flooding in the area between GB 3 and the present outlet of Lac Bienville. Present a more complete environmental comparison of this latter option and the selected option, including a discussion of the relative quality of the flooded areas in both.

4.14 In order to reduce the maximum operating levels of the Bienville Reservoir, discuss the overall possibility of lowering its minimum operating level. Discuss the possibility of excavating the sills at the outlet of the existing lake. Show the potential storage curve for levels below the present sill, down to 385 m. Discuss technical and economical aspects and limitations.

4.15 The EIS briefly discusses the impact of integrating Great Whale into the Proponent's system, stating that the impact would be positive. It does not, however, quantify the degree to which the Great Whale project would modify the firm energy capability of the entire existing system. Provide estimates of the firm and average energy capability of the Proponent's system without the Great Whale project.

4.16 The methodology used by the Proponent to evaluate the benefits of the Great Whale project suggests that the project is designed to be able to meet a fixed load at all times. Relaxation of the objective of meeting a firm energy demand could potentially have an important impact upon the sizing of the Bienville Reservoir and the required interannual storage. In order to reduce the flooded area around Lac Bienville, discuss the impacts of reducing the storage of the reservoir by 10%, 25% and 50%. For each reduction, provide the area flooded, the reductions in average and firm energy capability of the proposed Great Whale complex and the reductions in average and firm energy capability of the system as a whole.

4.17 To offset the effects of reducing the storage of the Bienville reservoir on energy production during forecasted critical hydrological sequences, discuss the possibilities of:

a) using thermal plants normally assigned to meeting winter peaks for longer periods, especially during the summer;

b) increasing energy purchases from neighboring utilities and from private producers in Quebec; and

c) using exceptional reserve in the GB 1 and GB 3 reservoirs.

4.18 Discuss the extent to which continuous modulation of the production objective in terms of the amount of available storage might permit reduction in the interannual storage without reducing the average energy production of the complex. In the context of joint operation, to what extent would modulation of production based on available storage reduce the interannual storage requirement of the Great Whale project?

4.19 Discuss the degree of variability of inflows to the Great Whale complex, and provide a more detailed description of the analyses performed with respect to long-term runoff variability and their results. Specifically, have simulations of the behaviour of the Great Whale complex been carried out for hydrological series other than those described in the EIS? If so, describe the simulations carried out providing the following information for each simulation: mean inflows, average annual energy production values, maximum and minimum annual energy production and the corresponding real levelized unit costs per kWh.

4.20 To what extent would it he possible and practical to apply the concept of stochastic hydrology to system planning and to the evaluation of the interannual storage requirement of the Great Whale project?

4.21 Evaluate the extent to which the requirements for active storage in the Bienville Reservoir could he reduced if the combined hydrological characteristics of all reservoirs in the system were also taken into account.

Access Roads and Airports

GUIDELINES paras. 428 to 442 and 448 to 456

428. The Proponent shall also specify and justify the selection of the optimal site for the GB 1 airport, taking into account the needs of the Cree and Inuit communities as well as of the Proponent. The Proponent shall prepare a detailed comparative evaluation of the following scenarios:

- improving the runway, existing infrastructures and support services at Kuujjuarapik/Whapmagoostui;

- establishing an airport at an intermediate site between GB1 and Kuujjuarapik/Whapmagoostui, whether on the coast or further inland to serve both locations. The distinction between Category I and II lands should not be interpreted as an absolute restriction in terms of the site selection;

- building a runway next to the GB1 station construction site.

Access roads:

429. The Proponent shall describe the various access roads and corridors under consideration and indicate whether some will be modified before specific approvals are sought. The Proponent shall also justify both the study area and the routes and corridors retained, and shall clearly highlight the concerns and preferences stated during the consultation hearings. In this regard, a photographic file of ecologically sensitive areas and a map of the routes themselves shall be provided to facilitate review. The Proponent shall detail the environmental safeguards it proposes to follow and justify them whenever they differ from provincial and federal standards.

430. The Proponent shall define the program for operating the borrow pits required for the proposed project. The Proponent shall also specify the standards for their location in relation to roads, watercourses, wildlife areas and the boundaries of future reservoirs, observing relevant regulations and characteristics of the environment. The Proponent shall demonstrate how the use of materials from borrow pits has been optimized, and shall specify plans for restoring them once extraction is complete. The Proponent shall locate and map all planned facilities, specifying access roads, available materials, the areas involved and the volumes of material required. The Proponent shall also take maintenance requirements for the project into account.

431. North-south access (LG2/Fagnant/GB1) and east-west access (Fagnant-Bienville). The Proponent shall discuss the technical, economic and environmental justification for selection of the proposed route and shall re-examine the sub-variants in the Preliminary Information.

432. GB1/Kuujjuarapik/Whapmagoostui branch road. The Proponent shall propose routes to link the GB1 construction site to Kuujjuarapik/Whapmagoostui and shall present a comparative evaluation of coastal and inland routes. This evaluation shall take into account the different airport sites under study, as well as the results of a study of the cumulative impacts of the coastal corridor.

433. The Proponent shall demonstrate how the chosen corridors will minimize the impacts on Category I lands; suggest alternative routes m areas where highly sensitive watercourses are crossed (e.g., spawning beds); justify all winter routes; indicate how the road design takes permafrost into account; identify the sections of the road that are to be paved, specifying the reasons, the views of the affected populations, the associated costs and environmental effects; identify areas of special interest (panoramic sites, access to a resource, traditional use by Natives, cultural or sacred sites, etc.) and indicate how the routes selected take into account protection or restoration measures; identify the emergency measures needed to cope with accidental spills of petroleum or hazardous products; describe these measures in detail, including the anticipated intervention time and environmental risks and the contingency arrangements made to secure decontamination facilities and/or permanent storage sites in southern Quebec.

434. The Proponent shall also provide the above-mentioned information for the secondary, temporary or permanent roads that lead to dikes, villages and camps or other installations needed for the construction of the infrastructures. The Proponent shall describe the technical characteristics and general road construction standards for the various road sections, including the technical components justifying the choice of the existing route; the length; width of the right of way, the road itself and the shoulders; standards for curbs, slopes, backfill and excavations, speed limit, and load capacity; and gradation of materials (particularly in the case of environments containing organic deposits likely to contain permanent ice lenses).

435. The Proponent shall describe the principal work to be completed during the various pre-construction, construction and maintenance phases, including land clearing and disposal of wood; clearing of organic materials and disposal methods; rock excavation; shaping of the road, spreading and compacting of materials; service infrastructures (service stations, maintenance centres, parking areas); special techniques and precautions to be taken in permafrost areas; road signs concerning safety and directions; maintenance and repair of the pavement, shoulders, ditches, bridges and culverts; and use of dust-control products and de-icers.

436. The Proponent shall describe the legal status of new access infrastructures during the construction of the proposed Great Whale River hydroelectric complex. The following, in particular, should be discussed:

shall access roads be public or private and on what basis will this decision be taken? The Proponent shall assess the rationale for establishing a control system similar to that put in place by the Societe d'Energie de la Baie James during the first phase of construction at James Bay; who shall provide maintenance and information services for access roads, including the installation of rest areas, waste collection, snow removal, etc.?; who shall be responsible for road safety? The Proponent shall describe in the impact statement any agreement reached with other parties regarding the status and maintenance of access roads, and report on consultations held on the subject.

437. The Proponent shall identify the required infrastructures for the construction and specify the roads or sections of roads that can be used as winter routes.

438. Works such as the construction of bridges, the installation of culverts, and transport by ferry shall be described as accurately as possible, clearly identifying alternatives.

439. The Proponent shall certify that such infrastructures comply in particular with the Reglement sur les normes d'intervention dans.les forest du domaine public (RRQ ch.F-4.1 R.1.OO1), especially with regard to narrowing watercourses and maintaining their navigability.

440. In planning the work period and sites, the Proponent shall take steps to ensure that the movement and especially the spawning of fish are not affected.

441. The Proponent shall indicate which access roads will be maintained or reused at the end of the project, and specify the future status of infrastructures used to cross watercourses. The Proponent shall describe the proposed bridges and the size of clearings and earthworks planned for each side of any watercourse where a bridge will be built. The temporary structures required to approach and cross large watercourses shall also be described. Where necessary, the Proponent shall describe the infrastructures required to maintain user access to watercourses.

442. The Proponent shall explain its choice of culverts and discuss the advantages and disadvantages of the various types of culverts available. Regarding their installation, the Proponent shall indicate the standards related to the slope permitted, the depth and the degree of overlapping in relation to the bed of the watercourse. All main culverts to be installed on permanent streams shall be listed and described in order to facilitate the application of regulations and monitoring operations.

Airports:

448. This section applies to all permanent and temporary airports, as well as to all seaplane and helicopter bases required for the project. It concerns activities related to the construction, operation, maintenance and closure of these infrastructures, as well as the restoration of the sites used. The Proponent shall present a list of potential airport sites and shall assess positive and negative attributes for each site.

449. The comparative analysis shall take into account the needs of other local and regional intervenors, to be identified during consultations with the communities concerned. The quality of air service available during construction work must be evaluated and the clientele that will use the facilities shall be described.

450. The Proponent shall discuss the biophysical and social constraints involved (topography, meteorology, threat to birds and other wildlife). The Proponent shall indicate the reasons for selecting the site, and the take-off and landing paths, and shall justify the rejection of other sites or paths. Potential sites for future camps and other infrastructures relating to the complex shall be indicated. The sites accepted shall be the subject of a detailed review.

451. For each permanent or temporary airport site the Proponent shall provide the technical information necessary to predict the environmental impacts, namely characteristics of main flight paths, runways, terminals, landing docks, hangars and other buildings, as well as of the navigational equipment; access roads, including a presentation of alternate routes; sources of electrical supply; a plan of the runway drainage system; borrow pit materials required, specifying location, surface area, volumes, and types; a fire protection system plan; an explanation of the proposed plane de-icing process and the containment of the substances used. The Proponent shall also provide: the location and description of fuel tanks and containment systems, draining and safety measures and the contingency arrangements made to secure decontamination or disposal facilities in southern Quebec in the event of a spill; a description of the proposed construction methods and the maintenance work and equipment required; results of archaeological digs; a description and location of the drinking water supply system, and the wastewater and solid waste disposal system; an estimate of the duration, frequency (day and night) and extent of use of the proposed infrastructures, and the amount of cargo and number of passengers passing through them; a summary of the constraints which may ensue from these infrastructures; a description of the manpower required for the construction and operation phases; and a work schedule.

452. The evaluation of the choice of an airport serving GB1 and Kuujjuarapik/Whapmagoostui has been described in paragraph 428. This evaluation shall be based on consultations with the parties involved, and the results of these consultations shall be presented as an integral part of the impact statement. Concerns regarding the safety of the existing runway at Kuujjuarapik/Whapmagoostui shall also be addressed. Planning for these structures will extend over a period of at least twenty-five years.

453. The Proponent shall discuss the various alternatives considered for an airport between GB2 and GB3 and other airports. The sites selected by the Proponent shall be examined in detail. The Proponent shall identify and justify its needs as well as the needs of other interested parties, and shall meet the specific requirements of these guidelines.

454. The Proponent shall identify and justify its needs for temporary airports. In addition, the Proponent shall study transportation by floatplane and the installations and equipment required.

455. The Proponent shall also explain how the engineering work in the area of the diversions or related to control structures may affect the use of temporary winter runways. If runways are required on dry land, the Proponent must justify them.

456. With regard to a proposed runway at Lac Fagnant, the Proponent shall pay particular attention to the biophysical assessment of the site and the protective measures that would be taken to reduce disturbances to the natural environment to a strict minimum and to protect the sector in general. The Proponent shall also evaluate the possibility of using other sites and of using only permanent sites. The Proponent shall also indicate the probability of requesting approval for making these temporary installations permanent.

4.22 While a technical analysis of resistance factors with respect to road corridors by segment has been presented, the overall advantages or disadvantages of taking a northern route instead of a southern route, from the GB 2 powerhouse to the Bienville reservoir control structures, are not summarized, nor is the choice between the two routes justified. Discuss the relative costs and benefits of road corridors that pass to the north vs. the south of the GB 2 and GB 3 reservoirs.

4.23 Indicate whether or not workers will be able to use their private vehicles on site and, if so, what restrictions would be imposed on such use.

4.24 Taking the needs and preferences of the local communities into consideration, provide discussion to support the comparative analysis of the proposed airport sites, with particular attention to the proposed airport location near Kuujjuarapik/Whapmagoostui.

4.25 Indicate the take-off, landing paths and aerial servitudes for all proposed airports and airstrips in the region.

4.26 Discuss the administrative status of the permanent roads and airports during and after the commissioning of the proposed project, and indicate planned restrictions regarding their use. Discuss the extent to which the long-term impacts of the project would vary depending on this administrative status. Indicate the anticipated roles of the various authorities in the management of these infrastructures, and describe their present commitment. Discuss how their future Status is considered in the design of the network of roads, and whether Transport Quebec has been consulted with respect to road design and construction standards.

Housing

GUIDELINES paras. 443 to 447

Housing:

443. The Proponent shall describe the housing facilities it will require and the planned organization of the construction site with respect to worker movements outside the camps, on-site safety measures, etc. The Proponent shall also indicate how the consumption of alcoholic beverages and the use of illegal drugs will be controlled.

444. The Proponent must indicate the exact location of each camp and the relative location with respect to other users of the territory. The Proponent shall submit development projects for these facilities, including their capacities and periods of use.

445. The development projects for each camp must include descriptions of drinking water supply source, method of managing wastewater and discharge areas, location and operating conditions of the solid waste disposal site, power supply (generator capacities, location, etc.), and management of any other installations (including fuel storage depots) required for the camps to function properly.

446. Several camps will be installed in open areas, favourable to heavy or off-road vehicle traffic. Since these environments are especially fragile, the Proponent shall indicate what measures would be taken to avoid disturbing them. The Proponent shall give special attention to the protection of riparian and aquatic habitats and sites of cultural or religious significance.

447. The Proponent shall also indicate whether some of the camps will become permanent or be given to various local parties interested in reusing them.

4.27 Describe the housing facilities required for each proposed camp, and provide a calendar indicating the approximate periods when each camp will be mobilized, operated and dismantled, and the site restored. Indicate in detail the consultation process that would be established to determine which buildings and other temporary infrastructures would be removed, which would remain, and which could be transferred to local or regional organizations at the end of the project.

4.28 Indicate the location of each of the proposed camps on 1:50 000 scale maps relative to traplines, land categories, Native people's camps and installations of other users of the territory.

4.29 Explain how the views and interests of Native people were integrated into selection criteria f& family housing areas and camps.

4.30 Based on the experience acquired at the La Grande complex, outline and discuss the rules concerning the consumption of alcoholic beverages in camps and on work sites, and how these rules would be applied, and indicate how illegal drugs would be prohibited.

The Collector System

GUIDELINES paras. 427 and 458 to 463

427. The Proponent shall present one or more scenarios combining roads and energy transportation lines in the same corridor. Technical, economical, social, biophysical and aesthetic advantages of these scenarios shall be discussed.

COLLECTOR SYSTEM:

458. The Proponent shall identify several corridors within the study areas in a logical and verifiable manner so that a preferred corridor or corridors may be selected. When this first step has been completed, a second set of guidelines dealing with the choice of a preferred route within the accepted corridor shall be sent to the Proponent.

459. In theory, the collector system should require as many corridors as there are lines; in practice, one corridor can sometimes accommodate two lines and even a road. The Proponent shall plan to combine the two lines linking the GB1 generating station to the Radisson station. The Proponent shall also indicate how it optimized the choice of distribution corridors and on what basis this optimization was based, describing any possibility of combining both roads and distribution corridors. Lastly, the Proponent shall explain how land use by native peoples was considered in preparing routes for the lines, referring in particular to the JBNQA and to consultations with concerned parties.

460. The Proponent shall provide the technical characteristics of the construction of the lines and, when applicable, the proposed switching stations or modifications to existing stations. Particular emphasis shall be placed on the characteristics necessary for analysing the choice of corridors. The Proponent shall present the technical constraints related to the collector system, and shall also take into account the transportation and accommodation infrastructures required for the project.

461. The Proponent shall specify the design criteria related to the project, as well as all information concerning technical construction methods that could influence the choice of corridors and allow the planning to be understood. The Proponent shall also specify the details for execution of the project according to the updated construction schedule, as well as the margin of manoeuvre.

462. The Proponent shall discuss the project's flexibility, in particular by demonstrating how reliability criteria justified the replacement of the 735-kV line that was initially planned with two 315-kV lines in the western part of the territory. The Proponent shall explain the choice of using a double-circuit 315-kV line between GB1 and Radisson and a single-circuit line between GB2 or GB3 and the Chissibi substation. The Proponent shall also explain how the options being studied, such as the harnessing of the Little Whale River, could modify the capacity of the complex and the design of the distribution system. The Proponent shall also specify the technical and economic implications of transmitting the energy produced at GB2 and GB3 elsewhere than through the Chissibi substation by connecting GB1 to LG2 or by going further east through the Tilly station. The modifications to be made to the Chissibi and Radisson stations shall be described.

463. The Proponent shall also address the implications of the proposed project with respect to the need to construct a 14th transmission line.

4.31 Provide a table summarizing technical, aesthetic and environmental factors for each of the corridor options presented.

4.32 Explain how the results of consultation with Native people were taken into account in locating corridors, and how they will be integrated in the selection of the lines within the corridors chosen.

4.33 Provide a comparative analysis of the proposed methods for responding to the increased power levels related to the incorporation of the Great Whale generating stations into the Proponent's grid (e.g., increase in the series compensation in existing substations or construction of the 14th transmission line). For each option, this analysis shall include a description of the infrastructures and additional lines as well as changes required to existing infrastructures, and the impact of each of these alternatives on the real and nominal levelized unit cost of energy from the Great Whale complex.

4.34 Describe and locate the powerline that would provide electricity to the GB 1 airport and to Kuujjuarapik/Whapmagoostui after the commissioning of the GB 1 generating station.

CHAPTER 5

IMPACTS OF THE PROJECT

Major inadequacies which affect the analysis of the impacts are: an inadequate knowledge of the human societies, an inadequate approach regarding the combined and integrated effects of the proposed project and an inadequate appreciation of the uncertainty associated with the project's impacts. These were addressed in Chapter 1. In addition to these inadequacies, there are a number of specific questions which have remained unanswered in the EIS. Requests for additional information are formulated in this chapter of the report.

With regard to the biophysical environment, the EIS does not recognize the existence of distinct ecosystems within the study area, their structure and function, or the processes and interrelationships which constitute ecosystem health. Rather, discussion is limited to descriptions of species present in the project area, the habitats they occupy, and the areas from which they would be extirpated or displaced by the project. After providing answers to specific requests, the Proponent should discuss in an integrated fashion the impacts of the project on ecosystem health and biodiversity.

With regard to the human environment, the GUIDELINES requested that the Proponent examine the possible effects of the project on various aspects of social cohesion and respect for values Specifically, the GUIDELINES indicated that the following should be examined: the components of the proposed project as potential agents of change, the social consequences of boom-and-bust, the consequences of modifying access to the territory or to resources, the population displacement from one community to another, the consequences of the presence of migrant workers and the consequences for the communities involved of jobs created by the project. Areas where change may occur were also identified: family relations, relations between the generations and the sexes, relations among sub-groups in the communities, as well as relations between the communities. The GUIDELINES also requested that the consequences for social cohesion be examined not only within each community but on a regional and a national level. Key issues within the broader categories of social impacts of the proposed project included the following: anticipated social effects of the diversification of social roles; possible tensions between employed and unemployed members of a community; consolidation or perturbation of resource exchange networks; strengthening of ties between communities; potential conflicts between Crees and Inuit, and between Native people and sport hunters and fishermen; and potential effects on social changes.

These issues are treated briefly in the EIS and are not discussed in a comprehensive way. In particular, the treatment of the following issues is incomplete: the social effects of changing access to the territory and to resources; the social consequences of building or abandoning the project; the social effects of employment Native workers, their families and their communities; the social effects of economic boom-and-bust and the social effects of increased contacts with non-Natives.

The Proponent has not addressed social cohesion or respect for values as major issues, and has not dealt adequately with the social organization of the Cree and the Inuit. The Proponent describes the Cree and Inuit communities as torn by tensions and dilemmas induced since the 1950s by various external factors, but makes no mention of persistent elements of social cohesion. In this context, the project is seen by the Proponent as an additional factor which would contribute to change, mainly through economic spinoffs and the opening up of the region. According to this analysis, these factors in turn would only accentuate tendencies attributed by the Proponent to the entrance of the communities into the modern world. The Proponent's evaluation of the changes to these indigenous societies that would be induced by the proposed project is not rooted in a broad understanding of the past and current intensity and rate of social change experienced by these societies, nor is it rooted in the substantial knowledge that these societies have of their own changing world.

The following requirements of this Chapter are addressed to the Proponent to provide the Review Bodies with an analysis of the impacts of the proposed project that is complete and adequate.

Health

GUIDELINES paras. 506 to 519. and 546

HEALTH:

Definition and approach:

506. The notion of 'health' here is meant to include the current equilibrium of each ecosystem. Taking the descriptions required in Chapter 3 as the basis of an overview of the current state of health of both the natural and human environments, the Proponent shall evaluate any changes to this state of health that might occur as a result of the proposed project.

Specific questions:

507. The study shall evaluate current and future states of ecosystem health and, in particular:

1. the diversity of flora and the factors which might disrupt it;

2. the abundance, distribution, and density of species of fauna, and the factors which limit these characteristics; in particular, in the relevant cases, the rates and causes of mortality and morbidity, including contamination and destruction of habitat;

3. the changing human populations and their reactions to disruptions related to development; and

4. for the human populations, the current state of individual, collective, physiological and psychological health, paying particular attention to diseases that serve as indicators of changes in health; and shall attempt to identify the causes. The evaluation shall take into account conceptions on the part of the affected populations with regard to their current health and to the impacts the proposed project would have on their health. It shall also take into account the local health services (both care and prevention) and, specifically, community resources.

508. The Proponent shall study the possibility that intervention in the territory may benefit or harm certain species. The Proponent shall examine any imbalance that might arise with respect to the current situation and shall evaluate them with respect to their duration and geographic scope. To this end the Proponent shall study; in particular, the pressures that human populations bring to bear on wildlife and shall relate this to the environmental stresses that might arise from the proposed project. In the analysis of these pressures, the following factors shall specifically be taken into account: demographic growth of the Native communities, increased access routes and improvements in transportation, increase in the number of sports hunters and fishermen, economic development of the region, poaching and over-exploitation, and the cumulative effects of these factors.

Food:

509. The Proponent shall assess the impacts of dietary changes that would result from the proposed project on the health of living beings, and shall study, among other issues, the increase or decrease in the quantity and quality of available food resources (due to the reduction of the territory, increased difficulty or ease of access, contamination by mercury or other pollutants, etc.).

510. The Proponent shall also indicate how the percentage of food derived from hunting, fishing and gathering in relation to store-bought food could change as a result of changes in their relative costs and in food quality, specifically vitamin and protein content, resulting from the proposed project. This study shall, of course, be adjusted to take into account the dietary and physiological needs of Northern inhabitants, and particularly those of hunters.

511. Finally, the Proponent shall examine the effects of the proposed project on cultural aspects of diet: the difficulty or ease with which dietary customs can be modified; social ties created by activities involving the production and consumption of food; spiritual, dietary, or other values accorded to certain edible species of animals and plants; and all other relevant considerations.

Mercury:

512. The Proponent shall undertake a state-of-the-art study of mercury contamination, evaluating the risks such contamination poses to the territory's wildlife and to human populations. The following paragraphs specify the principal requirements of this study. The Proponent shall also evaluate the nature and extent of the affected populations' fear of contamination and the consequences thereof, especially with respect to their dietary choices.

1. The Proponent shall review all relevant scientific information as well as the available reference data for the region of the proposed Great Whale River hydroelectric complex in order to predict mercury contamination of fish in the reservoirs and forebays of the proposed complex or of any other sector that might be affected.

2. The Proponent shall take into account any research programs carried out elsewhere on biogeochemical mercury cycles, and shall determine their applicability to the reservoirs planned for the proposed project.

3. The Proponent shall discuss the passage of fish through the turbines and the incidence of mercury contamination in downstream fish populations, in particular with respect to recruitment and potential toxicological effects. The Proponent shall also address contamination of crustaceans, molluscs, marine mammals (especially belugas), piscivorous birds (migratory and non-migratory) and waterfowl. The extent and duration of this contamination shall also be determined, taking into account all sources of leachate (soil, vegetation, etc.) as well as baseline data on distribution of this type of contamination.

4. As for cumulative impacts, the Proponent shall make use of data from the La Grande complex, and shall obtain data from the proponents of other projects (e.g. Churchill-Nelson and Conawapa).

5. With regard to Manitounuk Sound and Hudson Bay, the Proponent shall address the issue of the transfer and bioaccumulation of methylmercury up the food chain, from plankton and invertebrates to marine mammals, with respect to the design options under consideration for the tailrace canal, emphasizing those resources which are likely to be consumed by the human population.

6. The Proponent shall also evaluate the impacts of the proposed project with regard to the increase in human exposure to methylmercury. The following issues shall be clearly addressed:

a. an evaluation of exposure levels and their distribution over time with respect to the various hypotheses concerning methylmercury bioaccumulation. These hypotheses and the ecological basis on which they are founded shall be clearly specified;

b. the pharmacokinetic behaviour of methylmercury in humans, including the selection of models linking consumption to indicators of body burden (in blood and hair);

c. the neurotoxicity of methylmercury in humans (adults and children) for differing levels and durations of exposure, including the cumulative effects of long-term exposure; the neurotoxicity of methylmercury exposure in utero and in mother's milk, for different levels of exposure; and monitoring studies on the long-term effects of in utero exposure, taking into account the diet of the local population;

d. current epidemiological knowledge concerning exposure levels and risks similar to those expected in the context of hydroelectric development;

e. changes in human exposure levels since 1975 (distinguishing between villages and sex and age groups);

f. in light of the preceding information, future changes in the likely rates of exposure for different social groups and an evaluation of the risks to adult populations associated with this exposure, taking diet into account; and

g. a study of the type of measures that would be required to meet criteria for acceptable levels of human exposure, justifying the criteria employed in terms of public health.

7. Insofar as the accelerated bioaccumulation of methylmercury in fish and possibly in marine mammals would require restrictions on Native hunting and fishing activities or would raise concerns among the population regarding the toxic effects of methylmercury and its consequences, it will be necessary to address social and cultural issues such as changes in diet associated with the presence of methylmercury in the environment.

8. The Proponent shall review the experience of other communities affected by mercury contamination (both inside and outside Quebec) to determine potential social and cultural impacts. The following points shall be covered:

1. the level of exposure, taking into account the demographic profile of Native communities and the territorial organization of fishing activities;

2. the perception of risk by the various groups involved;

3. the harvesting of fish, marine mammals, and avifauna and the distribution and consumption of this harvest, taking into account knowledge that emerges from the study of mercury exposure among the population; and

4. experience in controlling exposure among pregnant women and women of child-bearing age.

Safety:

513. The Proponent shall examine all factors that could compromise or improve safety conditions within the territory, including those that emerge from the Proponent's own research and those that are brought up by the inhabitants of the region. The following factors in particular shall be addressed:

1. Works. The Proponent shall study any possible dangers to users of the territory resulting from construction, start-up and operation of the works, no matter what the origin of these dangers may be (seismicity, human error, modification of river flow, changes in reservoir water levels, explosives, hazardous wastes and others). In the case of seismicity, the Proponent shall take into consideration the cumulative risks arising from the impoundment of other reservoirs.

2. Fires. The Proponent shall study fire hazards related to construction and operation of the works and to increased human presence in the territory. In particular, reference shall be made to fires that occurred at the La Grande complex, and the consequences of an increased number of forest fires in the region shall be evaluated.

3. Roads. The Proponent shall study the risk of road accidents for wildlife as well as for humans.

4. Waterways. The Proponent shall study the dangers in crossing waterways in all seasons, particularly with regard to the effects of the tailrace canal on Manitounuk Sound.

Other issues:

514. Other contaminants. Given the effects of heavy metals on the food chain, the Proponent shall also determine the current and anticipated concentrations of contaminants such as lead, cadmium, copper, arsenic and zinc in the reservoirs, food sources and potable water, particularly that resulting from the melting of permafrost and from inundation. The Proponent shall also consider the cumulative burden of heavy metals in Hudson Bay resulting from the proposed project in combination with other development projects.

515. Potable water. The Proponent shall clearly identify every watercourse that will be directly or indirectly affected by the project, and shall evaluate the impact of the proposed project on potability, chemical composition and physical characteristics (appearance, taste, odour). The Proponent shall also evaluate the impact of the cutting off of the Great Whale River on the potable water supply in the communities of Kuujjuarapik and Whapmagoostui.

516. Wastewater and solid waste disposal. In addition to evaluating the effects of the Proponent's own wastewater and solid waste treatment facilities, the Proponent shall examine the potential consequences of the proposed project on municipal infrastructures with respect to wastewater and the treatment of solid wastes, specifically in the communities of Kuujjuarapik and Whapmagoostui.

517. Electromagnetic fields. The Proponent shall evaluate health hazards to humans, animals and vegetation resulting from the electromagnetic fields induced by the transmission lines of the collector system. The Proponent shall pay particular attention to the possible cumulative effects of these transmission lines.

518. Stress and quality of life. The Proponent shall examine in what ways the proposed project could increase or decrease irritants (noise, dust, theft of equipment and other goods) and the risk of accidents (seismic activity, mass movements, modification of ice conditions, roads, dams). With regard to human beings, the Proponent shall in particular examine its effects on levels of fear and confidence (e.g., with respect to resources, culture, identity and control over the environment), insofar as the sense of alienation or belonging might affect health.

519. Greenhouse effect. The Proponent shall evaluate possible methane (CH4) and carbon dioxide (C02) emissions from existing and planned reservoirs. The volume of the biomass involved and its rate of decomposition shall be estimated, and other areas that may serve as controls shall be identified. Other atmospheric phenomena related to the greenhouse effect, in particular the loss of photosynthetic activity in areas which are to be inundated, shall also be considered.

546. Biodiversity. The Proponent shall pay particularly attention to the impact of the proposed project on rare, vulnerable, or threatened species, whether so identified by governments or by organizations working in this field. The Proponent shall evaluate the probability that certain species might be threatened or might disappear from a specific location or area. In doing so, the Proponent shall take into account any protected status already granted or under consideration, as well as agreements concluded between Canada and other countries with regard to certain species.

5.01 Provide an analysis of the potential impact of the fears in the local communities have concerning the proposed project and its possible effect on their state of health.

5.02 Provide information on changes in the quality of food, particularly with regard to vitamin and protein content, using current international norms for scientific studies on diet, as well as the experience of the Cree of James Bay.

5.03 Provide information on the cost and nutritional value of replacement foods and discuss how information on the nutritional value of these foodstuffs could be provided to the Inuit. Use data available from Sante Quebec and Indian Affairs and Northern Affairs Canada on the cost of a basket of food provisions in the North, and provide a comparison of costs and quality of that food with food currently consumed in the communities concerned by the project.

5.04 Provide an updated assessment of current knowledge of the possible effects of electromagnetic fields induced by transmission lines on humans, animals and vegetation. With reference to the experience at the La Grande complex and other relevant projects, discuss public perception, particularly within the Native communities, of the risks associated with electromagnetic fields for humans and animals.

5.05 Based in part on the experience gained at the La Grande complex, evaluate the consequences on land use of an increase in the number of forest fires in the region as a result of the proposed Great Whale project.

5.06 Based in part on the experience gained at the La Grande complex, provide projections concerning anticipated traffic accidents and road safety.

5.07 Evaluate the overall impacts of wastewater and solid waste treatment facilities planned for the proposed complex. For the communities of Kuujjuarapik/Whapmagoostui, examine the consequences of the project on municipal infrastructure used for wastewater treatment and solid waste management. Specify the extent to which these facilities, or other new facilities, could be used jointly.

Contamination by Mercury and by Trace Metals

GUIDELINES paras. 512, 514, 541 and 124

Mercury:

512. The Proponent shall undertake a state-of-the-art study of mercury contamination, evaluating the risks such contamination poses to the territory's wildlife and to human populations. The following paragraphs specify the principal requirements of this study. The Proponent shall also evaluate the nature and extent of the affected populations' fear of contamination and the consequences thereof, especially with respect to their dietary choices.

1. The Proponent shall review all relevant scientific information as well as the available reference data for the region of the proposed Great Whale River hydroelectric complex in order to predict mercury contamination of fish in the reservoirs and forebays of the proposed complex or of any other sector that might be affected.

2. The Proponent shall take into account any research programs carried out elsewhere on biogeochemical mercury cycles, and shall determine their applicability to the reservoirs planned for the proposed project.

3. The Proponent shall discuss the passage of fish through the turbines and the incidence of mercury contamination in downstream fish populations, in particular with respect to recruitment and potential toxicological effects. The Proponent shall also address contamination of crustaceans, molluscs, marine mammals (especially belugas), piscivorous birds (migratory and non-migratory) and waterfowl. The extent and duration of this contamination shall also be determined, taking into account all sources of leachate (soil, vegetation, etc.) as well as baseline data on distribution of this type of contamination.

4. As for cumulative impacts, the Proponent shall make use of data from the La Grande complex, and shall obtain data from the proponents of other projects (e.g. Churchill-Nelson and Conawapa).

5. With regard to Manitounuk Sound and Hudson Bay, the Proponent shall address the issue of the transfer and bioaccumulation of methylmercury up the food chain, from plankton and invertebrates to marine mammals, with respect to the design options under consideration for the tailrace canal, emphasizing those resources which are likely to be consumed by the human population.

6. The Proponent shall also evaluate the impacts of the proposed project with regard to the increase in human exposure to methylmercury. The following issues shall be clearly addressed:

a. an evaluation of exposure levels and their distribution over time with respect to the various hypotheses concerning methylmercury bioaccumulation. These hypotheses and the ecological basis on which they are founded shall be clearly specified;

b. the pharmacokinetic behaviour of methylmercury in humans, including the selection of models linking consumption to indicators of body burden (in blood and hair);

c. the neurotoxicity of methylmercury in humans (adults and children) for differing levels and durations of exposure, including the cumulative effects of long-term exposure; the neurotoxicity of methylmercury exposure in utero and in mother's milk, for different levels of exposure; and monitoring studies on the long-term effects of in utero exposure, taking into account the diet of the local population;

d. current epidemiological knowledge concerning exposure levels and risks similar to those expected in the context of hydroelectric development;

e. changes in human exposure levels since 1975 (distinguishing between villages and sex and age groups);

f. in light of the preceding information, future changes in the likely rates of exposure for different social groups and an evaluation of the risks to adult populations associated with this exposure, taking diet into account; and

g. a study of the type of measures that would be required to meet criteria for acceptable levels of human exposure, justifying the criteria employed in terms of public health.

7. Insofar as the accelerated bioaccumulation of methylmercury in fish and possibly in marine mammals would require restrictions on Native hunting and fishing activities or would raise concerns among the population regarding the toxic effects of methylmercury and its consequences, it will be necessary to address social and cultural issues such as changes in diet associated with the presence of methylmercury in the environment.

8. The Proponent shall review the experience of other communities affected by mercury contamination (both inside and outside Quebec) to determine potential social and cultural impacts. The following points shall be covered:

1. the level of exposure, taking into account the demographic profile of Native communities and the territorial organization of fishing activities;

2. the perception of risk by the various groups involved;

3. the harvesting of fish, marine mammals, and avifauna and the distribution and consumption of this harvest, taking into account knowledge that emerges from the study of mercury exposure among the population; and

4. experience in controlling exposure among pregnant women and women of child-bearing age.

Other issues

514. Other contaminants. Given the effects of heavy metals on the food chain, the Proponent shall also determine the current and anticipated concentrations of contaminants such as lead, cadmium, copper, arsenic and zinc in the reservoirs, food sources and potable water, particularly that resulting from the melting of permafrost and from inundation. The Proponent shall also consider the cumulative burden of heavy metals in Hudson Bay resulting from the proposed project in combination with other development projects.

541. For all sectors affected by the proposed development, the Proponent shall indicate the area of vegetation that would be flooded and shall indicate the quantity of organic matter that would contribute to the release of methylmercury. In addition, for all sectors, the Proponent shall evaluate the area of peat bogs that would be floated and the consequences that would result.

124. Some potential impacts of the proposed project have regional and national implications and may affect the entire region of Hudson Bay around which other river development projects have already been built. As well, additional projects are anticipated in this region. The cumulative effects of all of these projects on the influx of sediments, nutrients, heat and contaminants (including mercury) into the Bay, on the regional climate, on the food chain and on the quality and even the survival of the marine resources of Hudson Bay are important environmental concerns. The Proponent shall evaluate the extent to which the proposed project will alter the ecosystem of Hudson Bay. The Proponent shall thus describe the cumulative impacts of this proposed project, considering in particular other projects under its purview, such as the La Grande complex, and other existing projects, such as Churchill-Nelson, and those currently undergoing public review, such as the Conawapa project.

The treatment of mercury contamination in the EIS raises several issues. Generally speaking, the information provided concerning mercury contamination in the environment, including sources and residence time, the bioaccumulation of methylmercury in wildlife, and the toxicity of acute or chronic exposure in human beings, is inadequate. Information on analytical methods and protocols used to determine methylmercury levels is also inadequate, as are descriptions of monitoring methods.

5.08 Based on an updated review of the scientific and medical literature, discuss the bioaccumulation of methylmercury in humans and the effects of prolonged exposure on human health.

5.09 Provide all available historical data on methylmercury exposure for each community in the study area, including Sanikiluaq, and evaluate for each community the additional risk associated with increased exposure.

5.10 Using Sante Quebec's sampling and survey methodologies and applicable data, evaluate the impacts of previous and anticipated changes in diet on health and quality of life, particularly the impacts of reduced consumption of fish and marine mammals resulting from mercury contamination or from fear of mercury contamination, by sex and age group. Using current international norms for scientific studies on diet, as well as the experience of the Cree of James Bay, provide information on anticipated changes in the quality of food due to contamination, particularly with regard to vitamin and mineral content. Complete this analysis by consulting the populations concerned by the proposed project.

5.11 Discuss the potential increase of methylmercury levels in marine organisms in Manitounuk Sound (especially marine mammals in the vicinity of the tailrace canal). Examine possible cumulative effects on marine mammals as a result of existing projects. Discuss the likely duration for which human consumption of mussels, marine mammals, and piscivorous birds would be limited due to mercury contamination.

5.12 Discuss the extent to which the flooding of peatlands and permafrost would contribute to the release of mercury and trace metals into the reservoirs of the project. Base this discussion on data from the la Grande complex, on data from other northern hydroelectric developments, and on studies carried out in peatland and permafrost areas.

5.13 Based on a review of the pertinent literature, describe anticipated changes to levels of trace metals (1ead, cadmium, copper, arsenic and zinc) in wildlife species commonly consumed by local residents.

Effects on Climate

GUIDELINES paras. 519 and 523

519. Greenhouse effect. The Proponent shall evaluate possible methane (CH4) and carbon dioxide (C02) emissions from existing and planned reservoirs. The volume of the biomass involved and its rate of decomposition shall be estimated, and other areas that may serve as controls shall be identified. Other atmospheric phenomena related to the greenhouse effect, in particular the loss of photosynthetic activity in areas which are to be inundated, shall also be considered.

Specific questions

523. With regard to river and maritime routes, the Proponent shall describe possible modifications to their use by fish, marine mammals, birds and humans. This description shall include a study of the following phenomena to determine how they could hinder the mobility of humans and animals:

1. erosion and sedimentation in the GB1, GB2 and GB3 reservoirs caused by impoundment, as well as such changes in rivers and estuaries due to changes in flow. Erosion and land subsidence linked to the melting of permafrost on the banks of reservoirs and modified rivers shall also be examined;

2. changes to rapids, and to portage trails which run alongside them;

3. modifications to tidal effects and to the movement of water masses in the estuaries;

4. bathymetric changes in the estuaries and in Manitounuk Sound, particularly in proximity to the tailrace canal;

5. ice conditions in the reservoirs and changes in the ice regime in rivers, estuaries, Manitounuk Sound and Hudson Bay, caused by changes in flow and by resulting changes in temperature;

6. temporary changes caused by reservoir impoundment and by tidal effects;

7. modifications to the local climate (precipitation, fog, temperature), including that of Hudson Bay, caused by the creation of the reservoirs of the proposed project and by the cumulative effects of these reservoirs together with those of other hydroelectric installations; and

8. the presence of debris and vegetation in the reservoirs and rivers.

5.14 Using empirical data derived from the la Grande complex and from other research, provide revised estimates of greenhouse gas emissions from the project. These revised estimates shall take into account the loss of photosynthetic area.

5.15 Discuss how the alteration of the annual discharge patterns into Manitounuk Sound might affect regional weather patterns, particularly fog conditions.

5.16 Indicate why data from Lac Saint-Jean and a Russian reservoir, rather than from the la Grande complex, were used to predict the impacts of the proposed project on climate.

Access to the Territory

GUIDELINES paras. 520 to 528

ACCESS TO THE TERRITORY:

Definition and approach:

520. In order to evaluate the free movement of all species inhabiting the territory, the Proponent shall inventory and map the land and water routes (including streams, rivers, lakes, estuaries, shorelines and Hudson Bay) and the aerial routes that are currently used, or could potentially be used, and which could be affected by the proposed Great Whale River hydroelectric complex. The seasons during which different movement patterns occur, and the reasons why, shall be particularly taken into consideration. With respect to wildlife, particular attention shall be paid to the movement of beluga populations and the corridors used by caribou. With respect to the human population, the Proponent shall also identify the methods of transportation employed (snowmobiles, canoes, various types of boats, ATVs [all-terrain vehicles], automobiles, trucks, helicopters, airplanes) and their costs. In addition, the Proponent shall describe the existing conditions governing the movement between the territory and neighbouring regions. The Proponent shall also consider the opinions of the inhabitants with regard to conditions of movement, as well as any fears they may express concerning the new conditions that would result from the proposed project.

521. In addition, the Proponent shall identify and map watercourses or sections of watercourses that would be lost and new watercourses that would be created, and shall indicate how these changes would modify access to the territory. For land routes, the Proponent shall identify and map the current network and shall describe the routes that would disappear due to the project, routes that would be created, and transformations to the territory that would be caused by the creation of these access routes. In all these cases, the degree to which accessibility would be reduced or increased as a result of the proposed project shall be evaluated. The Proponent shall thereby analyze how these access roads would transform the territory, and the effects these changes might have on the movement of living beings.

522. The Proponent shall evaluate the impact of the power transmission corridors planned for the collector system on the movement of humans and animals in the territory. In the same way, the impact of other infrastructures on human and animal movement shall also be studied. Finally, the Proponent shall evaluate the degree to which local inhabitants may change their mobility patterns in the territory because of fears related to the safety of project facilities.

Specific questions:

523. With regard to river and maritime routes, the Proponent shall describe possible modifications to their use by fish, marine mammals, birds and humans. This description shall include a study of the following phenomena to determine how they could hinder the mobility of humans and animals:

1. erosion and sedimentation in the GB1, GB2 and GB3 reservoirs caused by impoundment, as well as such changes in rivers and estuaries due to changes in flow. Erosion and land subsidence linked to the melting of permafrost on the banks of reservoirs and modified rivers shall also be examined;

2. changes to rapids, and to portage trails which run alongside them;

3. modifications to tidal effects and to the movement of water masses in the estuaries;

4. bathymetric changes in the estuaries and in Manitounuk Sound, particularly in proximity to the tailrace canal;

5. ice conditions in the reservoirs and changes in the ice regime in rivers, estuaries, Manitounuk Sound and Hudson Bay, caused by changes in flow and by resulting changes in temperature;

6. temporary changes caused by reservoir impoundment and by tidal effects;

7. modifications to the local climate (precipitation, fog, temperature), including that of Hudson Bay, caused by the creation of the reservoirs of the proposed project and by the cumulative effects of these reservoirs together with those of other hydroelectric installations; and

8. the presence of debris and vegetation in the reservoirs and rivers.

524. The Proponent shall examine the navigability of affected waterways, taking particular account of the Navigable Waters Protection Act. In assessing circulation during construction and after the start-up of the proposed complex, the Proponent shall pay particular attention to Manitounuk Sound, the Bienville reservoir and to river estuaries, especially that of the Great Whale River. This estuary provides the only location where boats can berth at Kuujjuarapik/Whaprnagoostui.

525. The Proponent shall analyze the obstacles and benefits resulting from the creation of new roads, as well as their contribution to the free movement of wildlife and humans in the territory. The Proponent shall pay particular attention to the possibility of human access to caribou migration corridors. With regard to caribou migration, the Proponent shall also pay particular attention to the cumulative effects resulting from other installations in the northern areas of the Quebec-Labrador peninsula. The Proponent shall also address the phenomenon of erosion of organic soil caused by modifications to the natural flow regime and to land drainage, and by the creation of swamps.

526. The Proponent shall describe any new air-traffic conditions and shall evaluate their impact on the flyway of birds, in particular at Kuujjuarapik/Whapmagoostui during the construction period and following start-up, if appropriate. The effects of these conditions on human mobility shall also be evaluated.

527. The Proponent shall evaluate any changes to the cost of travel in the territory, as well as in distances to be covered in order to access various locations used by the human populations living in the territory. The study of the effects on transportation costs shall take into account the income of the users during and following construction of the proposed project, particularly for those whose activities in the territory regularly require them to travel.

528. Finally, the Proponent shall evaluate how the construction of access routes to the installations would contribute to the opening of the territory as a whole through the creation of transportation links with the rest of the continent. The Proponent shall also indicate the extent to which needs for access (both northward and southward) would be met and to which needs for isolation would be compromised (potential users, frequency, seasons, methods of transportation, reasons for use, changes in travel costs between the host region and the rest of the country), for each affected population. Again, collaboration with the communities of Kuujjuarapik and Whapmagoostui and analysis of other instances where territories were opened (including Chisasibi) are recommended. The Proponent shall be particularly attentive to the sense of identification with the territory on the part of both local populations and those of other regions.

5.17 Identify and evaluate anticipated modifications resulting from the project to transportation methods and routes, including portage trails, used by Native populations to gain access to their harvesting territories, as well as the costs related to these changes.

5.18 Evaluate navigation conditions prior to, during, and after the start-up

of the proposed project on heavily frequented waterways such as Manitounuk Sound (especially near the tailrace canal), the Great Whale River, the estuary of the Little Whale River, and Lac Bienville, and discuss them in terms of the provisions of the Navigable Waters Protection Act.

5.19 Describe and evaluate the importance of the present air transport systems used by the local populations for inter-community and inter-regional travel, and provide likely scenarios of how the air transportation networks would change as a result of the proposed project as a whole.

5.20 Airports and airfields in the area may interfere with birds. For example, habitats may be lost, birds may be displaced or killed, and migration routes may be impeded. Describe the effects which the construction and operation of the proposed airports would have on migrant waterfowl and ptarmigan.

Availability of Resources

GUIDELINES paras. 529 to 546

AVAILABILITY OF RESOURCES:

529. The Proponent shall present an overview of the resources in the territory, and then shall evaluate changes in the diversity and wealth of these animal and plant resources as well as in their use both by Natives (hunting, fishing, trapping, gathering) and non-Natives (sports hunting and fishing). Special attention shall be paid to the territories located along Manitounuk Sound, to the region of Lac Bienville and to the Belcher Islands. Provisions of Subsection 4.4 of Appendix 1 to Section 4 of the JBNQA concerning an eight-mile corridor around the road between LG2 and Kuujjuarapik/Whapmagoostui shall be taken into consideration.

530. In addition, the Proponent shall estimate the future use of other resources in the territory (water, minerals, appeal of nature in general), by local communities and by the inhabitants of other regions for cultural purposes and for recreation, tourism, energy production and other purposes. The Proponent shall also consider the economic contribution of these resources, that is, the creation of revenues and especially of jobs (in outfitting, tourism, mining operations, etc.).

531. The Proponent shall describe and evaluate the positive and negative quantitative (extending as far as complete loss) and qualitative changes to habitats that could be caused by one or another element of the proposed project, or by their management.

532. With respect to flora, the Proponent shall indicate the land areas that would be lost and the impact of these losses on floral equilibrium, including losses in neighbouring regions. The positive or negative impacts of these losses on fauna shall also be studied.

533. In examining wildlife habitats, the Proponent shall pay particular attention to those species highly valued by the groups concerned, especially the beluga, caribou, fur-bearing animals and avifauna (particularly migratory birds).

534. Beluga. The Proponent shall evaluate the effects of the proposed project on the herd's reproductive cycle and, in terms of habitats, on calving areas and nurseries; in addition, on the basis of what is known about the ecology and distribution of marine mammals in the region, the Proponent shall assess the effects of changes in the ice regime and on physical, sedimentological, chemical and biological characteristics of the environment for each of the scenarios of the proposed project. In light of the present state of knowledge concerning this species, the Proponent shall also evaluate the differential effects of the diversion or non-diversion of the Little Whale River.

535. Caribou. In evaluating the impacts on caribou, the Proponent shall use all data already available as well as data to be collected by the Proponent, including results obtained from studies carried out on the La Grande complex and similar projects. This information shall be used to assess the influence of hydroelectric developments on changes in habits and habitats during and after the construction of the proposed complex. The evaluation shall also take into consideration preferred areas of use and migration routes.

536. Fur-bearing animals. The Proponent shall describe the proposed project's impact on fur-bearing animals, the rate of capture and the distribution of the species mentioned in Chapter 3.

537. Avifauna. The Proponent shall evaluate the abundance, distribution and seasonal habits of bird species throughout the territory and shall evaluate the impact of habitat losses for these species, especially in the case of waterfowl and migratory birds. The Proponent shall describe changes in shoreline habitat following the impoundment of reservoirs, and shall estimate the significance of lost nesting, staging, feeding and rest areas for avifauna in general, but particularly for waterfowl and ptarmigan, whether that significance is related to hunting or to ornithological interest. The Proponent shall describe the present state of knowledge concerning the use by waterfowl of the east coast of Hudson Bay and Manitounuk Sound, paying special attention to species of interest to Native inhabitants, particularly eider duck, ptarmigan, Canada Goose, and Snow Goose.

538. River sections and reservoirs. Taking into account the areas that would be inundated and reservoir management policy, the Proponent shall describe changes to shoreline and shoreline habitat that would result from the impoundment of the GB1, GB2 and GB3 reservoirs and the Bienville reservoir. The duration of the reservoir impoundment period and changes in water levels shall be taken into consideration, and an evaluation shall be made of the anticipated extent of changes in erosion and sedimentation. The Proponent shall estimate the significance of losses to nesting, breeding, feeding and resting areas for avian species in general, and especially for waterfowl and ptarmigan, whether that significance is due to hunting or to ornithological interest. The Proponent shall also estimate the loss of habitat for land fauna and shall interpret the results in relation to the value of the riparian habitat for these species. The Proponent shall also estimate the effects on aquatic fauna in terms of quality of the modified habitats (inundated or emerged); changes in species makeup and biomass shall also be assessed.

539. In the case of river sections where flow is to increase or decrease, an evaluation shall be made of the effects of these changes on erosion, sedimentation, water quality and ice conditions, and on the phyto- and zooplanktonic and benthic communities that inhabit them. The Proponent shall evaluate the loss or gain of habitat in relation to the various flow level scenarios under consideration and to the creation of reservoirs.

540. The Proponent shall evaluate the impact of the creation of reservoirs on fish, particularly with regard to the following: changes in fish communities in the reservoirs, taking into account both operating criteria and spawning and egg maturation conditions; growth rates as a function of population dynamics; mortality, fertility and reproductive age; as well as natural variability in age-class representation. The same parameters shall be evaluated for fish populations subject to changes in flow. The Proponent shall also evaluate the risk of transfer of fish species from one drainage basin to another, or from one water body to another.

541. For all sectors affected by the proposed development, the Proponent shall indicate the area of vegetation that would be flooded and shall indicate the quantity of organic matter that would contribute to the release of methylmercury. In addition, for all sectors, the Proponent shall evaluate the area of peat bogs that would be floated and the consequences that would result.

542. The Lac Bienville region. Lac Bienville is an area of great importance to the region's wildlife. The amount of prime wildlife habitat lost would depend on the size of the reservoir created. The Proponent shall conduct a comparative analysis of loss of habitat and decrease in wildlife productivity for the entire region. In addition to the studies mentioned in the preceding paragraphs, the Proponent shall specifically study the effects of impoundment and of changes in water levels on waterfowl and caribou found in this area at different times of the year.

543. Estuaries. Flow changes in the estuaries would have an impact on the physical and biological environments. In this context, the Proponent shall evaluate the effects of the proposed project and, more specifically, shall:

1. predict the behaviour of the estuaries after the completion of the proposed project with regard to erosion, salinity patterns, freshwater plumes, changes in temperature and turbidity, transport and deposition of sediment, bathymetry and physico-chemistry, using mathematical models;

2. evaluate habitat loss for fish and other marine organisms and predict possible changes in species makeup and the biomass. The Proponent shall present the effects of physical and physico-chemical changes on the ecology of fish larvae and on the recruitment of anadromous fish;

3. evaluate the influence of winter water conditions, including changes to freshwater plumes in coastal waters, on reproductive success and habitat availability for fish normally present in the estuaries in winter;

4. discuss the effect of changes in flow on the use of estuaries by marine mammals, particularly Little Whale River estuary, examining the effect of possible changes in temperature, bathymetry and availability of prey. Possibilities of replacement habitat shall also be examined, as well as the impact of these changes on the number and condition of these animals, particularly the beluga; and

5. evaluate the importance of the possible use of the GB1 spillway on the physical, chemical and ecosystemic components mentioned above.

544. Manitounuk Sound. Taking into account the increased freshwater supply in Manitounuk Sound, the Proponent shall evaluate its effect on tidal effects, ice cover, polynya zones and local bathymetric conditions:

The Proponent shall indicate the implications of the different options being studied on sedimentology, primary production (including ice algae), shellfish, fish, waterfowl and marine mammals. The Proponent shall evaluate the anticipated impacts of the proposed project on anadromous fish, taking into account changes in the estuarine environment. To support these predictions, the Proponent shall present the mathematical models used to reproduce current and future conditions of these habitats, and shall justify the choice of models.

545. Hudson Bay and Beicher Islands. The environmental impact of the proposed project on the wildlife and marine resources of the Belcher Islands requires special attention on the part of the Proponent. Long-term changes to the marine environment that would result from the development of the proposed project shall be evaluated, as well as the effects on the following elements: marine currents, physical and chemical properties of the water, formation, movement and break-up of ice; and fish, birds, seals, beluga and other forms of marine life, as well as certain mammals such as the polar bear. The Proponent shall also examine cumulative effects on marine productivity of the various hydroelectric complexes on James Bay and Hudson Bay, and the possible impacts of changes in currents and freshwater supply in these bays.

546. Biodiversity. The Proponent shall pay particularly attention to the impact of the proposed project on rare, vulnerable, or threatened species, whether so identified by governments or by organizations working in this field. The Proponent shall evaluate the probability that certain species might be threatened or might disappear from a specific location or area. In doing so, the Proponent shall take into account any protected status already granted or under consideration, as well as agreements concluded between Canada and other countries with regard to certain species.

5.21 Provide an extensive review of the literature concerning the impacts of hydroelectric developments on caribou, indicating any uncertainty which the authors of the cited papers have attached to their findings. Discuss the effect of the project on caribou migration routes and wintering grounds, with special attention to the Lac Bienville area. Include information concerning the Churchill Falls complex in the discussion of cumulative impacts.

5.22 Elaborate upon the contention that the access infrastructure (roads and airports) should "facilitate management" of caribou. Taking into account the la Grande experience, discuss the possible increased exploitation of the resource and the potentially conflicting interests of subsistence, commercial, and sport hunting.

5.23 Based on the map of the distribution of freshwater seals provided in the EIS, discuss the proposed project's potential impacts on them, including the effects of a possible augmentation in their harvest.

5.24 Based on the Proponent's experience at the La Grande complex and the experience of indigenous trappers, discuss the anticipated consequences of the project on furbearers. In particular:

a) quantify the anticipated survival of beavers following reservoir impoundment, taking into account the time required for reservoir filling and the time of year when filling occurs. Discuss the increase in beaver mortality predicted in the EIS resulting from overland migrations to and from reservoir draw-down zones;

b) provide a discussion supporting the conclusion presented in the EIS that impacts on muskrats will be minor;

c) discuss the impacts of the project on marten and mink.

5.25 Discuss the impacts of riparian habitat losses on the resident small mammal and amphibian communities and on their predators.

5.26 support the conclusion presented in the EIS that the project will have minimal impacts on avian species which do not nest there, but which use the area for moulting, staging or wintering.

5.27 Discuss the significance of the proposed project's modification of the north-south flyway of waterfowl, especially for lesser snow geese and Canada geese. Indicate more clearly the type and magnitude of project impacts on these species. In terms of habitat loss or change, describe the cumulative effects on migratory birds (especially waterfowl) of the various hydroelectric complexes which drain into Hudson Bay.

5.28 For the Lac Bienville region, provide quantitative predictions of the extent to which reservoir impoundment and water level fluctuations would affect local waterfowl populations.

5.29 Estimate the significance of lost nesting, feeding, and rest areas for songbirds, shorebirds and eiders. Discuss the impacts of the proposed project on eiders along the coast and on the Belcher Islands.

5.30 Indicate the proportion of the hunting territory of the affected golden eagles which will be flooded or otherwise modified by the proposed project. Evaluate the combined impacts of the complex and infrastructures on golden eagles.

5.31 Evaluate the extent to which the transmission lines and corridors would have impacts on bird populations.

5.32 The EIS provides little data concerning the biomass and taxonomic composition of zooplankton in the Great Whale study area, and such data as are available appear to be limited in scope to coastal rivers. These data indicate that the relative abundances of certain taxa differ greatly between the Great Whale and La Grande basins. Provide a detailed discussion of the similarities and differences which exist between the La Grande and Great Whale River basins with regard to zooplankton, phytoplankton, and benthos. Using quantitative examples, discuss the usefulness of findings from La Grande for predicting the impacts of the proposed project.

5.33 Provide an extensive review of the literature concerning the impacts of hydroelectric reservoir development on planktonic and benthic invertebrate communities, including the density and diversity of organisms present. Discuss how this information can be applied to the proposed reservoirs.

5.34 In light of the supplementary data requested in paragraph 3:16 of this report, describe the anticipated impacts of the proposed reservoirs on key species of fish as requested in paragraph 540 of the GUIDELINES.

5.35 Specific information requested in order to evaluate the effect of regulated river flow on fish was not provided in the EIS. Discuss the impacts of reducing, increasing, or regulating river flow on the resident fish communities (specifically, impacts on spawning, egg maturation, growth rates, mortality, fertility, reproductive and age-class representation). Estimate post-impoundment changes in the quality and quantity of available fish habitat, and the extent of changes in fish biomass.

5.36 Provide data to support statements in the EIS concerning post-project changes in the extent of fish habitats. Discuss data concerning the extent of losses of aquatic vegetation communities in the context of habitat loss (e.g., for different fish species).

5.37 The discussion in the EIS deals mainly with the short-term period during which fish populations in a reservoir undergo an initial expansion. Provide details concerning the changes in the fish which would occur in the reservoir system in the longer term, after the initial population expansion is over. Provide a comparison between the operating conditions in LG 2 reservoir and those of the proposed GB 1 reservoir.

5.38 Insofar as it concerns spawning, the EIS identifies two coregonid spawning beds in the Denys River, but does not discuss the river's potential or importance in maintaining other species. In order to know whether the area would continue to provide good quality habitat after the river is cut off, the Proponent shall evaluate the impact of the reduced flow of the Great Whale River on access to the spawning areas of the Denys River. Discuss specifically the impact on the lake whitefish spawning area upstream from PK-8, as a result of reduced flow in the Great Whale River.

5.39 Discuss the ways in which the alteration of the estuarine environment by the proposed project would affect fish, particularly marine and anadromous species. Discuss how changes in water conditions during winter would affect the reproductive success and habitat availability for fish which presently frequent the estuaries during winter.

5.40 Discuss how disruption of the migration of anadromous fish in the Great Whale River would affect populations in the estuary and in Manitounuk Sound.

5.41 No information is provided concerning the biological impacts in the estuary which could result from the use of the GB 1 spillway. Discuss how the key fish species expected to inhabit the Great Whale River estuary under post-project conditions would respond to sudden, large pulses of fresh water.

5.42 Much of the requested information regarding Manitounuk Sound is provided. However, according to the predictions in the EIS, the large inflow of fresh water into the Sound under the winter ice could result in the formation of a reduced-salinity layer up to 5 metres thick. The biotic impacts of this layer are not discussed. Determine the area of Manitounuk Sound which would fall within the 5-metre reduced-salinity layer. Provide a detailed discussion, with appropriate maps, of the extent to which benthic and littoral life in the Sound would be affected, and provide estimates of potential changes to ice algae and phytoplankton populations.

5.43 Provide data to support conclusions in the EIS concerning predicted changes in the salinity of Manitounuk Sound, and associated changes in the Sound's biota. Indicate the methods by which these predictions were made.

5.44 Discuss potential changes to the extent of polynyas in Manitounuk Sound, and the resultant changes in the frequentation of the Sound during the winter by polar bears, other marine mammals arid waterfowl attracted by polynyas.

5.45 Evaluate the impacts of changes to water temperature and salinity in the estuary of the Little Whale River resulting from the proposed project on the use of the estuary by belugas for moulting.

5.46 With regard to the Proponent's contention that belugas displaced from the Little Whale River might find suitable alternative habitats in the Nastapoka estuary and Lac Guillaume-Delisle areas, discuss the likelihood that these areas could support increased beluga populations.

5.47 Discuss the possibility that the artificial ice-free area around the tailrace canal in Manitounuk Sound would attract belugas and trap them in an adverse winter habitat, should food sources there be insufficient, or should their vulnerability to predation there be significantly increased.

5.48 Indicate the extent to which traditional ecological knowledge was used in the assessment of the project's impacts on belugas.

5.49 Discuss how feeding, mating, and the winter use of the estuaries and adjacent areas by ringed seals would be affected by flow changes caused by the proposed project.

5.50 Provide quantitative data necessary to support predictions regarding the effect of post-project estuarine flow changes on marine mammals.

5.51 Identify the potential impacts of the proposed project on the marine resources of the Belcher Islands. Describe the incremental effects of the proposed project on the productivity of eastern Hudson Bay, especially the waters surrounding the Belcher Islands.

5.52 The importance to marine productivity of the annual timing of freshwater discharges into Hudson Bay shall be addressed. Discuss the potential cumulative effects of the proposed project and of other existing hydroelectric projects on the marine resources of Hudson Bay. Insufficient explanation is provided for the lack of data on Hudson Bay. Discuss the significance of missing data concerning the impacts of other hydroelectric projects in Hudson Bay to the analysis of project impacts.

5.53 Provide data to support predictions in the EIS concerning erosion, sedimentation, and ice conditions of the affected watercourses. Indicate the methods by which these predictions were made.

5.54 In the EIS, most of the predictions of impacts on the Great Whale and Little Whale estuaries were based on the experience acquired at the Eastmain estuary. Discuss in more detail the similarities and differences between these estuaries.

5.55 Specify the magnitude and spatial distribution of the predicted temperature and turbidity in the affected estuaries which would occur during the operation of the proposed project. Indicate the changes expected to occur at the mouths of the Great Whale and Little Whale Rivers (changes in depth, wave regimes and offshore deltas). Discuss the models used to predict changes in the physical and chemical characteristics of the affected estuaries, the reliability of these models, and the manner in which they were verified. In particular, discuss the modelling of the conditions under ice in the estuarine environment.

5.56 Anticipated changes in the sedimentation regime of the Great Whale and Little Whale Rivers were not dealt with in sufficient detail in the EIS. Describe with greater precision the effects of the project on the long-term equilibrium conditions of sedimentation in the estuaries of the Great Whale and Little Whale Rivers. Discuss the reliability of the results of relevant analyses.

5.57 Indicate the means by which the size and shape of freshwater plumes was calculated for open and for ice-covered water. Specify how anticipated under-ice temperatures, salinities, and water velocities were calculated.

5.58 The EIS has not treated the fate of Manitounuk Sound in terms of habitat stability. Depth-averaged models were used in spite of the predicted stratification of density in the water column. Comparisons of numerical models, physical models and observations of salinity, velocity and temperature were not given. Explain why 3-D numerical models were not used to predict changes to currents and water mass characteristics. Discuss why ice was not included in the numerical and physical models described in the EIS. Provide evidence that numerical models were calibrated for the present conditions in Manitounuk Sound. Evaluate the importance of freshwater retention in Manitounuk Sound. Discuss the changes to shore erosion characteristics which would result from increased surface currents in the Sound.

Exploitation of Resources

GUIDELINES paras 547 to 552

Exploitation of resources:

547. The Proponent shall study expected changes resulting from the proposed project on the harvesting of fauna and plants, berries and other vegetation. The Proponent shall clearly identify the work that would take place on each trapline and shall also take into account the different categories of land established by the JBNQA.

548. In this study, the Proponent shall consider the entire territory to be occupied in a continuous fashion even if, for example, certain parts of the territory appear to be unoccupied at the time the studies are carried out. Replacement territories for traditional activities are to be considered in this context.

549. The Proponent shall evaluate the effect of the proposed project with regard to use of the territory by present or future Native or non-Native local populations for activities other than food production, such as recreation, education, the transmission of knowledge, rest, tourism, community and inter-community festivals, and others.

550. Moreover, the Proponent shall examine the effect of the proposed project on the current and potential state of sports fishing and hunting. The Proponent shall evaluate the availability of animal resources, not only for the inhabitants of the region, but also for users from the rest of Quebec or elsewhere. The study shall take into account the influx of sport fishermen and hunters during and after construction, whether they be workers or visitors to the region, particularly in the context of the opening of the communities of Kuujjuarapik and whapmagoostui. Reference shall be made to the experience acquired in the James Bay region during and after the construction of the La Grande complex. The combined effects of opening the territory and modifying it in terms of area, availability and accessibility shall also be taken into account.

551. In addition, the Proponent shall examine the impacts that would result from the proposed project on tourism in the region, taking particular account of sites with a potential for sports or tourism, highly valued species, and rivers known for recreational or other activities. The Proponent shall evaluate the availability of these resources, not only for the members of local communities, but also for a wider population that identifies with the territory or shows interest in certain specific components of the environment.

552. The Proponent shall discuss in what way the proposed project is compatible with Native or non-Native plans for future development of the territory. For example, the Proponent shall examine the effects that would result from economic stimulation in the region (investment, employment structure, income, etc.). The Proponent shall in particular consider the future use of new products, the introduction of new technologies to process raw materials already in use, and the development of new markets. In short, the Proponent shall study the effects of the proposed project (including the construction of roads and airports) on regional development (outfitting, mines, etc.). The Proponent shall also examine the consequences of the proposed project on the availability of government services, the quality of air transport services, and the cost and availability of consumer products (the absence of competition shall be emphasized, when appropriate).

5.59 Assess the cumulative impacts of changes in both natural resources and the human environment for communities in the study area.

5.60 Provide recent data concerning the harvest of wildlife by all Native groups in the study area, including the Inuit of Sanikiluaq, and concerning the collection of plants by the Cree. Describe and evaluate the impacts which the project would have on the harvesting of wildlife by all Native groups.

5.61 Specifically, evaluate the impacts of increased tourist (e.g., hunters and fishers) resulting from the opening of the territory on wildlife populations and their exploitation by Native peoples, paying particular attention to Manitounuk Sound, the Lac Bienville region and the Belcher Islands.

5.62 Analyse the consequences of the project on the re-organization of traplines.

5.63 Besides the jobs created by the project itself, evaluate the employment and economic potential of activities related to tourism, tourism promotion, outfitting, mineral resources, and other environ men t-related activities such as wildlife management, environmental monitoring, mitigation and management.

5.64 Describe and analyse the future plans of the different Native communities in the study area regarding tourism development or other economic activities. Discuss the impact of the proposed project on these plans.

5.65 Provide data on the exploitation of non-wildlife resources, such as cultural and tourist sites, for each community affected, and describe how the project will affect these resources.

The Project Considered as a Resource

GUIDELINES paras. 553 to 555

The project considered as a resource:

553. The Proponent shall describe the economic spinoffs that would be derived from the sale and rental of goods and services on a local, regional and national basis. The Proponent shall explain how the proposed project would contribute to the economic development of all the communities in the region, and shall also examine the possible impacts on these same communities should the proposed project or some of its elements be abandoned.

554. The Proponent shall evaluate the impacts of the proposed project on the employment situation, locally as well as regionally and nationally. This evaluation should include the number and type of jobs that would be created; length of employment; training and experience acquired; as well as salaries for Native and non-Native workers from the region, from neighbouring towns and regions, and from the rest of Quebec. Furthermore, the hiring policy with regard to Native workers shall be specified.

555. The Proponent shall present a profile of workers to be hired in Native communities (age, sex, education, training, experience), and shall describe their possibilities for long-term employment during operation of the facilities. In addition, the Proponent shall specify both the type and duration of the jobs that Native workers would hold.

5.66 Provide information on and discuss the implications of the economic spinoffs of the project. This discussion shall include the development of Native-owned businesses in the affected communities, including Sanilkiluaq and Kawawachikamach.

5.67 Describe the future employment situation in the communities affected by the project. Discuss the Native people's desire for employment in the project. Evaluate the medium- and long-term social effects of jobs created in the communities.

5.68 Discuss the economic consequences to the communities likely to be affected by economic spinoffs of the proposed project, if the project is cancelled or if some of its important elements are substantially modified.

5.69 Among the implications of the project for the affected communities, examine the possible need for additional municipal services in Kuujjuarapik/Whapmagoostui.

Social Cohesion

GUIDELINES paras. 556 to 566

SOCIAL COHESION:

556. Once again, making use of the descriptions required in Chapter 3, the Proponent shall describe how the proposed project would fit into the existing process of social change in the communities of northern Quebec. More specifically, the Proponent shall indicate what effect the proposed project would have on the extent, intensity and rate of the social change that has been underway since the 1950s, as a result of both internal or external factors.

557. The Proponent shall identify and evaluate the possible consequences of the proposed project on the social cohesion of Native communities in the territory. In particular, the Proponent shall consider the following aspects: the sense of autonomy, the boom-and-bust effect, population displacement, effects related to the opening of the region, the presence of migrant workers and the Native work force.

558. The Proponent shall study the risk of the boom-and-bust effect in Quebec and Native societies that might result from the proposed project. This disruption is related to large but temporary construction sites that are shut down abruptly. The Proponent shall indicate how extensive this effect might be, as well as the consequences that might follow.

559. Furthermore, the Proponent shall study and evaluate not only how the proposed project would modify access to the territory and to resources, but also what impact these modifications would have on the social organization of the communities. In particular, the Proponent shall examine the possible transformation of family relations and relations between the sexes and the generations due to changes in activities involving the harvesting and consumption of goods from the territory (for example, changes caused by mercury contamination). The Proponent shall also study changes affecting the relations between groups formed to carry out specific activities in the territory (hunting, fishing, weekend camping, etc.). The Proponent shall also examine possible changes in relations among the members of each community, particularly with regard to relations involving the distribution of the population across the territory and the sharing of game.

560. The Proponent shall study the possibility that individuals or families would emigrate from one community to another after completion of the proposed project, and shall assess the impact of any such movement on Kuujjuarapik and Whapmagoostui, the communities most directly affected, as well as on others.

561. The Proponent shall also study the anticipated effect of the opening of the region and of the communities of .Kuujjuarapik and Whapmagoostui. In this regard, the Proponent shall evaluate the medium and long-term social effects of interpenetration among regions that, until now, have remained isolated. With regard to the inhabitants of the North, the Proponent shall identify the elements of social life in general that are likely to resist or to be susceptible to change. In particular, the following factors shall be evaluated:

1. the social impacts of economic development (outfitting, tourism, mining, commerce, etc.);

2. impacts on Native employment;

3. the effects of easier access to the South, especially for youth;

4. the positive and negative effects of increased contact with the inhabitants of neighbouring regions, as well as with visitors who might travel to the region for one reason or another;

5. the effects of easier access to alcohol, solvents and drugs, particularly the possible increase in the rate of violent death and family and community violence;

6. the effects on the rights of Native people; and

7. the cumulative social effects of the proposed project, which would take place alongside the other sources of the social change affecting the populations of the region.

562. Each major component of the access infrastructures shall be examined (north-south and east-west roads, airports, etc.); the access routes shall also be evaluated as a whole, since their effects are likely to be cumulative. In the same way, the study shall include an analysis of the positive and negative effects that would result from a road connection between Kuujjuarapik/Whapmagoostui and the sites of any other development activity in the territory. In preparing this section, the Proponent shall work closely with the communities of Kuujjuarapik, Whapmagoostui and Chisasibi, and shall indicate the experience acquired following the opening of other communities in northern Quebec, on the Lower North Shore or elsewhere in Canada. The Proponent shall also collaborate with the relevant organizations and governmental departments.

563. The Proponent shall examine the effects of increased Native presence in Quebec's Near and Middle North. The Proponent shall also analyze how the inhabitants of these regions would be affected by their participation or non-participation in the construction of the proposed project and in its future operation.

564. The Proponent shall study the impact of the presence of migrant workers in the territory during the construction period. Information shall be provided with regard to the anticipated number of workers, their place of origin, main characteristics, living and travelling conditions, work schedules and holidays, consumption habits and behaviour (including alcohol and drugs), sexuality (including epidemiological and social risk behaviour) and recreational activities, including hunting and fishing. The Proponent shall also determine the level of knowledge among these workers concerning Cree and Inuit history and culture, and concerning the various agreements signed by the Native people and the governments of Quebec and Canada. Moreover, the Proponent shall provide information on safety and health conditions for all workers at the sites. The Proponent shall also provide information on representations made by workers and their families with regard to the advantages and disadvantages of working in James Bay and on the probable impacts of their work on their skills and on their ability to find work or to be retrained after the project has been completed.

565. The Proponent shall evaluate the medium and long-term social effects of jobs created in the Native communities. To this end, the Proponent shall specifically study Native attitudes toward wage work, Native representations regarding employment in development projects, relations between Native and non-Native workers both on-and off-site, and problems encountered by Natives employed in the construction of such projects. For the study of these last two points, the Proponent shall draw upon the experience of the La Grande complex.

566. The Proponent shall complete the analysis of social effects by extending the exercise called for in paragraph 251 with an evaluation of the positive and negative effects of the construction or abandonment of the proposed project on the population of southern Quebec.

5.70 The analysis in the EIS of the impacts of the proposed project on the social cohesion of the affected communities is inadequate and incomplete. It does not provide a sufficient basis on which to understand or evaluate the impacts, negative or positive on the social, economic and cultural fabric of the affected communities. Moreover it does not adequately discuss the fundamental issue of respect for Native knowledge and culture. The Proponent is redirected to respond to paragraphs 556 to 569 of the GUIDELINES, in its study and analysis of these areas. This shall be done in an integrated fashion, based on a comprehensive use of the literature and the results of adequate study and consultation in cooperation with the affected peoples.

5.71 The GUIDELINES required that the Proponent evaluate the movement of goods and people that would be generated by new roads, and estimate their consequences on social cohesion in light of, notably, economic development, social problems and pressures on the environment that this movement could generate. The GUIDELINES further required the Proponent to take into consideration the fact that opening up the territory would be one more source of social change. Beyond mentioning the probability of the arrival of a greater number of sport hunters and fishermen or tourists, the analysis shall focus on the possible social effects of the presence of these visitors.

5.72 Discuss the impacts arising from opening up the territory with respect to modifying the current process of social change, referring to appropriate examples elsewhere (for instance, the Alaskan North Slope), but with particular reference to the previous experience of Chisasibi and Eastmain due to the construction of the La Grande complex.

5.73 Examine the anticipated consequences of the project on inter-community migration of local populations, and the resulting consequences on the social cohesion of the societies involved.

5.74 Examine the consequences of the boom-and-bust effect which would be caused by the project on the local communities.

5.75 Examine the consequences, for the communities, of jobs created by the project, with regard to the possible effect of employment on the diversification of social roles in the population.

5.76 Discuss the issue of migrant workers' consumption and behavioural habits with respect to the possible effects of these habits on the Native communities of the study area. Incorporate information from the La Grande experience, and take into consideration the fears and apprehensions of the Native populations which would be affected.

Respect for Values

GUIDELINES para. 567

RESPECT FOR VALUES:

Respect for culture:

567. The Proponent shall evaluate the effects of the proposed project on the cultures of the Cree, Inuit and, in certain cases, the Naskapis and the people of the rest of Quebec, as well as on the cultural identity of these groups, paying particular attention to the following elements:

1. life-style, including dietary practices and consumption habits in general, methods of production and distribution of goods and services, artistic production, types of recreation, holidays and celebrations;

2. the Cree and Inuktitut languages and the teaching of other languages, particularly taking into account the increased presence of individuals who do not speak the Native languages;

3. the transmission of know-how and knowledge, given that the activities that encourage such teaching be modified;

4. spiritual ties with any living creatures, and the spiritual dimension of the use of the territory in which they live (rites, ceremonies), including, in some cases, those of the Naskapi;

5. burial sites and relations with ancestors (including for the Naskapi);

6. archaeological heritage. In this regard, the Proponent shall ensure that archaeological digs are carried out on the main development sites and areas proposed for the infrastructures (dams, dikes, reservoirs, roads, airports, etc.). The Proponent shall indicate the measures to be taken should archaeological remains be uncovered;

7. sites and phenomena valued for historical, aesthetic, or other reasons (which the Proponent shall identify), such as portage trails, ancient meeting places, sites where specific events occurred, areas of interest rendered accessible by the project, the Native concept of the continual flow of rivers; and

8. the sense of identification and, more specifically, the notions of belonging related to the territory, language, and cultural values, as well as the sense of responsibility toward the ecosystems.

5.77 Examine the effects of the proposed project on the various Native groups sense of identification, on their notion of belonging related to the territory and self-esteem, and on their confidence in their ability to control their environment as well as their future.

5.78 With regard to land use and harvesting activities, in addition to the collection of basic data (e.g., regions used, cycle of activities, harvested species), discuss the social rules and world view which regulate these activities, the way in which these activities are practiced (weekend vs. seasonal hunting, individual vs. familial hunting, etc.) and the consequences that any modification to these activities may have on other areas of culture.

5.79 Show that the interest of these societies in their burial Sites, and in other Sites of cultural value, has been properly taken into account.

CHAPTER 6

MITIGATIVE AND COMPENSATORY MEASURES

It is essential that mitigative measures be incorporated into the planning of the proposed project, so that, wherever possible, its impacts on the human and biophysical environments can be minimized or prevented. It is therefore important that the Proponent provide details of the measures which would be employed to mitigate the impacts of the proposed project, or to compensate Native communities for losses and social disruption resulting from its construction and operation.

In the EIS, the descriptions of the measures designed to mitigate the project's impacts on the biophysical environment are site-specific and, for the most part, based on experience acquired at the La Grande complex. Because the EIS provides no data concerning the effectiveness of the mitigation programs carried out at La Grande, and since it does not provide a comparative analysis of the extent to which measures in place at La Grande would be appropriate for the proposed project, it is not possible to assess the degree to which the proposed mitigative measures would be effective.

The following requirements of this Chapter are addressed to the Proponent to provide the Review Bodies with a description and analysis of the mitigative and compensatory measures that are complete and adequate.

General

GUIDELINES paras. 601 to 605

GENERAL:

601. The Proponent shall present mitigative measures for the impacts of the proposed project. The Proponent shall also identify the nature and scope of the residual impacts that will occur in spite of these measures and propose, where necessary, a program of compensatory measures.

602. It is essential that mitigative measures be planned in advance, and not be instituted reactively. Before construction work on the proposed project begins, the Proponent shall develop a proactive plan for mitigative and compensatory measures that would be implemented during the construction and operation phases of the complex.

603. A detailed description of the Proponent's policy concerning mitigation and compensation shall be presented, including its rationale and an analysis of mitigation and compensatory measures undertaken with respect to the La Grande projects. In particular, if funds have been set aside (whether as capital or as operating costs) for mitigation and compensation, the Proponent shall distinguish between funds which were destined for mitigation and for compensation, and shall explain how these figures were arrived at. The Proponent shall evaluate the effectiveness and efficiency of the mitigative and compensatory measures for the La Grande projects and shall report on the level of satisfaction of the affected populations with regard to those measures. The Proponent shall also refer to other projects in northern environments (Churchill, Churchill-Nelson, etc), as well as to relevant literature available, in order to demonstrate that the mitigative and compensatory measures proposed reflect the state of the art in the field.

604. Furthermore, the Proponent's policy concerning mitigation and compensation shall be compared with that of other major Canadian utilities that are undertaking hydroelectric development in a northern environment. The Proponent shall refer to other projects in northern environments (Churchill Falls, Churchill-Nelson, etc.), as well as to the relevant literature available in order to demonstrate that the mitigative and compensatory measures proposed reflect the state of the art in this field, and are respectful of Native populations.

605. In keeping with the requirements outlined in paragraph 128, the Proponent shall consult with the Native populations and ascertain their needs with regard to developing mitigative and compensatory measures for the proposed project. A concrete mitigation and compensation program should reflect these consultations.

6.01 Describe the policies concerning mitigation and compensation for the Native communities affected by the Great Whale project distinguishing between the overall resources and those to be devoted to mitigation, on the one hand, and to compensation, on the other. In this context, provide comparative data on the mitigative and compensatory measures for each phase of the La Grande complex. How were compensation packages calculated? Explain the degree to which the measures described for the La Grande complex correspond to those which are proposed for the Great Whale complex.

6.O2 Referring to the experience acquired in all phases of the La Grande complex, including the more recent projects (e.g., LG 1, LA 1, LA 2 and Brisay), describe how the Native communities were involved in planning compensatory and mitigative measures. Report on their level of satisfaction with this process, with the measures taken, and with the means used to assess that satisfaction.

6.03 Referring to the La Grande complex, evaluate the efficiency and effectiveness of the organizational structures put in place to implement the mitigative measures, including liaison committees, and report on the experience gained since the structures were established, including the perceptions of the Native populations.

6.04 With regard to the anticipated residual impacts and compensatory measures, discuss how the Proponent's Politique de mise en valeur integree will be applied to the Great Whale complex.

6.05 Describe how the results of the consultations with the Native peoples and other intervenors in the Great whale project will be taken into account in planning mitigative and compensatory measures. Justify the consultation methodologies to be used to ensure the cooperation of, and collaboration with, the Native communities.

6.06 Justify the selection of mitigative measures in light of current and evolving knowledge and practices elsewhere in Canada.

Mitigative Measures

GUIDELINES paras. 606 to 609

MITIGATIVE MEASURES:

606. The objective of mitigative measures is to lessen or alleviate a project's negative environmental impacts. To this end, the Proponent shall present all such measures, as well as the preventive and corrective actions proposed during all phases of the proposed project. Particular attention shall be paid to minimizing the impacts on Category I and II lands.

607. The Proponent shall provide an indication of the costs, timing and mode of implementation of these mitigative measures, and shall identify the parties responsible for their implementation, as well as the contractual obligations of the contractors and sub-contractors hired to carry out specific measures.

608. The Proponent shall also report on the experience concerning the organization of remedial work activities and propose an institutional framework appropriate to the proposed project. The proposed institutional framework shall take into account the central role of Native peoples who will be affected by the proposed project.

609. The review of mitigative measures by the Proponent shall include, but not be limited to, the following aspects and general categories: health and well-being; safe access to land and resources; drinking water quality and supply and other municipal infrastructures; valued or sacred sites; socio-economic impacts; employment and contractual opportunities for Native peoples; hydrological management, restoration and project management.

6.07 Describe the proposed mitigative measures, including their scope, the potential work-sites, timetables, and the organizations responsible for their implementation, with an estimate of the funds allocated to each mitigative measure.

6.08 Specify the proposed mitigative measures for minimizing the impacts of the project on the environment of Manitounuk Sound, including those measures relating to the GB 1 tailrace canal.

6.09 Indicate the degree to which the proposed mitigative measures and those set forth in existing agreements constitute firm commitments that will actually be realized.

6.10 In many cases mitigative measures will themselves have environmental impacts. Specify and discuss such proposed mitigative measures and their impacts.

6.11 In the event of the project's construction, patterns of winter and spring travel on the frozen surface of Manitounuk Sound would be disrupted by the formation of an ice-free area in the vicinity of the GB 1 tailrace canal. Provide details concerning possible routes around this area, incorporating relevant experience obtained at the La Grande estuary.

6.12 Indicate the costs of mitigative measures associated with the construction of the collector system, the PRB airfield, and related infrastructures (excluding the GB l-PRB road, for which costs are already included in the estimated cost of the PRB diversion structures). Indicate whether the various Proponent-financed mitigation funds described in the EIS are included in the estimated cost of the PRB diversion structures, or whether they represent additional funds.

Health and Well-Being

GUIDELINES paras. 610 to 612

HEALTH AND WELL-BEING:

610. The Proponent shall identify the groups that would be most affected by the proposed project and shall consult with members of those communities to determine ways to reduce or eliminate any impacts on health and personal and community well-being.

611. The Proponent shall indicate how the collaborative work with existing health-care agencies will be established and shall ensure that community members (particularly those concerned with health-related matters) may participate in the decision-making process.

612. In the case of mercury, the Proponent shall suggest a social intervention strategy and shall identify the resources required to implement and periodically review it. In this context, the Proponent shall propose, among others, a strategy for ongoing dialogue and consultation between the Proponent and the affected population as well as those government agencies involved. The Proponent shall address problems of language or comprehension in implementing information programs for users of these resources.

6.13 Describe how a plan will be developed, in consultation with the communities concerned, to inform the inhabitants about the possible risks of acute and chronic methylmercury intoxication. This plan shall include a list of fishing and resource harvesting areas where the risk of contamination is acceptable. The plan shall integrate local environmental and ecological knowledge.

6.14 Provide the main elements of a nutrition education program, including a food consumption guide, that would be required to help minimize the risk of chronic methylmercury exposure to the affected Native populations. The Native communities and the health authorities shall be consulted on this matter and the programs and guides shall take into account other socio-economic factors such as dietary changes in different age groups and the practical economic difficulties encountered by the Cree and Inuit communities with regard to food harvesting and the consumption of store-bought food.

6.15 Considering the uncertainty that still exists concerning the chronic effects of methylmercury intoxication, justify the choice of an intervention threshold that does not follow WHO recommendations regarding the admissible level of consumption of foods contaminated by methylmercury.

6.16 In order to better understand and assess the intervention strategy proposed for methylmercury contamination, specify the nature of the intervention protocol and the operations of the proposed methylmercury monitoring and analytical laboratory.

6.17 Provide an assessment of the recent research into possible mitigative strategies designed to control the production of methylmercury.

Safe Access to Land and Resources

GUIDELINES paras. 613 to 61 5

SAFE ACCESS TO LAND AND RESOURCES:

613. The Proponent shall indicate how the free movement of Native peoples will be maintained, should the proposed project be approved, in order to ensure access to the territories, including replacement of access routes for fishing, hunting and trapping during construction phases when access will be restricted; and the possibility of maintaining rivers, lakes and reservoirs as traditional transportation routes for Native peoples, both in summer and winter.

614. In addition, the Proponent shall indicate the specific measures to be taken to ensure that Native activities can be pursued in safety. Where waterways become partially or totally unsuitable for travel due to reduced or increased water flow, the Proponent shall specify remedial and compensatory measures to be implemented.

615. The Proponent shall examine the measures to be taken to limit negative impacts on migratory birds, considered as a resource for southern and northern populations.

6.18 The proposed project's main impacts on the access to resources and on safe travel throughout the area would result not only from the modification of the existing transportation routes, but also from the long period that would probably be required before new patterns of transportation, and hence of land use, could be established. Direct impacts on resources could result from reducing the accessibility of highly harvested areas, or from opening up formerly remote areas, creating a risk of over exploitation. Identify anticipated mitigative methods or compensation which would be required to counteract the negative effects of the proposed project's dikes, bridges, control weirs and various other structures on water travel. Indicate the nature of proposed mitigative measures, and the areas where they would be employed.

6.19 Describe programs planned to disseminate information to the users of the affected waterways concerning post-project alterations in navigation conditions.

6.20 For present and future users of the territory, prepare a synthesis of potentially dangerous situations which could arise during and after the project's construction. Provide details concerning measures planned to prevent or mitigate such dangers.

6.21 Provide an analysis of the JBNQA and Native land tenure systems with regard to the lands affected by the project infrastructures, including access routes and corridors.

6.22 Demonstrate how the selection of all access routes and corridors that impact on Native land tenure systems adequately take into account the aims of the Proponent's consultation policies and, in addition, human environmental issues such as the Native use of traplines, wildlife harvesting and other Native resource development activities.

Drinking Water

GUIDELINES paras. 616 and 617

DRINKING WATER AND OTHER MUNICIPAL

INFRASTRUCTURES:

616. The Proponent shall indicate how an acceptable and adequate drinking water source both in quality and supply for Kuujjuarapik/Whapmagoostui will be ensured, in collaboration with these communities. In this regard, the Proponent shall present the various options and indicate the advantages and disadvantages of each one while describing the work required and the environmental impact. The Proponent shall also identify any other agencies involved and indicate the extent of the Proponent's participation in the implementation of the measure taken to guarantee that the communities will have a viable and sufficient source of drinking water to satisfy their current and future needs.

617. The Proponent shall also propose mitigative measures to be undertaken concerning other municipal infrastructures (e.g., solid waste and wastewater) that could be affected by the proposed project.

6.23 The EIS proposes five options for a source of drinking water for the village of Kuujjuarapik/Whapmagoostui, but does not present adequate technical information about each one, nor does it discuss the advantages and disadvantages of each option. Discuss the advantages and disadvantages of each of the five proposed options for the water supply for Kuujjuarapik/Whapmagoostui, incorporating a discussion of the perceptions of the Native communities with respect to water quality. Discuss the means of transport of water from its source to its recipients, and the possible impacts of the required installations. Provide supporting technical studies to justify the various options proposed.

6.24 Regarding the sources, treatment, and anticipated quality of drinking water for the communities of Kuujjuarapik and Whapmagoostui, specify the procedures which will be put into place to enable consultation with, and collaboration between, the responsible agencies.

6.25 Demographic projections presented in the EIS extend from 1989 to 2004. Identify the methodology used to generate the Proponent's estimate of drinking water needs in 2014.

6.26 Concerning available options for the post-project drinking water supply for Kuujjuarapik/Whapmagoostui, indicate the degree to which ground water, and the construction of weirs on the Great Whale River, were considered.

6.27 Identify specialized training programs and characteristics of the operation and maintenance of proposed and future water management systems in Kuujjuarapik/Whapmagoostui.

Valued or Sacred Sites

GUIDELINES paras. 618 and 619

VALUED OR SACRED SITES:

618. In. consultation with the communities concerned, the Proponent shall identify the location of burial sites that could be disturbed by the proposed project, and shall design a program to deal with their possible relocation. In addition, the Proponent shall discuss measures to be undertaken for the preservation of historical, sacred, cultural, archaeological and natural sites and the recovery of materials. The Proponent shall also discuss the best way to use the results of various studies to enhance knowledge of the history and prehistory of the territory in order to ensure that this knowledge is made available to Native groups.

619. Measures the Proponent intends to undertake regarding the aesthetic and recreative enhancement of areas which may or may not be affected by construction work, including those used for hunting and fishing, shall be indicated. These measures shall include the possible deforestation of sectors to be flooded for purposes of aesthetics or wildlife management and/or the removal of wood residue after impoundment. The Proponent shall also examine the possibility of selecting corridor pathways in such a way that the power lines would be as little visible as possible from sites of special interest.

6.28 Provide an inventory of the areas and sites valued by each Native community. Indicate those areas and sites which the communities wish to see protected, as well as measures proposed to accomplish this work. Indicate how the Native groups concerned will be informed of the results of this inventory.

6.29 Describe the archeological work and excavations that have been carried out to date, and describe a mitigation program to execute the archaeological work which remains to be carried out. The description of this program shall include the work schedules, priorities for action, and criteria to be used to select the specific sites to be excavated, and shall indicate how "concentration" with the Native communities could be assured.

6.30 Describe the modalities of the November 1, 1978 agreement between the Grand Council of the Cree and the SEBJ concerning the location and moving of burial sites, and indicate each Native populations' level of participation and satisfaction regarding this program. Indicate whether this agreement could serve as a model for the Great Whale project.

6.31 Indicate the archaeological research methods chosen, especially with regard to integrating the knowledge and oral tradition of Native people, with the purpose of encouraging the Native people's participation in the various stages of achaeological work: from site surveys to excavation, analysis, interpretation of data, and communication of results.

6.32 Indicate how archaeological finds will be displayed, and how archaeological results and interpretations will be communicated to the Cree, Inuit, Naskapi, and to the public in general. Include the results of all prior surveys conducted in the territory, in particular those conducted at the La Grande complex. Discuss the format of the communications plan, and provide details concerning the schedule for its implementation.

Socio-Economic Impacts, Employment, and Contractual

Opportunities for Native Peoples

GUIDELINES paras. 620 to 624

SOCIO-ECONOMIC IMPACTS, EMPLOYMENT AND

CONTRACTUAL OPPORTUNITIES FOR NATIVE PEOPLES

620. The Proponent shall describe the most appropriate strategies for the development of education programs designed and carried out by Native peoples to heighten awareness of the proposed project's impacts, the social changes that may occur, and the mitigative measures that might be taken to minimize the impacts of the proposed project.

621. The Proponent shall outline policies concerning the employment of Native peoples and the use of Native enterprises by the Proponent and by contractors engaged for the construction and operation of the proposed project.

622. Measures the Proponent intends to take to ensure that a substantial number 6f Natives have employment opportunities and to ensure that Native enterprises are involved in the construction and operation of the proposed project shall be identified. This shall include but not be limited to: a clear policy concerning preferential employment and contractual allocations to Natives; the measures the Proponent intends to include in the tender documents to ensure that contractors hire Native workers and subcontract to Native enterprises; the number of jobs which the Proponent and contractors would guarantee to the Native population, both in the construction phase and in the operation of the proposed project; and an indication of the value of contracts which the Proponent and contractors would guarantee to Native enterprises.

623. The experience of the Proponent during the construction and operation of the La Grande project shall be presented, with emphasis on the effective participation of Native people in construction work and the value of and interest shown in training programs designed to develop local manpower for the long-term jobs that were created. The Proponent shall take into account the reports prepared by the James Bay Employers' Association.

624. Employment barriers to Natives shall be identified and specific corrective measures proposed. These barriers shall include but not be limited to the use of French in the workplace, restrictions resulting from collective agreements, employment regulations in the construction sector, and the training requirements of the Native population.

6.33 Describe policies and mechanisms which would favour the employment of Natives and the awarding of contracts to Native enterprises during the planning, construction and operational phases of the project.

6.34 Indicate the number of jobs that would be guaranteed for the Native population during the operational phase of the project; also provide an indication of the number of jobs and the value of the contracts that the Proponent and its contractors would guarantee Native enterprises.

6.35 Discuss specific corrective measures that would remedy restrictions on the employment of Native peoples resulting from collective bargaining agreements and employment regulations.

6.36 Specify measures that will facilitate the learning of the French language by the Native work force.

6.37 Analyse the outcome of professional development and training programs at the La Grande complex. Provide an analysis of Native participation in these programs. Indicate the duration and types of employment, both short-term and permanent, that Native trainees were able to obtain. Provide sources of information for this analysis.

6.38 The EIS does not include information concerning strategies for the development of educational programs to be used by Native peoples in the affected communities to heighten awareness of project impacts and related career development opportunities. Indicate strategies planned to establish ongoing educational programs concerning the project's impacts and related career development opportunities for Native people.

6.39 Describe the training programs which Native workers would require in order to gain employment in the construction and long-term operation of the proposed project. Program descriptions shall include information concerning strategies which could be adopted to favour the development of new training methods, such as: correspondence education, short-term courses, the use of new information technologies, the organization of exchanges of personnel and ideas, the creation of new structures of cooperation and partnerships, and the diffusion of economic and job-related information.

6.40 Provide specific information about the periods during which work schedules would be modified to accommodate traditional hunting activities. Indicate the process by which decisions of this nature will be made, and how they will be coordinated with the Native peoples.

Hydrological Management and Ecosystem Maintenance

GUIDELINES paras. 625 to 628

HYDROLOGICAL MANAGEMENT AND ECOSYSTEM MAINTENANCE:

625. The Proponent shall discuss policies and commitments regarding the management and control of water levels in rivers where flows are to be decreased, in order to maintain viable ecosystems. The measures aimed at regulating or mitigating the effects of backflow and flooding along banks in areas where flows are to be increased shall also be discussed. A review of erosion control measures and other measures shall also be provided. The Proponent shall carry out the same type of analysis regarding reservoirs.

626. The Proponent shall explain plans for the construction of dikes or dredging to restrict flooding and shall present the impoundment schedule, including the uncertainty inherent in such a schedule. The possible environmental benefits of these plans shall be outlined.

627. In reservoirs, and in the Lac Bienville area in particular, the Proponent shall discuss plans to control water levels via containment measures and shall outline mitigating measures where waterfowl and other resources are vulnerable to this type of development.

628. With regard to impacts on fish and other wildlife, the Proponent shall address at least the following:

1. protection and development of aquatic habitats;

2. opening of new fishing areas;

3. formulation and evaluation of methods for implementing an intensive harvest program, prior to filling the reservoirs and forebays upstream, to enable the recovery and relocation of wildlife;

4. a comparative and detailed assessment of mitigative strategies designed to control the production of methylmercury and its bio-accumulation in fish, waterfowl and marine mammals;

5. development of spawning beds, taking into account reservoir operations and the various species concerned, specifying design and location criteria;

6. implementation of measures to allow for fish transport through the turbines and to control fish mortality;

7. formulation of a reservoir management policy designed to ensure the protection, diversity and productivity of fish stocks in the reservoirs. To this end, the Proponent shall discuss links between reservoir design and operation criteria on the one hand and fish community structures and reproductive strategies on the other; the Proponent's analysis shall include a clear description of the constraints inherent in managing reservoirs and containment bays as well as an explanation of the areas of uncertainty that should be considered in developing these strategies;

8. establishment of an environmental studies program designed to improve the level of information available on the freshwater seal population of the Lacs des Loups Marins;

9. recovering wood debris from reservoirs; and

10. maintenance of minimum discharge.

6.41 Provide relevant studies, with specific examples, of various erosion and flood-control measures which could be employed in reservoirs and reduced-flow rivers of the proposed project to maintain the integrity of local ecosystems. Include an assessment of the effectiveness of such measures as were applied at the La Grande complex. In particular, describe the scope of the work which would be required to lower the natural sill on the Coats River to reduce flooding along the diversion pathway, and discuss the degree to which flooding would be reduced.

6.42 Describe measures which could be employed to protect the permafrost areas on the periphery of the proposed GB 1 reservoir from erosion. Describe specific measures planned to maintain the integrity of areas of riparian and peatland ecosystems of interest around Lac Bienville.

6.43 Describe existing or projected programs for the protection of ecosystems that host species which are rare, threatened or endangered.

6.44 Indicate the degree to which using deflectors to artificially increase current velocity in reduced-flow rivers would provide a suitable habitat for the harlequin duck. Provide supporting data from previous experiences, if available. Assess the possibility of using alternative measures.

6.45 The EIS suggests that one measure which could mitigate the proposed project's impacts on waterfowl populations would be the enhancement of waterfowl habitats in Southern Quebec, where breeding density is higher than in the study area. Provide details of such a habitat-enhancement plan, taking into account the different habitat requirements of waterfowl. Discuss the practicality and anticipated effectiveness of such a plan, and the surface area and location of the habitats which would be required. Concerning the installation of nesting platforms to improve habitat for birds of prey, provide a list of target species according to the habitats affected, and specify the locations where structures designed for golden eagles would be placed.

6.46 Indicate the extent to which the enhancement of waterfowl habitats in Southern Quebec would benefit Native peoples in the North. Indicate the extent to which the cost of mitigative measures planned in Southern Quebec are part of the amount reserved for the Great Whale complex.

6.47 Provide a discussion of other measures in Northern Quebec which could mitigate the proposed project's effects on key waterfowl species.

6.48 Indicate the extent to which various key mammal species could be drowned during the impoundment of the proposed project's reservoirs and forebays, providing appropriate supporting evidence. Explain why it is deemed unnecessary to proceed with a wildlife harvesting program in the areas which would be flooded by the proposed project.

6.49 In light of previous relocation programs, discuss the fact that only one relocation (i.e., that of a golden eagle nest) has been proposed for the Great Whale project.

6.50 With regard to the management of reservoirs and project impacts on fish in general, discuss mitigative and compensatory measures and management schemes which could be used to preserve or create spawning grounds. Demonstrate the effectiveness of measures to enhance or create spawning grounds for the affected fish species, in light of previous work conducted in this field. Map the areas with potential for development as spawning habitats.

6.51 The EIS indicates that lake trout and suckers have difficulty surviving in reservoirs, yet contends that no fish species have ecological constraints which require specific water management measures. Justify this latter contention using available data.

6.52 Since data in the EIS indicate that freshwater seals inhabit the areas where the proposed GB 1 and Bienville reservoirs would be located, discuss potential mitigative measures for the seal population in these regions.

Restoration and Project Administration

GUIDELINES para. 629

RESTORATION AND PROJECT ADMINISTRATION:

629. With regard to clean-up measures, restoration of degraded areas and resources and project administration, the Proponent shall develop strategies that address the following:

1. clean-up of sectors that could be flooded and which include waste items, particularly barrels, that could pose a threat to the environment;

2. periods when construction must be modified in order to protect fish spawning, waterfowl migration, caribou migration, etc.;

3. the proposed restoration program and the various methods available for restoring and redeveloping sites which were stripped or otherwise disturbed by construction activities;

4. if temporary roads prove necessary, the Proponent shall indicate the re-naturalization modes selected. The Proponent shall also indicate the measures to be implemented for decommissioning these roads and other infrastructures and for restoring the affected watercourses;

5. the administrative status of permanent roads, during and after construction; the Proponent shall indicate which department or organization will control and maintain these roads and control access to the territory;

6. the possibility of adjusting work schedules to accommodate traditional hunting activities, especially in Manitounuk Sound;

7. long-term responsibility for the implementation of the mitigative measures should project infrastructure or other types of equipment cease to be under the Proponent's control; and

8. clean up and renewal programs related to material and waste at the end or during the construction periods and operation.

6.53 Provide details concerning the restoration of sites which have been cleared or disturbed as a result of construction activities. Discuss the comparative advantages and disadvantages of the different methods for restoring disturbed sites.

6.54 Discuss the comparative success of different revegetation programs carried out at La Grande. Indicate whether the planned measures for the regeneration of vegetation in the sites affected by the proposed project will be similar to those which were implemented at the La Grande complex. Indicate whether revegetation programs would be adapted to the particular requirements of certain sectors of the proposed project and if so, how these programs would be adapted. Describe the extent to which plant species more readily usable by wildlife than alder (e.g., willow) could be used in the restoration of different types of environments.

6.55 Present measures proposed for recovering wood debris from reservoirs. Assess the potential impacts of these measures, taking. into account the recovery procedure or procedures these measures would entail.

6.56 Specify the periods during which construction might be modified to protect important fish and wildlife species. Describe the process by which decisions with respect to such modifications would be made.

6.57 Indicate what mitigative measures would be required if the roads are opened to the public, or if they remain as private roads with controlled access.

Residual Impacts and Compensatory Measures

GUIDELINES paras. 630 to 634

RESIDUAL IMPACTS AND COMPENSATORY MEASURES:

630. Residual impacts are those physical, social and economic impacts for which no mitigative measures can be established or that remain even after implementation of mitigative measures, including the environmental impacts of such major installations as dams, dikes, access infrastructures, and transmission line corridors which permanently alter the natural environment.

631. The Proponent shall identify the nature and scope of all residual impacts of the proposed project regarding both the construction and operation phases of the complex, referring to the same criteria used to identify the original impacts in order to facilitate comparison between the two groups of impacts. The Proponent shall present residual impacts in the form of an overview that will enable compensatory measures to be identified.

632. There is often a fine line between mitigative and compensatory measures. Some mitigative measures identified above may also be described as compensatory measures. It shall be the Proponent's responsibility to distinguish one from the other in the presentation of the

EIS.

633. The Proponent shall clearly describe its policy concerning compensating the Native population for the construction and operation of the proposed project, as well as for its impacts. The Proponent shall indicate how this policy would be applied with respect to the proposed project and in particular shall identify which persons or groups would be compensated.

634. The Proponent's policy regarding compensation for the Native population with respect to any unforeseen impacts of the proposed project discovered after mitigation and compensatory measures had already been determined shall also be indicated.

6.58 Present a breakdown of the nature, duration and intensity of the residual impacts which would be associated with the proposed project. With regard to residual impacts on Native land use, provide a comparative analysis of the experience obtained at the La Grande complex.

6.59 Describe compensatory measures which could be applied with regard to the residual impacts of the proposed project. Issues of mixed jurisdictions shall be addressed clearly (e.g., the Proponent, government agencies, Native agencies, non-governmental organizations).

6.60 Describe specific measures which could be put into place to resolve possible conflicts which may arise concerning the exploitation of wildlife resources, in the context of previous experience in the James Bay territory.

6.61 In the context of the proposed project, describe the Proponent's policy regarding the provision of compensation for the Native communities which would be affected, should unforeseen impacts be observed after the initial implementation of mitigative and compensatory measures.

CHAPTER 7

ENVIRONMENTAL SURVEILLANCE, MONITORING AND LONG-TERM MANAGEMENT PROGRAMS

Descriptions of the programs for the surveillance of practices and procedures during the construction phase of the proposed project and details of programs necessary to monitor changes in the biophysical and human environments during and following its construction, are essential and vital information for the authorization of the project. Furthermore, the presentation of a coherent plan for the management of the long-term impacts of the project over its lifespan, and afterwards, is considered essential in view of the irreversible effects that the proposed project might have on the development of this and adjacent regions of Northern Quebec.

In the EIS, the program proposed to monitor the human environment is not as rigorous as that proposed for the biophysical environment. No general plan is set forth for measurement or long-term management of the project's social impacts on Native peoples, nor is a comprehensive process proposed which would facilitate consultation with the Native peoples in this regard. The discussion provided concerning long-term management pays little attention to issues relating to the management and conservation of northern environments.

Information concerning programs to be put into place to monitor the effects of the project on the biophysical environment is based largely upon experience at the la Grande complex. As was the case with the mitigative measures, however, no appraisal is provided of the effectiveness of the monitoring programs put in place at la Grande, and it is therefore difficult to predict how effective these programs would be in the context of the proposed project.

The following requirements of this Chapter are addressed to the Proponent to provide the Review Bodies with description and analysis of environmental surveillance, monitoring and long-term management programs that are complete and adequate.

Overview and Principles

7.01 Present an organization chart indicating the protocols and institutional frameworks that would govern the coordination of the organizations involved in environmental surveillance, monitoring and long-term management, and the approval of sectorial studies to be done. Specify the nature (e.g., monetary, technical, administrative) of the proposed collaboration between the Proponent and these organizations, and discuss how this collaboration would take place.

7.02 Describe the procedures that will be established with the Cree, Naskapi and Inuit populations of both Quebec and the Belcher Islands to ensure their participation in any proposed mechanisms for surveillance, monitoring and long-term management.

7.03 If, in the course of the long-term management of the project, unanticipated impacts are recognized or impacts are found to have been initially underestimated, describe the process by which decisions would be made concerning actions to be taken. Discuss thresholds for action and the possibility of new environmental monitoring programs.

7.04 Provide an assessment of environmental monitoring carried out at the La Grande complex, including an evaluation of the way in which the results of environmental monitoring have enhanced our understanding of the affected ecosystems. In addition, provide an assessment of the ways in which the data gathered have enabled timely and appropriate implementation of remedial or compensatory measures. Comments of the affected Native communities shall be incorporated into this evaluation.

7.05 Describe the mechanisms by which information concerning environmental protection would be circulated to the appropriate parties during the construction phases of the project. Indicate the nature of any information or data that would be distributed regarding surveillance, monitoring and long-term management.

7.06 Present a plan for monitoring social and cultural change within the Native communities affected by the project. This plan shall include a research framework that will integrate and relate (in a quantitative and qualitative way) the key human environment issues and project impacts identified in the EIS to the actual social and cultural changes occurring in the Native communities over the life of the project.

7.07 Monitoring of social and cultural changes during and after the construction of the la Grande was incomplete. Since monitoring in the present context cannot be based entirely on the La Grande experience, specify the protocols, financing and institutional frameworks necessary to coordinate the implementation of a monitoring plan. Indicate how collaboration between the various groups involved, in particular local and regional Native organizations, would be established. Indicate when the various surveillance and monitoring programs would be initiated, if and how these programs would be submitted to the concerned interveners and communities for approval, and whether or not a periodic and systematic review of these programs is planned.

7.08 The social impacts monitoring program presented in the EIS mainly concerns food and nutrition. Discuss the possibility of implementing, in conjunction with appropriate health authorities, an expanded program to monitor indicators of health in the Native communities, and the evolution of certain pathologies directly or indirectly linked with the proposed project.

7.09 Indicate measures that would be taken to control methylmercury exposure in children, pregnant women and breast-feeding infants, following the construction of the proposed project. Provide information on the long-term detection and monitoring programs that would be required, including epidemiological studies to examine the chronic effects on Native people of all age groups. Discuss collaborative efforts of responsible agencies and local organizations, such as the Cree Board of Health and Social Services of James Bay and the Kativik Regional Health and Social Services Council.

Surveillance and Monitoring

GUIDELINES paras. 705 to 711

SURVEILLANCE:

705. Environmental surveillance involves the general supervision of project construction to ensure that the conditions of authorization and all environmental laws, regulations and codes are respected.

706. The Proponent shall identify specific surveillance measures to be implemented, the environmental code to be applied, as well as the contractors' obligations arising from environment-related provisions in their contracts.

707. The Proponent shall describe the measures to be taken to ensure that on-site personnel are well-informed with respect to Native rights and traditional lifestyles.

708. A detailed description of the Proponent's operating manual shall be provided. The Proponent shall also describe in detail the process to be employed in the surveillance of activities involving the use of explosives, including the control measures designed to ensure this surveillance, the management procedures for hazardous products and waste and for fire surveillance, and the emergency intervention measures to be used during and after construction.

MONITORING:

709. Environmental monitoring refers to the study of conditions both during and after construction so as to determine whether or not environmental impacts are as anticipated. The objectives of the monitoring program are to seek a better understanding of the nature of impacts; to help improve methods of anticipating the impacts of future development projects; and to assess the effectiveness of the measures and the need for changes in operating procedures. The knowledge gathered by the Proponent shall be applied to improve mitigative or compensatory measures, operating procedures and the long-term management plan. The Proponent shall thus describe how all of the impacts predicted in response to Chapter 5 of these Guidelines, as well as any unanticipated impacts that might arise, will be monitored.

710. In addition, should the project be approved, the environmental monitoring program shall complete the gathering of the baseline data required to describe original environmental conditions and shall contribute to the study and management of cumulative impacts generated by major hydroelectric developments.

711. The proposed monitoring program shall reflect the experience gained through the La Grande projects and other comparable hydroelectric complexes and subsequent efforts to monitor their impacts. This proposal should include descriptions and, where appropriate, explanations of the changes made to the methodology used in the La Grande (1975) complex environmental monitoring program.

7.10 With regard to surveillance programs to be implemented, discuss the measures in the Environment Code that should be adapted to the proposed project.

7.11 Identify the measures which would be implemented in the event of an emergency (e.g., hydrocarbon or other chemical spills, the breach of a dam or a dike) during the construction and operation phases of the project.

7.12 Describe how it would be ensured that requirements of the Environment Codewith regard to pressure standards for underwater blasting would be respected.

7.13 Provide details of the surveillance, monitoring and long-term management programs which would be put in place concerning the project's access roads and airports.

7.14 In cases where samples necessary for monitoring could not be collected from the Native harvest, indicate alternative measures for collecting samples. More generally, indicate alternative means to monitor resource stock evolution if indicators from Native wildlife harvest data were no longer available.

7.15 Specify how sediment dispersal and accumulation would be monitored in Manitounuk Sound.

7.16 Considering the limits of photo-interpretation, provide more details concerning methods to be used to monitor physical changes in the two estuaries that would be subject to decreased river flow.

7.17 Present details of a program which would be put in place to monitor the use of the Little Whale River estuary by belugas during and following the project's construction. In addition to measuring the presence and abundance of the whales in the estuary, this program should monitor those environmental variables which are thought to affect beluga presence and abundance.

7.18 Provide details concerning the proposed monitoring program and specific studies to be carried out concerning suckers and lake trout in the reservoirs of the proposed project, and in particular in the Bienville Reservoir. In this connection, take into account the recent results obtained from the monitoring of the Caniapiscau Reservoir.

7.19 Justify the frequency of sampling proposed for long-term biophysical monitoring in the proposed project's reservoirs, affected rivers and estuaries, and in Manitounuk Sound. If necessary, redefine sampling strategies so as to make the proposed monitoring more representative.

7.20 Describe possible programs to monitor the freshwater seal population in the area which would be affected by the project.

7.21 Describe a possible program to monitor changes in temperature, salinity, circulation and ice conditions of the affected area in Hudson Bay.

7.22 Describe a possible program to monitor potential changes in the methylmercury content of fish, birds and mammals in southeastern Hudson Bay.

7.23 Describe possible programs to monitor long-term changes in the caribou population in the study area.