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Jordan River System Water Use Plan Order Review

Findings Report

FINAL

Order # 0281532

November 24, 2016

Evaluators:

ICF Consulting Canada

1090 Homer Street, Suite 300

Vancouver, BC V6B2W9

Triton Environmental

1308–1030 West Georgia Street

Vancouver, BC V6E 2Y3

i November 2016

Executive Summary 1

On July 20, 2004, the British Columbia Comptroller of Water Rights (Comptroller) issued the Jordan River 2 System Water Use Plan Order (Order) (Appendix A). The Order contains 13 Requirements, including a 3 physical works, operational constraints, monitoring studies to address fisheries and recreation 4 objectives, and annual reporting. After completing actions in response to the Requirements, BC Hydro 5 prepared reports synthesizing the results of the physical works project and monitoring studies. As part 6 of step 13 in the B.C. Government Water Use Planning process, BC Hydro retained ICF-Triton as an 7 independent third-party to conduct an Order Review, including reviewing implementation and 8 outcomes of the Order and projects and studies specified by the Order, identifying potential issues, and 9 preparing a Findings Report outlining the review findings. 10

The Order Review found that BC Hydro fully complied with seven of the Requirements (green rating) and 11 was non-compliant with five Requirements (amber rating); however, there were no adverse effects 12 reported as a result of the non-compliances. Two of the outcomes associated with two of the non-13 compliant ratings were negative. Based on these findings, a potential need for follow-up action has been 14 identified for Requirements 2 and 13. There is a potential need for follow-up for these two 15 Requirements because aspects of the overall objective of the actions mandating these Requirements 16 were not achieved. Findings are presented in the table below (see Section 3 of the Finding Report for 17 details on each finding). 18

This Findings Report presents the findings from the Jordan River System Water Use Plan Order Review 19 (Order Review). It describes both the extent of BC Hydro’s compliance with the Order Requirements 20 (Requirements) and the outcomes of those Requirements. 21

This Findings Report was prepared to provide an opportunity for regulators, First Nations, and 22 stakeholders to review the results of the Order Review and submit questions, suggestions or comments. 23 Input collected from these parties will inform the next steps in the Order Review process including the 24 development of conclusions, recommendations and further actions associated with any key issues 25 identified during the process. Analysis of issues and development of recommendations will occur 26 following the 60-day public review and comment period. Conclusions and recommendations will be 27 summarized and submitted to the Comptroller. 28


Findings Report — Draft 4.1

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Jordan River System Water Use Plan Order Review Results 1

# Requirement Rating Conclusion Potential

Issue1 Performance Outcome(s)

1 Design Plans - The licensee shall submit, to the Comptroller, design plans, prepared by a professional engineer registered in British Columbia, for the alteration of works to enable a flow release into Jordan River through Elliott Dam.

BC Hydro complied with Requirement 1.

The design plans were developed as specified for a flow release valve to provide a minimum flow rate of at least 0.25 m3/s through Elliott Dam into lower Jordan River (BC Hydro, 2008b).

2 Physical Works - The licensee shall alter the works in accordance with the approved plans after leave is given in writing by the Comptroller.

With the exception of operational issues with the valve, BC Hydro complied with Requirement 2. No adverse effects were identified or were expected on the broader intended outcome of a minimum flow of 0.25 m3/s. The operational issues that constituted the non-compliance resulted in a potential issue, as repairs to the control valve may be required.

The flow release valve, once installed, could not be operated as originally designed, as it was intended to be powered using onsite electrical sources, but emergency backup power was not reliable until a replacement backup generator was installed in 2010. To ensure minimum flow compliance in the event of a power failure including failure of emergency backup power at Elliott Dam, the valve was locked in the full open position until the backup power could be replaced. However, by the time the backup power was replaced the valve regulation controls had corroded and were not functional. This resulted in a release discharge averaging 0.35 m3/s (D. Burt and Associates, 2015). The higher volume of release discharge resulted in the intended instream flows needed to achieve the Water Use Plan rearing area and wetted stream length targets, providing benefits to target fish species and their habitat (JORMON-1 is the associated monitoring study to evaluate instream flows. Refer to Requirement 10 for details on monitoring results).



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3 Minimum Operating Levels - Between July 1 and September 30 of any year, the minimum operating elevation of Diversion Reservoir shall be 376.0 m, measured at the dam using the Geodetic Survey of Canada (GSC) datum. Between October 1 and June 30 of any year, the minimum operating elevation of Diversion Reservoir shall be 372.0 m, measured at the dam using GSC datum.

With the exception of one non-compliance, BC Hydro complied with Requirement 3. No apparent adverse effects were identified or were expected as a result of the non-compliance.

Reduced drawdown was implemented as specified with the exception of the one non-compliance noted. JORMON-4 is the associated monitoring study conducted to evaluate the effects of reduced drawdown on rainbow trout. Refer to Requirement 9 and 10 for details on monitoring results.

4 Minimum Operating Levels - The licensee shall leave the low-level outlet at Bear Creek Reservoir closed and shall obtain approval of the Comptroller in advance of any draft below 411.0 metres, the full supply level.


The low-level outlet at Bear Creek Reservoir was kept closed; as such, there was no monitoring of this requirement.



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5 Maximum Discharge Rate - The licensee shall ensure that, on a minimum of 4 weekend days during the month of March, the combined maximum discharge rate under licenses FL117999 and FL118000 shall be 30 cubic metres per second (m3/s) between the hours of 06:00 and 18:00. This maximum discharge rate may be exceeded in emergency situations and the Comptroller shall be notified at the earliest possible convenience in this event.


Constrained flows stipulated in this requirement were implemented. JORMON-5 is the associated monitoring study conducted to evaluate the effects on surfing quality, refer to Requirement 9 and 11 for more details on monitoring results.

6 Minimum Flows - The licensee shall release a minimum flow of 0.25 m3/s into Jordan River at the Elliott Dam outlet (PD31684), at all times, commencing within 2 years of the date of this order (hereinafter referred to as the "commencement date"), the works having been altered as per Requirements 1 and 2 above.


The minimum flow release requirement was met. JORMON-1, 2 and 3 are the associated monitoring studies conducted to evaluate the effects of in-stream flows in Jordan River below Elliott Dam and the effect of these flows on target fish species, or their habitat, refer to Requirement 9 and 10 for details on monitoring and results and Requirement 2 for more information on minimum flows and how they relate to physical works.



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7 Alternate Operations - The minimum release specified in Requirement 6 takes precedence over the minimum operating elevation specified in Requirement 3 in the event that both conditions cannot be met. The licensee shall notify the Comptroller when the reservoir elevation falls below that minimum elevation as a result of this precedence.


It was not necessary for BC Hydro to prioritize the minimum release flow over reservoir elevation levels.

8 Monitoring Plan - The licensee shall submit a monitoring plan for acceptance by the Comptroller within three months of the date of this order outlining details of the monitoring proposed, including what is to be measured, the frequency, location and how it is to be reported.

With the exception of the fisheries and surfing quality monitoring plan Terms of Reference not being submitted on time, BC Hydro complied with Requirement 8. No adverse effects were identified or were expected as a result of the delay in the submission of the Terms of Reference.

The Terms of Reference to conduct five monitoring studies were developed and approved by the Comptroller. Monitoring studies were developed with input from regulators, stakeholders and First Nations.



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9 Monitoring - The licensee shall implement monitoring in accordance with the plan as accepted under Requirement 8.

With the exception of a non-compliance because JORMON-4 was not fully implemented in accordance with the approved plan and the Comptroller was not notified, BC Hydro complied with Requirement 9. No adverse effects were identified or were expected as a result of this non-compliance.

Monitoring was implemented as specified in the Terms of Reference with the one exception noted. The last year of JORMON-4 monitoring was planned to include an extensive drawdown to look at the response in aquatic productivity, but this treatment drawdown did not occur for operational reasons.

An additional identified outcome is that for the surf quality monitoring (JORMON-5) a variety of factors (low flows, absence of surfers, marginal wave height and poor weather conditions) limited the monitors ability to gather data on surfing quality under unconstrained flow conditions during odd years, as a result monitoring of unconstrained flow conditions was conducted on several days during even years.



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10 Reporting - The licensee shall provide annual reports to the Comptroller beginning 1 year after the commencement of the monitoring as per the plan accepted in Requirement 8, including the following information: a) Size and abundance of rainbow trout in Lower Jordan River below Elliott Dam. b) Salmonid spawner surveys in Lower Jordan River. c) Fish stress indicators in Diversion Reservoir in comparison to the inventory measured during the preparation of the Jordan River Water Use Plan.


The monitoring conducted by BC Hydro found the following in relation to installation and operations of the hollow cone release valve to release minimum flows (Requirement 1, 2, and 6) and limiting reservoir drawdown as stipulated in Requirement 3:

JORMON-1 found that the flows used in the Water Use Plan overestimated August inflows and underestimated loses to groundwater by approximately 0.1 m3/s. If minimum flows of 0.25 m3/s had been released, this would have resulted in in-stream flows lower than planned (if the assumptions regarding base flows had been correct). However, due to the need to leave the control valve in the open position, releases averaged 0.35 m3/s, which ultimately resulted in the target instream flows expected as a result of the minimum flow releases originally planned (0.25 m3/s) (D.Burt and Associates 2015).

Following the implementation of the flow releases, JORMON-2 found that the density of 1+ and 2+ rainbow trout2 increased, juvenile trout and Coho fry repopulated the copper impacted zone and habitat continuity was improved in the system. Although changes to the condition factor of rainbow trout relative to baseline observations were not observed following flow releases, their condition factor was similar to fish outside the impacted zone (D.Burt and Associates 2015).



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10

JORMON-3 spawner surveys observed low counts of adult salmon and steelhead in the Lower Jordan River during the study years, however there was an increase in number of Coho present during 2014 surveys. Flow release did not increase quantity of available spawning habitat, but did dilute pollutants enough in some reaches to facilitate rearing (based on fish presence) where it was previously too contaminated (D. Burt and Associates 2015).

JORMON-4 found that there was no significant increase in rainbow trout condition factor within the Diversion Reservoir due to reduced allowable drawdown; however, abundance did increase significantly. It was also found that the fish habitable zone (appropriate levels of dissolved oxygen and temperature) of the reservoir could be negatively impacted by extensive drawdown (D. Burt and Associates 2015).

11 Surfing Reporting - The licensee shall provide annual reports to the Comptroller, beginning 1 year from the effective date of this Order, documenting pertinent information regarding surfing conditions during the days outlined in Requirement 5.


JORMON-5 found that constraints on generation stipulated in Requirement 5 have potential benefit to surfing. However, other factors such as environmental conditions (weather, tides, wind, etc.) greatly limited the ability to predict when flow constraints would successfully improve surf conditions. If all other factors are consistent, constrained flows provide more favourable surf conditions (D. Burt and Associates 2015).

12 Alternate Operations - The licensee shall operate the works in an alternate manner in the event of an emergency, a dam safety requirement, or an extreme hydrological event.

N/A3

Requirement 12 is not measurable.

BC Hydro operated the works in an alternate manner on one occasion when the Diversion Reservoir was drafted below the minimum elevation of 372.0 m for 3 hours in order to prepare for a substantial storm event and forecasted inflows (BC Hydro, 2006).



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13 Deviations from the Order - The emergency operations or other deviations from this order shall be reported to the Comptroller in a timely manner.

With the exception of one deviation not being reported in a timely manner (Comptroller of Water Rights, 2006), BC Hydro complied with Requirement 13. No adverse effects were reported or expected regarding the delay in the reporting of the deviation.

BC Hydro reported emergency operations or other deviations on three occasions. On one occasion, reporting of a deviation, which occurred in January 2005, was not completed until the March 2006 annual report. This was the first year of operation under the WUP Order and reporting expectations were still being defined. Following this delay in reporting BC Hydro have implemented procedures to address reporting requirements and responsibilities which has resulted in no further reporting deviations occurring.

1 A check mark indicates where there is a potential issue. 2 1+ and 2+ refers to fish that are at least one year old and at least two years old, respectively. 3 The performance rating is not applicable because this requirement is not measureable. It provides for operational flexibility, but does not stipulate specific actions on the part

of BC Hydro. Performance Rating System

Non-compliant with adverse effect (occurs when there is an identified or reasonable expectation of adverse effect on social or environmental resources based on documents reviewed and information accessed for the assessment).

Non-compliant with no adverse effect (occurs when there is no identified or reasonable expectation of adverse effect on social or environmental resources based on documents reviewed and information accessed for the assessment).

Compliant.

Potential Issue?

No, no potential issue identified Yes, there is a potential issue identified

1

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xi November 2016

Table of Contents 1

1 Background and Introduction .......................................................................................................1 2

1.1 Water Use Planning Process Overview ............................................................................................ 1 3

1.2 Order Review Process ...................................................................................................................... 2 4

2 Introduction to the Jordan River System .......................................................................................9 5

2.1 Jordan River System Information ..................................................................................................... 9 6

2.2 Jordan River System Water Use Plan ............................................................................................. 10 7

2.3 Jordan River Order ......................................................................................................................... 10 8

3 Findings ..................................................................................................................................... 15 9

Requirement 1 ...................................................................................................................................... 15 10

Requirement 2 ...................................................................................................................................... 16 11

requirement 3 ....................................................................................................................................... 18 12

Requirement 4 ...................................................................................................................................... 20 13

Requirement 5 ...................................................................................................................................... 20 14

Requirement 6 ...................................................................................................................................... 21 15

Requirement 7 ...................................................................................................................................... 22 16

Requirement 8 ...................................................................................................................................... 24 17

Requirement 9 ...................................................................................................................................... 25 18

Requirement 10 .................................................................................................................................... 29 19

Requirement 11 .................................................................................................................................... 35 20

Requirement 12 .................................................................................................................................... 38 21

Requirement 13 .................................................................................................................................... 39 22

4 Financial Metrics ........................................................................................................................ 41 23

5 Summary and Analysis of Results ............................................................................................... 43 24

6 References ................................................................................................................................. 55 25

Appendix A: Original Water Use Plan Order 26

Appendix B: Crosswalk of Jordan River System Water Use Plan Objectives and Recommendations, and 27 Order Requirements 28

Appendix C: Program Evaluation Approach Used for the BC Hydro Water Use Plan Order Reviews 29

Appendix D: Water Use Plan Order Review Process – Finding Development 30

Appendix E: Table of Jordan Monitoring Studies and Associated Management Questions 31

Appendix F: Synthesis Report 32

Appendix G: Jordan Water Use Plan Order Implementation Timeline 33

34



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List of Tables 1 Page 2

1 Performance Rating System ............................................................................................................. 4 3

2 Jordan River System Water Use Plan Requirements ..................................................................... 12 4

3 Study Outcomes Relative to Each Management Question for JORMON-1 through JORMON-4 .. 31 5

4 Study Outcomes Relative to Each Management Question for JORMON-5 ................................... 37 6

5 Jordan River System Physical Works and Monitoring Program Financial Metrics ........................ 41 7

6 Jordan River Order Review Results ................................................................................................ 44 8

9 List of Figures 10

Page 11 1 Water Use Planning Process: Overview2 ......................................................................................... 2 12

2 Issue Analysis and Development of Recommendations .................................................................. 5 13

3 Jordan River System Location .......................................................................................................... 9 14

4 Jordan River System Area ................................................................................................................ 9 15



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Key Terms and Definitions 1

B.C. British Columbia

Comptroller British Columbia Comptroller of Water Rights

Guidelines Water Use Plan Guidelines

Jordan River System Jordan River hydroelectric facility. Part of the Bridge River/Coastal Generation Area and includes the Jordan Generating Station, Elliott Dam and Headpond, Jordan Diversion Dam, Diversion Reservoir, Bear Creek Dam, and Bear Creek Reservoir

JORMON-1 Lower Jordan River Inflow Monitoring

JORMON-2 Fish Index, Lower Jordan River

JORMON-3 Lower Jordan River Salmon Spawning Assessment and Enumeration

JORMON-4 Diversion Reservoir Fish Indexing

JORMON-5 Monitoring Surfing Quality below the Jordan River Generating Station

JORWORKS-1 Water Release Mechanism at Elliott Dam (Physical Works)

Km Kilometres

m Metres

m3/s Cubic metres per second

Order Jordan River System Water Use Plan Order

Order Review Water Use Plan Order Review

Order Review Program Water Use Plan Order Evaluation Program

Requirement Water Use Plan Order Requirement

2

1 November 2016

1 Background and Introduction 1

On July 20, 2004, the British Columbia Comptroller of Water Rights (Comptroller) issued the Jordan River 2 System Water Use Plan Order (Order) (Appendix A). The Order was the culmination of the Jordan River 3 System Water Use Planning process initiated in 1999. The Order contains 13 Order Requirements 4 (Requirements) including operating criteria, a physical works project, and monitoring studies to address 5 fishery and recreation objectives that BC Hydro was required to undertake over an 8-year period, and 6 annual reporting. After completing actions in response to the Requirements and the physical works 7 project, BC Hydro prepared reports synthesizing results of the monitoring studies and physical works. As 8 part of step 13 of the Water Use Plan Guidelines (Guidelines)1 (Province of British Columbia, 1998) 9 (Figure 1), BC Hydro retained an independent third-party to evaluate the projects and studies 10 undertaken to comply with the Order. 11

This Findings Report presents the findings from the Jordan River System Water Use Plan Order Review 12 (Order Review). It describes both the extent of BC Hydro’s compliance with the Requirements and the 13 outcomes of those Requirements. 14

This Findings Report has been prepared to provide an opportunity for regulators, First Nations, and 15 stakeholders to review results of the Order Review and submit questions, suggestions, or comments. 16 Input collected will inform the next steps in the Order Review process, including the development of 17 conclusions, recommendations, and further actions associated with any key issues identified during the 18 process. Questions outside the scope of the Order Review will be referred to the appropriate BC Hydro 19 program or contact. 20

The report is organized as follows: 21

Section 1 provides general information on the Order Review process and the purpose of this Findings 22 Report. 23

Section 2 presents information specifically relating to the Jordan River System, Requirements, and the 24 monitoring studies and the physical works undertaken. The information in this section forms the basis of 25 the Order Review. 26

Section 3 presents the findings relative to each Requirement. 27

Section 4 presents the financial metrics relative to implementation of the Order Requirements. 28

Section 5 summarizes the findings. 29

1.1 Water Use Planning Process Overview 30

In 1998, the British Columbia government issued the Water Use Planning Guidelines, which describe a 31 consultative process whereby the operations of an existing, licensed water control facility are reviewed 32 and revised, as appropriate, in order to achieve a balance in water use objectives for the system (See 33 Appendix B for a crosswalk between the water use objectives and Requirements). From 1999 to 2004, a 34 total of 23 Water Use Plans were developed for 31 of BC Hydro’s hydroelectric facilities, using the Water 35 Use Planning process depicted in Figure 1. Steps 2 to 9 included extensive consultation with regulatory 36 agencies, stakeholders, and First Nations, with a view to balancing the interests of power generation 37

1 http://www.env.gov.bc.ca/wsd/plan_protect_sustain/water_use_planning/cabinet/wup.pdf



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with a range of social and environmental values. Issues related to, or resulting from, the original 1 construction of BC Hydro generation facilities were excluded from the Water Use Plan scope.2,3 Once 2 accepted by the Comptroller, operational changes, monitoring studies, and physical works outlined in 3 the Water Use Plans are being implemented by BC Hydro through Orders from the Comptroller under 4 the Water Act. 5

BC Hydro is now at step 13 of the Guidelines process, which 6 recommends scheduling reviews oriented to specific priority 7 issues that may arise during the implementation of each Water 8 Use Plan. To respond to step 13, BC Hydro is undertaking a Water 9 Use Plan Order Review Program (Order Review Program) to 10 review implementation of the 23 Orders. The reviews will 11 evaluate Order outcomes against desired results and financial 12 commitments to determine the extent of BC Hydro’s compliance 13 with the Orders. Any changes that have occurred as a result of 14 formal instructions from the Comptroller will be identified and 15 considered in the reviews. 16

To facilitate completion of step 13, BC Hydro is working with ICF-17 Triton to provide an independent, consistent, replicable, and 18 scalable process for each Order Review and to prepare objective 19 Findings Reports that support a transparent review and comment 20 process with regulatory agencies, First Nations, BC Hydro 21 employees, and stakeholders. 22

Based on the outcome of each Order Review, the Comptroller will 23 confirm, revise, replace, or rescind the Orders, as appropriate. 24 Further information on the program evaluation approach being 25 used for the Order Review Program is provided in Appendix C. 26

1.2 Order Review Process 27

The process used to review implementation of the 23 Orders (the 28 Order Review process) was developed based on extensive 29 discussions between BC Hydro, regulators, and ICF-Triton aimed 30 at developing a process that is independent, consistent, 31 replicable, and scalable (i.e., able to address the differing number 32 and nature of priority issues associated with each Order). The 33 process was also designed to ensure consistency across reviews 34 while still allowing for refinements as required, based on lessons 35 learned, as individual Order Reviews are completed. The Jordan Order Review was one of the first 36 projects to be piloted under this process. This pilot review will inform the areas for improvement or 37 change needed in the process for future reviews. 38

2 For figure and more information on the Water Use Planning process see:

http://www.bchydro.com/about/sustainability/conservation/water_use_planning.html. 3 For another perspective on the BC Hydro Water Use Plan program see WWF-Canada report:

http://awsassets.wwf.ca/downloads/wup_report_r04.pdf

Figure 1. Water Use Planning Process: Overview2



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The Order Review process consists of two main parts: 1

1. Finding Development (this report). 2

2. Issues Analysis and Recommendation Development (next steps). 3

Figure 2 outlines the steps in each part of the Order Review process. More detailed information on the 4 Finding Development steps is provided in Appendix D. 5

1.2.1 Part 1 – Finding Development 6

Part 1 – Finding Development focusses on collecting information and applying performance measures to 7 develop findings using the following steps: 8

1. Kickoff Meeting to Identify Priority Issues – The objective of this meeting is to identify priority 9 issues, refine the scope of the Order Review, and verify the regulators, First Nations, and other 10 parties who will be involved in the Order Review. 11

2. Confirm Requirements – Based on relevant documentation, develop a comprehensive inventory of 12 Requirements (operational constraints, physical works, monitoring studies, and reporting), 13 variances4 and associated management questions to establish the basis for the Order Review. 14 Identify and confirm Requirements that are not measurable, e.g., a requirement that allows BC 15 Hydro to operate works in an alternate matter in the event of an emergency or a dam safety 16 incident. 17

3. Identify Performance Measures – Identify performance measure(s) to be applied to each 18 Requirement (Appendix D, Table D1) to support the evaluation of performance relative to the 19 Requirements. 20

4. Collect Data on Performance Measures – Performance relative to each Requirement is determined 21 by an evaluator with applicable subject matter expertise as described below. 22

a. Findings relative to each performance measure are developed by comparing the evidence 23 contained in the documentation compiled during step 2 (see Appendix D for a list of the types of 24 documents compiled) against each performance measure. Findings are then reviewed together 25 to determine a performance rating (Table 1) and determine BC Hydro’s compliance with each 26 Requirement. 27

b. Outcomes (positive, neutral, or negative; intended or unintended) resulting from the Order 28 Requirements are also reviewed and documented. Intended outcomes need to be consistent 29 with the Water Use Plan objectives. These outcomes are determined based on review of actual 30 data or anecdotal observations based on documents reviewed and information accessed for the 31 Order Review (e.g., synthesis or monitoring reports). 32

c. Potential Issue as a result of BC Hydro’s compliance is also assessed: 33

• A Potential Issue occurs if an identified or reasonable expectation of adverse effect on social 34 or environmental resources occurs, regardless of whether BC Hydro is compliant or not. 35

4 A variance is temporary or permanent modification to an Order Requirement (e.g., changes to timelines or changes

in ramping rates) or associated Terms of Reference requested by BC Hydro and granted by the Comptroller.



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• A Potential Issue occurs if an objective of a mandated action defined by a Requirement 1 under the Order and approved by the Comptroller was not achieved. 2

Table 1. Performance Rating System 3

Non-compliant with adverse effect (occurs when there is an identified or reasonable expectation of adverse effect5 on social or environmental resources based on documents reviewed and information accessed for the assessment).


Compliant.

4

Potential Issue?


Performance rating for each Requirement is determined as follows: 5

Compliant 6

• BC Hydro is deemed to be compliant with its Water Use Plan Order if all actions mandated 7 within a Requirement have been completed. This includes any actions that were to be defined 8 by a Requirement under the Order and approved by the Comptroller. For example, where the 9 Order required a monitoring study be designed and conducted, the study was designed by BC 10 Hydro, and then approved by the Comptroller. BC Hydro subsequently completed the study as 11 approved. 12

• If the actions mandated within a Requirement were completed but did not achieve the expected 13 outcome, BC Hydro is compliant with the Requirement. For example, if monitoring studies 14 designed to answer management questions were completed as designed and approved but did 15 not answer or fully answer all management questions, BC Hydro is considered to be compliant 16 with the related Requirement. 17

• If deviations from the Order occurred under a variance, BC Hydro is compliant with the 18 Requirement. Only a deviation from the Order without an approved variance is considered a 19 non-compliance. 20

• BC Hydro is deemed to be non-compliant if it failed to complete all actions mandated within a 21 Requirement. For example, if one of a series of mandated actions either in the text of the Order 22 or subsequently agreed to as part of a monitoring study was not completed. 23

• If an identified or reasonable expectation of adverse effect on social or environmental resources 24 occurs based on documents reviewed and information accessed for the Order Review and if all 25 actions mandated within a Requirement were completed, BC Hydro is deemed to be compliant. 26 However, the adverse effect would be noted as a “negative outcome” and the need to identify 27 potential follow-up actions identified. 28

5 An adverse effect is an undesirable effect to social or environmental resources



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Figure 2. Issue Analysis and Development of Recommendations 1

2



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Non-compliant with no adverse effect 1

• Non-compliant with no adverse effect occurs when there is no identified or reasonable 2 expectation of adverse effect on social or environmental resources based on documents 3 reviewed and information accessed for the assessment. 4

Non-compliant with adverse effect 5 • Non-compliant with adverse effect occurs when there is an identified or reasonable expectation 6

of adverse effect on social or environmental resources based on documents reviewed and 7 information accessed for the assessment. 8

5. Gap Analysis Informed by Performance Measures – A Gap Analysis is a tool that provides BC Hydro 9 and regulators with a high-level overview of initial findings based on information provided to 10 ICF-Triton, and identifies missing information. The Gap Analysis forms part of the basis for the 11 Findings Report. Feedback from BC Hydro and the Comptroller is addressed to ensure that there is 12 general agreement on the scope of the findings, verify information, and collect additional 13 information, as needed before the Findings Report is prepared. 14

6. Findings Report – Findings Development culminates in the preparation of the Findings Report which 15 documents activities undertaken by, or on behalf of, BC Hydro to comply with the Order and 16 discusses BC Hydro’s compliance with the Requirements. 17

The purpose of the Findings Report is to respond to step 13 of the Guidelines and provide a 18 complete, factual record of BC Hydro’s compliance with the Orders. Specifically, it is designed to: 19

• Summarize BC Hydro’s compliance with the Orders. 20 • Identify areas where it was not possible to fully comply, reasons why, and the associated effect. 21 • Identify the outcome of BC Hydro’s compliance with the Orders. 22 • Identify actions, if any, still needed to fully satisfy the Requirements. 23 • Assess financial performance relative to original commitments made by BC Hydro. 24

The Findings Report also describes whether the monitoring program undertaken developed during 25 implementation of the Orders successfully answered the management questions, and highlights what 26 was learned. Because the Findings Report focuses on factual information, it does not identify new issues 27 or alternatives, or make recommendations for next steps. Analysis of issues and development of 28 recommendations will occur following the 60-day public review and comment period. 29

The scope of this Findings Report is limited to BC Hydro actions conducted in response to the Order from 30 the date of the Order through December 2014, the final year of conveyance reports included in this 31 Order Review. Findings are based solely on data and documentation produced by, or on behalf of, BC 32 Hydro to comply with the Order, notes from interviews with BC Hydro staff, and feedback from the 33 Comptroller. Independent data collection or observation to verify monitoring study findings was not 34 performed. Similarly, statements regarding the benefit of operating constraints on target resources are 35 based on monitoring documentation, interviews with BC Hydro technical staff, and professional 36 judgement, and are solely intended as comparisons of reported versus expected outcomes. 37

As stated earlier, more detailed information on the Finding Development steps is provided in Appendix 38 D. 39



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1.2.2 Part 2 – Issue Analysis and Recommendation Development 1

Part 2 – Issue Analysis and Recommendation Development focusses on identifying ongoing and new 2 issues based on the outcomes of Order implementation, and will culminate in the development of 3 recommendations for consideration by the Comptroller. 4

Issues outside the scope of the Order that are identified during the Order Review process will be noted 5 and referred to the appropriate BC Hydro program to be addressed. 6

Regulator and First Nations Review and Verification 7

The draft Findings Report was provided to regulators and First Nations once BC Hydro’s review and 8 verification was complete. This step allowed for a 4-week review period and invited written comments 9 on the draft report. In addition, a workshop with regulators and interested First Nations was held to 10 review findings and supporting evidence and begin identifying issues that will need to be evaluated as 11 part of Issue Analysis and Recommendation Development. Following the workshop, Order Review- 12 related comments and new information was incorporated into the report, and prepared for publication. 13

60-day Public Review Period 14

The Findings Report will be made available to First Nations, regional and municipal governments, 15 stakeholders, and other interested parties for a 60-day review and comment period. Additional 16 engagement may be undertaken depending on the report findings and comments received. 17

Analysis of Issues and Recommendations 18

Input gathered during the public review period will be considered by the Comptroller and BC Hydro, 19 along with technical and financial information, to inform any additional action that may be needed. 20 Issues raised will be evaluated to determine if additional engagement is needed. 21

Once the issues received have been analyzed, recommendations will be developed and summarized. 22 The recommendations summary will be submitted to the Comptroller for review and decision with 23 regard to the Order, the Comptroller will either confirm, revise, replace, or rescind the Jordan River 24 Order in response.25

9 November 2016

2 Introduction to the Jordan River System 1

This section presents information specific to the Jordan River System. Section 2.1 provides site-specific 2 background information about the Jordan River System. Section 2.2 outlines the Jordan River System 3 Water Use Planning process. Section 2.3 describes the Jordan River System Order. 4

2.1 Jordan River System Information 5

The Jordan River is located within the Capital Region District, 6 along the southwest coast of Vancouver Island, 7 approximately 72 kilometres (km) west of Victoria, British 8 Columbia. The Jordan River, which is 35 km long, flows 9 southwesterly, between the Sooke Hills and the Seymour 10 Mountain range into Juan De Fuca Strait. 11

The Jordan River System is part of BC Hydro’s Bridge 12 River/Coastal Generation Area, and it is the only major 13 hydroelectric development on the southwest side of 14 Vancouver Island. The Jordan River can contribute up to 35 15 percent of the island’s total hydroelectric generation. Figure 3 16 shows the Jordan River System location, and Figure 4 shows 17 the Jordan River System area. 18

Figure 4. Jordan River System Area 19

20

Figure 3. Jordan River System Location



10 November 2016

2.2 Jordan River System Water Use Plan 1

The Water Use Plan consultative process for the BC Hydro’s Jordan River System was initiated in April 2 2000 and concluded with the development of the Jordan River System Water Use Plan (accepted by the 3 Comptroller and published in April 2003). Key interests identified included power, fish, water quality, 4 recreation, cultural use and heritage resources, socioeconomics, and wildlife. The scope and objectives 5 of the Water Use Plan are described in more detail in the sections that follow. 6

The Jordan River System Water Use Plan process was intended to clarify BC Hydro’s operating 7 parameters, in consideration of objectives related to fish, wildlife, and recreation interests on the Jordan 8 River System. The scope of the Water Use Plan was limited to those issues that could be addressed by 9 changing the way the facilities are operated. A number of issues outside the scope of the Jordan Water 10 Use Plan were raised by Consultative Committee members and observers, and these were detailed in 11 the 2002 Jordan River Consultative Committee Report (BC Hydro 2002).6 12

As per Step 4 of the Water Use Plan Guidelines, the Consultative Committee stated specific objectives 13 for the desired outcomes in dealing with water use issues. In defining the objectives, the Consultative 14 Committee articulated what they sought to achieve through incremental changes in BC Hydro 15 operations (e.g., maximize fish production). The Jordan River System Water Use Plan (BC Hydro 2003) 16 reflects the consensus recommendations of the Consultative Committee for addressing the objective. 17

2.3 Jordan River Order 18

The Order (Order #0281532; Appendix A) was issued by the Comptroller on July 20, 2004, and included 19 13 Requirements. Table 2 provides an overview of the Requirements, the target resource intended to 20 benefit from each Requirement, and the page number of the finding discussion. See Appendix B for a 21 Crosswalk of Water Use Plan objectives and recommendations versus the Requirements. 22

In response to the Order, Terms of Reference were developed to define the scope of the physical works 23 and monitoring studies to comply with the Order. Requirements 1 and 2 specify the requirements for 24 design and construction of one physical work project as described below. 25

• JORWORKS-1 – Water Release Mechanism at Elliott Dam (Physical Works): plan, design, and 26 install a water release valve in Elliott Dam to enable a minimum flow release of 0.25 cubic 27 metres per second (m3/s) into the Lower Jordan River. It was expected that the increased base 28 flow would result in improved ecosystem conditions and an increase in habitat for fish from the 29 mouth of the river up to and including 300 metres (m) below Elliott Dam (see JORMON-2 30 and -3). 31

Requirement 8 included five monitoring programs: four related to fisheries and one related to 32 recreation opportunities: 33

6 For additional information, see the BC Hydro Jordan River Water Use Planning web page:

http://www.bchydro.com/about/sustainability/conservation/water_use_planning/vancouver_island/jordan_river.html



11 November 2016

Fisheries 1

• JORMON-1 – Lower Jordan River Inflow Monitoring: assess the performance of modelled flows 2 used in the minimum flow decision relative to measured flows in the Jordan River below Elliott 3 Dam. 4

• JORMON-2 – Fish Index, Lower Jordan River: assess the performance of the minimum flow 5 decision using fish abundance and fish condition as performance measures. 6

• JORMON-3 – Lower Jordan River Salmon Spawning Assessment and Enumeration: assess 7 spawning success of salmon in the anadromous reach of the Lower Jordan River. 8

• JORMON-4 – Diversion Reservoir Fish Indexing: assess the impacts of extensive drawdowns on 9 Diversion Reservoir rainbow trout condition factors, and water quality. 10

Recreation 11 • JORMON-5 – Monitoring Surfing Quality Below the Jordan River Generating Station: assess the 12

performance of operation constraints on surf quality. 13

The Terms of Reference describes the scope of work that is needed to be undertaken to fulfil the 14 Requirements and answer the management questions that the monitoring studies were designed to 15 address. 16

Additional information on the monitoring studies and their associated management questions is 17 provided in Appendix E. Upon completion of the monitoring studies, a synthesis report was prepared to 18 summarize the results from the monitoring programs and outline whether anticipated benefits are being 19 realized under the current operating constraints (Appendix F). 20



12 November 2016

Table 2. Jordan River System Water Use Plan Requirements 1

Requirement

Type of Action Target Resource

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1 – The licensee shall submit, to the Comptroller, design plans, prepared by a professional engineer registered in British Columbia, for the alteration of works to enable a flow release into Jordan River through Elliott Dam.

15

2 – The licensee shall alter the works in accordance with the approved plans after leave is given in writing by the Comptroller.

16

3 – Between July 1 and September 30 of any year, the minimum operating elevation of Diversion Reservoir shall be 376.0 metres, measured at the dam using the Geodetic Survey of Canada (GSC) datum. Between October 1 and June 30 of any year, the minimum operating elevation of Diversion Reservoir shall be 372.0 metres, measured at the dam using GSC datum.

18

4 – The licensee shall leave the low-level outlet at Bear Creek Reservoir closed and shall obtain approval of the Comptroller in advance of any draft below 411.0 metres, the full supply level.

20

5 – The licensee shall ensure that, on a minimum of 4 weekend days during the month of March, the combined maximum discharge rate under licenses FL117999 and FL118000 shall be 30 cubic metres per second (m3/s) between the hours of 06:00 and 18:00. This maximum discharge rate may be exceeded in emergency situations and the Comptroller shall be notified at the earliest possible convenience in this event.

20



13 November 2016

Requirement


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6 – The licensee shall release a minimum flow of 0.25 m3/s into Jordan River at the Elliott Dam outlet (PD31684) at all times, commencing within 2 years of the date of this Order (hereinafter referred to as the "commencement date"), the works having been altered as per conditions [Order Requirement] 1 and 2 above.

21

7 – The minimum release specified in Order Requirement 6 takes precedence over the minimum operating elevation specified in Order Requirement 3, in the event that both conditions cannot be met. The licensee shall notify the Comptroller when the reservoir elevation falls below that minimum elevation as a result of this precedence.

22

8 – The licensee shall submit a monitoring plan for acceptance by the Comptroller within 3 months of the date of this Order outlining details of the monitoring proposed, including what is to be measured, the frequency, location and how it is to be reported.

24

9 – The licensee shall implement monitoring in accordance with the plan as accepted under Requirement 8.

25

10 – The licensee shall provide annual reports to the Comptroller beginning 1 year after the commencement of the monitoring, as per the plan accepted in Requirement 8, including the following information:

a) Size and abundance of rainbow trout in Lower Jordan River below Elliott dam,

b) Salmonid spawner surveys in Lower Jordan River, c) Fish stress indicators in Diversion Reservoir in comparison to the inventory

measured during the preparation of the Jordan River Water Use Plan.

29



14 November 2016

Requirement


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11 – The licensee shall provide annual reports to the Comptroller beginning 1 year from the effective date of this Order documenting pertinent information regarding surfing conditions during the days outlined in Requirement 5 above.

35

12 – The licensee shall operate the works in an alternate manner in the event of an emergency, a dam safety requirement, or an extreme hydrological event.

38

13 – The emergency operations or other deviations from this Order shall be reported to the Comptroller in a timely manner.

39

1

15 November 2016

3 Findings 1

This section presents the findings of the Order Review with the information presented as follows: 2

• Requirement and the overall performance rating for that Requirement. 3 • Findings for each performance measure and evidence to substantiate each finding. 4 • Discussion where appropriate. 5 • Conclusion regarding BC Hydro’s performance relative to each Requirement. 6

A timeline of key milestones and completion of time-dependent tasks pertinent to the discussion of 7 findings is included in Appendix G, and the synthesis report prepared by D.W. Burt and Associates 8 (2015), which contains a review and technical evaluation of the Jordan River Order physical works and 9 monitoring studies, is provided in Appendix F. The Water Use Plan objectives and Consultative 10 Committee recommendations that provided the basis for the Order Requirements are provided in 11 Appendix B. 12

REQUIREMENT 1 RATING POTENTIAL

ISSUE? The licensee shall submit, to the Comptroller, design plans, prepared by a professional engineer registered in British Columbia, for the alteration of works to enable a flow release into Jordan River through Elliott Dam.

PERFORMANCE MEASURES 13

FINDINGS 14

PERFORMANCE MEASURE 1.1 FINDING

Were design plan(s) developed and submitted in accordance with requirements?

The designs plans were developed and submitted in accordance with the requirements. The designs were approved by the Comptroller on September 18, 2006, consistent with the Order and the approved revised delivery schedule.

BC Hydro was required to develop design plans, prepared by a professional engineer registered 15 in B.C., for the installation of a flow release valve to enable a fish flow release into lower Jordan 16 River through Elliott Dam, and submit them to the Comptroller. The release mechanism was 17 required to provide a minimum flow rate of at least 0.25 m3/s. Although the Order did not 18 specify a deadline for the completion of design plans, release of minimum flows was ordered to 19 commence July 20, 2006, 2 years after the Order was issued (see Appendix A). Therefore, design 20 plans needed to be completed and approved by the Comptroller to allow sufficient time for the 21 release mechanism to be constructed, and minimum flow releases to be commenced within 2 22 years. As shown in Appendix G, the schedule was extended and a revised delivery schedule was 23 submitted, approved and achieved. 24



16 November 2016

DISCUSSION 1

BC Hydro met the performance measure associated with this Requirement. Based on the design 2 plans that were developed, implementation of this Requirement contributed to the Water Use 3 Plan objective to maximize resident fish populations, invertebrates, and aquatic life in the 4 reservoirs. No potential issue was identified. 5

CONCLUSION 6

Performance 7

BC Hydro complied with Requirement 1. 8

Identified Outcomes 9

The design plans were developed as specified for a flow release valve to provide a minimum 10 flow rate of at least 0.25 m3/s through Elliott Dam into lower Jordan River (BC Hydro, 2008b). 11


ISSUE? The licensee shall alter the works in accordance with the approved plans after leave is given in writing by the Comptroller.


FINDINGS 13


Were the works constructed/implemented as required/on schedule/as designed?

The flow release valve, once installed, could not be operated as originally designed, due to reliability concerns with backup power at the site.

JORWORK-1 was completed in two phases. Phase I included inserting a pipe through the 14 upstream end of the dam and was completed in 2004, prior to receipt of the Order. It is 15 therefore not evaluated further. Once plans were approved, construction proceeded on Phase II 16 of the works project according to the adjusted schedule. Phase II involved inserting the 17 downstream end of the pipe through the dam and joining it to the pipe inserted during Phase I 18 construction (BC Hydro, 2008) (see Appendix G for approved timelines). 19

Construction necessary to commence release of minimum flows (including installation of fish 20 release pipe, pneumatic gate valve [flow release valve], and gauging instrumentation) was 21 completed, and minimum flow releases commenced in advance of the January 30, 2008, 22 deadline included in the revised schedule (BC Hydro, 2008). However, the flow release valve, 23 once installed, could not be operated as originally designed, due to reliability concerns with 24 backup power at the site. The flow valve was designed with automated controls to allow BC 25 Hydro to maintain flows as close to the minimum flow of 0.25 m3/s as possible depending on 26 headpond elevation (D. Burt and Associates, 2015). Flow regulation through the valve was 27 intended to be powered using on-site electrical sources, but reliable emergency backup power 28



17 November 2016

was not installed until 2010. To ensure minimum flow compliance in the event of a power failure 1 at Elliott Dam, the valve was locked in the full open position until the backup power was 2 replaced. This resulted in a release discharge averaging 0.35 m3/s (D. Burt and Associates, 2015); 3 minimum flows were maintained above the 0.25 m3/s threshold stipulated in the Order. By the 4 time backup power was replaced in 2010, the valve regulation controls had corroded and were 5 not functional (D. Burt and Associates, 2015). 6

All systems and components of the flow release mechanism were designed to minimize 7 maintenance requirements (BC Hydro, 2008). However, the need to leave the valve locked open 8 and the corrosion that occurred indicates potential deficiencies in the design or implementation 9 of JORWORKS-1. Specifically: 10

• The lack of reliable backup power did not allow variable operation that adjusted to changing 11 headpond elevations. The design called for variable operation of the valve to maintain flows 12 at 0.25 m3/s (BC Hydro, 2008). This was not achieved. 13

• Controls required a constant and reliable power supply for BC Hydro to allow automatic 14 operation. Lack of regular operation may have contributed to control corrosion (D. Burt and 15 Associates, 2015). 16

• The recommended maintenance schedule may not have had enough maintenance checks to 17 allow for the corrosion of the controls to be discovered. 18


Were required report(s) and notification(s) completed as required?

Annual monitoring reports were completed from 2006 to 2012 as required, and notifications were provided to the Comptroller. However, none of the reporting indicated the flow release valve could not be operated as designed.

BC Hydro included progress updates on JORWORKS-1 in the annual monitoring and physical 19 works reports (annual reports) prepared and submitted to the Comptroller from 2006 to 2012. 20 Once construction concluded in 2008 and flow releases commenced, no new information on the 21 operation of JORWORK-1 was added to the annual reports; the summary from the 2008 report 22 was repeated. An engineering completion report was prepared and submitted to the 23 Comptroller in December 2008 (see Appendix G). Neither the annual reports nor the 24 engineering report describe the reliability issues associated with backup power, nor do they 25 capture the decision to not rely on the existing backup power in 2008 (BC Hydro 2006–2012; BC 26 Hydro 2008b). 27

DISCUSSION 28

While the flow release valve could not be operated as originally designed and reporting was 29 silent on this topic, a minimum flow rate of 0.25 m3/s was achieved and BC Hydro met the 30 remaining performance measures associated with this Requirement. 31

The Water Use Plan rearing area and wetted stream length targets were based on modeled base 32 flows of 0.105 m3/s (D. Burt and Associates, 2015). However, as described under Requirement 33 10, August inflows were overestimated and loses to groundwater were underestimated by 34 approximately 0.1 m3/s. As a result, the higher than required flow rate, offset the overestimated 35



18 November 2016

base flows to achieve the habitat targets and contributed to the Water Use Plan objective to 1 maximize resident fish populations, invertebrates, and aquatic life in reservoirs. 2

CONCLUSION 3

Performance 4

With the exception of operational issues with the valve, BC Hydro complied with Requirement 2. 5 No adverse effects were identified or were expected on the broader intended outcome of a 6 minimum flow of 0.25 m3/s. 7

The operational issues that constituted the non-compliance resulted in a potential issue, as 8 repairs to the control valve may be required. 9


The flow release valve, once installed, could not be operated as originally designed, as it was 11 originally intended to be powered using onsite electrical sources, but emergency backup power 12 was not reliable until a replacement backup generator was installed in 2010. To ensure 13 minimum flow compliance in the event of a power failure including failure of emergency backup 14 power at Elliott Dam, the valve was locked in the full open position until the backup power could 15 be replaced. However, by the time the backup power was replaced the valve regulation controls 16 had corroded and were not functional. This resulted in a release discharge averaging 0.35 m3/s 17 (D. Burt and Associates, 2015). The higher volume of release discharge resulted in the instream 18 flows needed to achieve the Water Use Plan rearing area and wetted stream length targets, 19 providing benefits to target fish species and their habitat (JORMON-1 is the associated 20 monitoring study to evaluate instream flows. Refer to Requirement 10 for details on monitoring 21 results). 22


ISSUE? Between July 1 and September 30 of any year, the minimum operating elevation of Diversion Reservoir shall be 376.0 m, measured at the dam using Geodetic Survey of Canada (GSC) datum. Between October 1 and June 30 of any year, the minimum operating elevation of Diversion Reservoir shall be 372.0 m, measured at the dam using Geodetic Survey of Canada (GSC) datum.


FINDINGS 24


Were operational specifications and timing requirements met as prescribed for reservoir levels?

Operational specifications and timing requirements were met as prescribed in the Order. However, in one instance the reservoir was drafted below the specified operating elevation. The Comptroller was notified about this occurrence.



19 November 2016

All data was measured at the dam using Geodetic Survey of Canada datum and two instances 1 were identified when the reservoir dropped below the prescribed elevations (Appendix G), as 2 follows: 3

• January 17, 2005 – the reservoir was drafted in anticipation of a storm event that was not as 4 severe as expected (BC Hydro, 2005). The reservoir was drafted below the minimum level 5 for 3 hours. It is BC Hydro’s standard practice to draft the Jordan Diversion Reservoir prior to 6 storm events. For large storm events, this means drafting Diversion Reservoir as close as 7 practical to the minimum elevation as the largest storm events will fill the reservoir even 8 when the powerhouse is run at full-load. 9

• September 14 to 19, 2008 – the deviation was associated with preparations to take the 10 Jordan generator unit out of service. Prior to generating station outages, it is BC Hydro’s 11 standard practice to draft the Jordan Diversion Reservoir as close as practical to its minimum 12 elevation to avoid the need to use spillways during the outage (and forego energy 13 production). On this occasion, the draft was taken below the minimum elevation and 14 corrective actions were taken to prevent recurrence (BC Hydro, 2008). 15

On both occasions, drafting of the reservoir was conducted following standard operating 16 procedures (BC Hydro Generation Operating Order) and the Comptroller was notified. The first 17 instance occurred as a result of a hydrological event (Requirement 12), and therefore is within 18 the allowed criteria specified in the Order. However, the second instance where the reservoir 19 was drafted below the minimum operating level specified in the Order was for reasons other 20 than an emergency situation (Requirement 12), or to maintain minimum flows (Requirement 7). 21 Otherwise, BC Hydro maintained the operating elevation of Diversion Reservoir at 376.0 m 22 between July 1 and September 30 and at 372.0 m between October 1 and June 30 between 23 2005 and 2014 (BC Hydro, 2005–2014). 24

DISCUSSION 25

The two instances when BC Hydro drafted below the specified operating elevation of the 26 Diversion Reservoir were of a brief and minor nature with no documented adverse effects. 27 Based on the adherence to operating specifications and timing requirements, implementation of 28 this Requirement contributed to the Water Use Plan objective to maximize resident fish 29 populations, invertebrates, and aquatic life in reservoirs. No potential issue was identified. 30

CONCLUSION 31

Performance 32

With the exception of one non-compliances, BC Hydro complied with Requirement 3. No 33 adverse effects were identified or were expected as a result of the non-compliance. 34


Reduced drawdown was implemented as specified with the exception of the one non-36 compliance noted. JORMON-4 is the associated monitoring study conducted to evaluate the 37 effects of reduced drawdown on rainbow trout. Refer to Requirement 9 and 10 for details on 38 monitoring results. 39



20 November 2016


ISSUE? The licensee shall leave the low-level outlet at Bear Creek Reservoir closed and shall obtain approval of the Comptroller in advance of any draft below 411.0 metres, the full supply level.


FINDINGS 2


Were operational specifications and timing requirements met as prescribed for flows, reservoir levels and restriction(s)?

BC Hydro left the low-level outlet at Bear Creek Reservoir closed at all times, and the reservoir was not drawn down below 411.0 m due to BC Hydro operations. Accordingly, prior approval from the Comptroller was not required.

BC Hydro kept the low level outlet at Bear Creek Reservoir closed at all times in order to comply 3 with the 411.0 m minimum level in the reservoir. However, on September 17, 2012, the 4 reservoir level dropped below 411.0 m due to low natural inflows during dry summer weather 5 (BC Hydro, 2012). Given that reservoir levels dropped as a result of circumstances outside of BC 6 Hydro’s control, prior approval from the Comptroller was not required. BC Hydro notified the 7 Comptroller of the change in reservoir level on September 26, 2012 (BC Hydro, 2012). 8

DISCUSSION 9

BC Hydro met the performance measure associated with this Requirement. Based on the 10 adherence to operating specifications and timing requirements, implementation of this 11 Requirement contributed to the Water Use Plan objective to maximize resident fish populations, 12 invertebrates, and aquatic life in reservoirs. No potential issue was identified. 13

CONCLUSION 14

Performance 15



The low-level outlet at Bear Creek Reservoir was kept closed. As such, there was no monitoring 18 of this Requirement. 19


ISSUE? The licensee shall ensure that, on a minimum of 4 weekend days during the month of March, the combined maximum discharge rate under licenses FL117999 and FL118000 shall be 30 cubic metres per second (m3/s) between the hours of 06:00 and 18:00. This maximum discharge rate may be exceeded in emergency situations and the Comptroller shall be notified at the earliest possible convenience in this event.



21 November 2016


FINDINGS 2


Were operational specifications and timing requirements—flows, control specification(s), restriction(s)—met as prescribed?

Operational specifications and timing requirements were met as prescribed in the Order.

Requirement 5 required BC Hydro to constrain flows to improve surfing conditions during at 3 least 4 weekend days each March, unless this was not possible due to an emergency situation. 4 The annual conveyance reports BC Hydro submitted to the Comptroller from 2005 to 2014 5 indicate that BC Hydro followed the discharge requirements (BC Hydro, 2005–2014). No 6 emergencies occurred between 2005 and 2014 (BC Hydro, 2005–2014). 7


Were required notification(s) completed and submitted as required?

No notifications were required.

No notifications to the Comptroller were required as operational specifications and timing 8 requirements were met as prescribed. 9

DISCUSSION 10

BC Hydro met the performance measures associated with this Requirement. Based on the 11 adherence to operating specifications and timing requirements and data outlined in the annual 12 conveyance reports, implementation of this Requirement contributed to the Water Use Plan 13 objective to maximize the quality of surfing. No potential issue was identified. 14

CONCLUSION 15

Performance 16


Identified Outcome 18

Constrained flows stipulated in this requirement were implemented. JORMON-5 is the 19 associated monitoring study conducted to evaluate the effects on surfing quality. Refer to 20 Requirement 9 and 11 for more details on monitoring results. 21


ISSUE? The licensee shall release a minimum flow of 0.25 m3/s into Jordan River at the Elliott Dam outlet (PD31684) at all times, commencing within 2 years of the date of this order (hereinafter referred to as the "commencement date"), the works having been altered as per Requirements 1 and 2.



22 November 2016


FINDINGS 2


Were operational specifications and timing requirements met as prescribed for flows?

Implementation of the physical works met the minimum flow release requirements and commenced January 2008, consistent with a revised schedule approved by the Comptroller.

Implementation of the physical works met the minimum flow release requirements, and release 3 of minimum flows began within the final approved schedule (Appendix G). However, as 4 described in the discussion for Requirement 2, flows never reached the minimum flow limit of 5 0.25 m3/s due to reliability concerns with the backup power system (it was locked in the open 6 position to ensure minimum flows were maintained). Despite these operational issues, the 7 minimum flow and timing requirements were met (BC Hydro, 2008–2014). 8

DISCUSSION 9

BC Hydro met the performance measure associated with this Requirement. Based on the 10 adherence to operating specifications and timing requirements, implementation of this 11 Requirement contributed to the Water Use Plan objective to maximize resident fish populations, 12 invertebrates, and aquatic life in reservoirs. No potential issue was identified. 13

CONCLUSION 14

Performance 15



The minimum flow release requirement was met. JORMON-1, 2 and 3 are the associated 18 monitoring studies conducted to evaluate the effects of in-stream flows in Jordan River below 19 Elliott Dam and the effect of these flows on target fish species, or their habitat, refer to 20 Requirement 9 and 10 for details on monitoring and results and Requirement 2 for more 21 information on minimum flows and how they relate to physical works. 22


ISSUE? The minimum release specified in Requirement 6 takes precedence over the minimum operating elevation specified in Requirement 3 in the event that both conditions cannot be met. The licensee shall notify the Comptroller when the reservoir elevation falls below that minimum elevation as a result of this precedence.



23 November 2016


FINDINGS 2


Were operational specifications and timing requirements—flows, reservoir levels, volume(s), control specification(s), restriction(s)—met as prescribed?

Operational specifications and timing requirements were met as prescribed in the Order.

Requirement 7 required BC Hydro to release a minimum flow of no less than 0.25 m3/s from 3 2008 onwards, once the minimum flow release mechanism from JORWORKS-1 was installed, as 4 specified in Requirement 2 (see findings for Requirement 2). The Order stated that this 5 minimum flow release would take priority over meeting the Diversion Reservoir elevations 6 outlined in Requirement 3 (see findings for Requirement 3), if necessary. BC Hydro’s 7 Conveyance Reports from 2005 to 2014 indicate that the minimum release was maintained. BC 8 Hydro did not have to prioritize the minimum release flow over reservoir elevation levels from 9 2005 to 2014 (BC Hydro, 2008–2014). 10

Minimum flows were maintained in accordance with Requirement 6 (from 2008–2014), and it 11 was not necessary to drop the reservoir elevation to maintain flow (BC Hydro, 2008–2014). 12


Were required notification(s) completed and submitted as required?

No notifications were required.

No notifications to the Comptroller were required as operational specifications and timing 13 requirements were met as prescribed (BC Hydro, 2008–2014). 14

DISCUSSION 15

BC Hydro met the performance measures associated with this Requirement. Based on the 16 adherence to operating specifications and timing requirements and data outlined in the annual 17 conveyance reports, implementation of this Requirement contributed to the Water Use Plan 18 objective to maximize resident fish populations, invertebrates, and aquatic life in the reservoirs. 19 No potential issue was identified. 20

CONCLUSION 21

Performance 22



It was not necessary for BC Hydro to prioritize the minimum release flow over reservoir 25 elevation levels. 26



24 November 2016


ISSUE? The licensee shall submit a monitoring plan for acceptance by the Comptroller within 3 months of the date of this order outlining details of the monitoring proposed, including what is to be measured, the frequency, location and how it is to be reported.


FINDINGS 2


Were fish studies plan(s) developed and submitted in accordance with requirements?

JORMON-1 through JORMON-4 Terms of Reference were developed in accordance with the requirements and were approved by the Comptroller. However, the Terms of Reference for the fish studies were not submitted to the Comptroller within 3 months of the Order date (by October 20, 2004).

The Order instructed BC Hydro to develop and submit monitoring plans for four fisheries and 3 one surfing quality study by October 20, 2004 (Appendix G). 4

Although the final Terms of Reference satisfied the expectations of regulators and First Nations, 5 multiple layers of consultation and review were required, and the Terms of Reference had to be 6 reviewed and approved by both B.C. Ministry of Environment and Fisheries and Oceans Canada 7 before they could be submitted to the Comptroller for review and approval. As a result, the 8 Terms of Reference drafting and consultation process took longer than originally anticipated and 9 resulted in an 8-month delay in finalizing the Terms of Reference and submitting them to the 10 Comptroller. The Comptroller approved all of the Terms of Reference on June 30, 2005 (see 11 Appendix G for timeline details). 12


Were surfing quality plan(s) developed and submitted in accordance with requirements?

The JORMON-5 Terms of Reference were developed in accordance with the requirements and were approved by the Comptroller. However, the Terms of Reference were not submitted to the Comptroller within 3 months of the Order date (by October 20, 2004).

The JORMON-5 Terms of Reference outlines a monitoring plan approved by the Comptroller to 13 assess the decision to limit maximum turbine discharges to 30 m3/s on 4 weekend days during 14 the month of March. The Comptroller-approved monitoring plan deviates from the specific 15 wording of Requirements 5 and 11 by providing for collection of comparative data on surfing 16 quality during constrained discharge flows (up to 30 m3/s maximum) in even years, and during 17 unconstrained flows (over 30 m3/s) in odd years (BC Hydro, 2004). 18



25 November 2016

Although the final Terms of Reference satisfied the expectations of the Comptroller, the 1 consultation and review process took longer than originally anticipated and resulted in an 2 8-month delay in finalizing the Terms of Reference and submitting them to the Comptroller. 3

DISCUSSION 4

While BC Hydro did not submit the Terms of Reference for the fish studies or the surfing quality 5 to the Comptroller by the date specified in the Order, BC Hydro met the remaining components 6 of the performance measures of this Requirement. The delays had no known adverse effects. 7 Accordingly, implementation of this Requirement contributed to the Water Use Plan objectives 8 to maximize the quality of surfing and maximize resident fish populations, invertebrates, and 9 aquatic life in reservoirs. No potential issue was identified. 10

CONCLUSION 11

Performance 12

With the exception of the fisheries and surfing quality monitoring plan Terms of Reference not 13 being submitted on time, BC Hydro complied with Requirement 8. No adverse effects were 14 identified or were expected as a result of the delay in submission of the Terms of Reference. 15


The Terms of Reference to conduct five monitoring studies were developed and approved by 17 the Comptroller. Monitoring studies were developed with input from regulators, stakeholders 18 and First Nations. 19


ISSUE? The licensee shall implement monitoring in accordance with the plan as accepted under Requirement 8.


FINDINGS 21

All four fisheries monitoring programs (JORMON-1, 2, 3, and 4) were completed as per the 22 Terms of Reference approved by the Comptroller, with the exception of JORMON-2 and 23 JORMON-4. (D.W. Burt and Associates, 2006–2013, 2015; D.W. Burt and R. Hudson, 2013; R. 24 Hudson, 2006–2010; Cascadia Biological Services, 2006–2013 Reports; Lough et al. 2006–2013 25 Reports; Appendix G). 26



26 November 2016


Was the fish monitoring completed per design? BC Hydro completed JORMON-1 through JORMON-4 as per the Terms of Reference approved by the Comptroller, or as amended through subsequent communications with the exception of JORMON-4. Monitoring during extensive drawdown in the final year of the study as specified in the Terms of Reference was not conducted.

JORMON-2 was completed as per the approved Terms of Reference with one exception, which 1 was agreed upon with the Comptroller in advance. JORMON-2 was initially scheduled to be 2 conducted 2 years prior to minimum flow releases and 4 years post minimum flow releases. 3 However, the monitoring schedule was adjusted due to delays in the installation of the flow 4 release valve, which delayed the start of minimum flow releases. As a result, the monitoring 5 program was conducted for 3 years prior and 3 years post minimum flow implementation. BC 6 Hydro informed the Comptroller of the schedule change for JORMON-2 on May 31, 2006 7 (Comptroller, 2015). 8

The schedule change was evaluated to assess the effect on results generated by JORMON-2. 9 According to the 2015 Jordan Synthesis Report (Appendix F), “The delayed implementation 10 timing did not undermine the study effectiveness, as the comparison of biologic response using 11 3 years prior/3 years post flow implementation still adequately describe flow effects” (D. Burt 12 and Associates, 2015). 13

JORMON-4 called for 5 years of monitoring under the Order drawdown regime (baseline years), 14 followed by a final year with extensive drawdown below 376.0 m during the summer months 15 (treatment year). The treatment year was meant to assess the response in aquatic productivity 16 to an extensive drawdown. However, BC Hydro was unable to provide the conditions for an 17 extensive drawdown in year 6 due to operational constraints. Based on the water budget for 18 that year, it would not have been possible to satisfy summer flow requirements if BC Hydro had 19 proceeded with the extensive drawdown (Leake, A. miscellaneous communications, 2016). 20 Additionally, survey during drafting events in 2005 and 2008 revealed that severe drawdown 21 during the summer months can lower the mid-water layer of crucial fish habitat to the point 22 where it is drawn off by hollow cone valve releases. As a result, that aspect of the monitoring 23 program could not be specifically addressed (Lough et al., 2013; D.W. Burt and Associates, 24 2015). It was possible to draw conclusions from data collected regarding the benefits of limited 25 drawdown on rainbow trout, such as a significant increase in trout abundance, without the 26 extensive drawdown in year 6, and this was weighed into the decision to not attempt extensive 27 drawdown (Leake, A. miscellaneous communications, 2016). However, other than the annual 28 report produced to summarize the result of the final year of monitoring, there is no 29 documentation to indicate the Comptroller was notified of this change. As a result, JORMON-4 30 was not fully completed per design. 31



27 November 2016


Was the surfing quality monitoring completed per design?

Most aspects of the surfing quality monitoring program were implemented in accordance with the Terms of Reference. However, the survey question regarding effect of discharges on surf quality was vague. As a result, responses did not consistently indicate whether effects were positive or negative.

Surfing quality monitoring was conducted each March (and sometimes in late February or early 1 April) from 2006 to 2011 as specified in the Terms of Reference (Recreation Resources Limited, 2 2008–2011). The JORMON-5 Terms of Reference provided for surfing quality monitoring under 3 constrained flows7 to take place during even years and for monitoring under unconstrained 4 flows to take place during odd years to generate comparative data. However, a variety of factors 5 (low flows, absence of surfers, marginal wave height, and poor weather conditions) limited 6 monitors’ ability to gather data on surfing quality under unconstrained flow conditions during 7 odd years. Therefore, monitoring of unconstrained flow conditions was conducted on several 8 days during two even years (2008 and 2010) instead of only during odd years. Although 9 monitors hoped to gather data during fully unconstrained flows around 70 m3/s, no opportunity 10 to do so occurred during the 2006–2011 monitoring periods (Recreation Resources Limited, 11 2008–2011). 12

As specified in the Terms of Reference, monitoring included both on-site observations and 13 in-person surveys of surf users, and, prior to the first monitoring event, a survey instrument for 14 assessing the relationship between discharge flows and surfing quality (the key focus of the 15 survey) was developed. Of the 17 survey questions, one dealt directly with discharge flows and 16 surfing quality. However, the question did not specifically ask if the effect on quality of surfing 17 was positive or negative. As a result the information generated by the survey regarding the 18 effects of discharge flows on surf users was vague. 19

Question: Did you notice if the water discharge from the Jordan River affected your water 20 activity? 21

Observation: This question asks if the surfing was affected, not whether the effect benefited 22 or detracted from the quality of surf conditions. 23

Some of the annual reports included comments by surf users who noticed discharge effects; 24 however, the person administering the survey did not probe respondents to clarify whether 25 discharges benefited or detracted from the quality of surfing conditions. Although some 26 comments characterized discharge effects in clearly negative or positive terms, other comments 27 were less clear and were difficult to interpret without speculation (Recreation Resources 28 Limited, 2008, 2009, 2010, 2011). As a result, while the monitoring was conducted as specified 29 in the Terms of Reference, there was a deficiency inherent in the survey instrument. Outcomes 30 of the monitoring and the effect of this deficiency are discussed later in the report (see 31 Performance Measure 11.2). 32

7 Per Requirement 5, constrained flows are the maximum allowable flows (30 m3/s) stipulated in this Requirement.

Unconstrained flows are regular run flows.



28 November 2016


Was the surfing quality monitoring completed on budget?

The JORMON-5 project was completed under budget.

1

If a study is under budget, it is only an area of concern if the management questions were not 2 answered (i.e., the quality of the work completed was compromised). Outcomes are discussed 3 in detail under Requirement 11). Based on the findings in this section, outcomes from this study 4 were not compromised due to reduced costs. 5

DISCUSSION 6

While extensive drawdown in the final year of monitoring required under JORMON-4 was not 7 conducted and the Comptroller was not notified in advance of the change, BC Hydro met the 8 remaining performance measures of this Requirement. 9

CONCLUSION 10

Performance 11

With the exception of a non-compliance because JORMON-4 was not fully implemented in 12 accordance with the approved plan and the Comptroller was not notified, BC Hydro complied 13 with Requirement 9. No adverse effects were identified or were expected as a result of this 14 non-compliance. 15


Monitoring was implemented as specified in the Terms of Reference with one exception noted. 17 The last year of JORMON-4 monitoring was planned to include an extensive drawdown to look 18 at the response in aquatic productivity, but this treatment drawdown did not occur for 19 operational reasons. 20

An additional identified outcome is that for the surf quality monitoring (JORMON-5) a variety of 21 factors (low flows, absence of surfers, marginal wave height and poor weather conditions) 22 limited the monitor’s ability to gather data on surfing quality under unconstrained flow 23 conditions during odd years; as a result, monitoring of unconstrained flow conditions was 24 conducted on several days during even years. 25



29 November 2016


ISSUE? The licensee shall provide annual reports to the Comptroller beginning 1 year after the commencement of the monitoring as per the plan accepted in Requirement 8, including the following information:

a) Size and abundance of rainbow trout in Lower Jordan River below Elliott Dam.

b) Salmonid spawner surveys in Lower Jordan River. c) Fish stress indicators in Diversion Reservoir in comparison to the

inventory measured during the preparation of the Jordan River System Water Use Plan.


FINDINGS 2


Was the fish monitoring reporting completed per design?

All the reporting required for JORMON-1 through JORMON-4 was completed as per design, including yearly reports and summary reports, where required.

BC Hydro prepared and submitted annual monitoring reports and a final summary report in the 3 last year of each study for JORMON-1 through JORMON-4 in accordance with the requirements 4 of the Order and the Terms of Reference. 5

Information that was specified within the Order was found to have been addressed by the 6 monitoring programs, specifically JORMON-2 to JORMAN-4, as follows: 7

• JORMON-1: Lower Jordan River Inflow Monitoring Program. Reported on accuracy of 8 baseflow assumptions in Jordan River below Elliot Dam and implications for the Water Use 9 Plan decision (R. Hudson, 2006; D. W. Burt and R. Hudson, 2007–2013). 10

• JORMON-2: Fish Index: Lower Jordan River. Reported on the size and abundance of rainbow 11 trout in the lower Jordan River below Elliot Dam (D.W. Burt and Associates, 2006–2013). 12

• JORMON-3: Lower Jordan River Salmon Spawning Assessment and Enumeration. Reported 13 results of salmonid spawner surveys in the Lower Jordan River (Cascadia Biological Services, 14 2006–2013). 15

• JORMON-4: Diversion Reservoir Fish Indexing. Reported on fish condition in Diversion 16 Reservoir (Lough et al., 2006–2013). 17



30 November 2016


Did the fish monitoring answer the management question(s)?

Although the monitoring programs were completed, the findings of the JORMON-3 and JORMON-4 were unable to answer the following management questions: • JORMON-3 was unable to determine whether

the planned flow releases improved spawning habitat for salmon and steelhead in the anadromous reaches of the Lower Jordan River.

• JORMON-4 was unable to determine (through field observation) the effects of a prolonged extensive drawdown on rainbow trout condition.

Collectively, JORMON-1, -2, -3, and -4 were designed to address 11 management questions and 1 satisfy six study objectives (Appendix E) as follows: 2

• JORMON-1: three management questions and two objectives (BC Hydro JORMON-1 Terms 3 of Reference, 2005). 4

• JORMON-2: three management questions and one objective (BC Hydro JORMON-2 Terms of 5 Reference, 2005). 6

• JORMON-3: three management questions and two objectives (BC Hydro JORMON-3 Terms 7 of Reference, 2005). 8

• JORMON-4: two management questions and one objective (BC Hydro JORMON-4 Terms of 9 Reference, 2005). 10

Table 3 presents a summary of the study outcomes relative to each management question and 11 study objective. Although the monitoring studies were generally conducted as designed, with 12 the exception of JORMON-4 as described under Requirement 9, they were not able to fully 13 answer one of the management questions (Table 3). 14


Based on fish monitoring results, have the operational requirement(s) resulted in a beneficial change to the target resource (i.e., fish habitat and abundance)?

JORMON-1 through JORMON-4 identified a number of benefits to the target resource (i.e., salmonids, rainbow trout) that were realized as a result of the operational requirement(s).

As shown in Table 3, JORMON-1 through JORMON-4 indicated several benefits to fish resources 15 as a result of minimum flows and reduced reservoir drawdown. Benefits included increases to 16 habitat continuity and fish abundance in the Lower Jordan River and increased abundance of 17 rainbow trout within the Diversion Reservoir with reduced allowable drawdown. 18



31 November 2016

Table 3. Study Outcomes Relative to Each Management Question for JORMON-1 through JORMON-4

Associated Monitoring Program Management Question or Objective

Was the Question Answered? Outcome

JORMON-1 How accurate were the assumptions made regarding local inflows that were used for Water Use Plan recommendations?

Yes It was identified that the assumptions made regarding local inflows that were used for Water Use Plan recommendations were 258–289% higher then what was actually observed. The local inflows measured were 0.055 m3/s for the month of August compared to a predicted inflow of 0.16 m3/s.

JORMON-1 What are the reasons for the differences, if any, between the monitored and assumed inflows?

Yes It was determined that the Water Use Plan assumptions overestimated local inflows by 0.105 m3/s and underestimated the amount of water lost to ground by 0.03–0.04 m3/s for the month of August.

JORMON-1 What implications, if any, are there on the Water Use Plan recommendations based on revised inflow data?

Yes BC Hydro identified the implications of overestimating the assumed flows such that the minimum flow release would need to be 0.39 m3/s instead of 0.25 m3/s to achieve the same weighted usable area of fish habitat.

JORMON-2 Does the flow release restore habitat continuity (i.e., are all habitat units connected by flowing water)?

Yes The results from JORMON-2 confirmed that the amount of water released into the Jordan River from 2008 onwards restored habitat continuity throughout the Lower Jordan River. Areas of the river that were predominately dry and unconnected exhibited continuous flow and allowed for unrestricted movement of fish.

JORMON-2 How will the planned flow releases affect the standing stock of the rainbow trout population?

Yes The results from JORMON-2 determined that the observed flow releases resulted in an increase in abundance of rainbow trout (increased standing stocks) in the Lower Jordan River. Following the flow releases it was also observed that 1+ and 2+8 juvenile trout and Coho fry repopulated the copper impacted zone in Reach 2 of the Lower Jordan River. Note: The issues with the installation of the cone valve meant that it was not possible to confirm the benefits to resident fish in the Lower Jordan River at the minimum flow limit of 0.25 m3/s. The habitat benefits that were observed in the Lower Jordan River were associated with higher flow releases from the control valve, not the 0.25 m3/s minimum flow release.

8 1+ and 2+ refers to fish that are at least one year old and at least two years old, respectively.



32 November 2016



JORMON-2 How will the planned flow releases affect the distribution of fish condition (weight to length) by age within the rainbow trout population?

Yes JORMON-2 monitoring results showed that there was no significant difference between the average condition factor of rainbow trout before and after the flow releases. It appears that increases in rearing habitat and food production after the flow release were met with increased trout abundance leaving the influence of density-dependent factors on condition factor unchanged. However, their condition factor was observed to be similar to fish outside the copper impacted zone.

JORMON-3 Will the planned flow releases improve spawning habitat for salmon and steelhead in the anadromous reaches of the Lower Jordan River?

Yes JORMON-3 monitoring results indicated that observed flow release did not greatly improve salmon spawning habitat as most spawning occurs after the arrival of fall rains. It was noted they could aid in the passage of adult salmonids. However, improvements to adult salmonid passage were not confirmed, because very low numbers of Coho, chum, and steelhead were observed throughout the study.

JORMON-3 Will the planned flow releases improve effective incubation habitat for spawning salmon and steelhead?

Yes Incubation success was assessed both pre- and post-flow release as a part of JORMON-3 and it was determined that there was no apparent benefit to incubation success from the flow release.

JORMON-3 What are the potential sources of contamination from the planned flow releases and what effects, if any, will the planned flow releases have on chronic toxicity of rearing and incubating salmonids?

Yes JORMON-3 monitoring results identified a potential source of contamination from an abandoned copper mine downstream of the Elliot Dam. It was determined based on JORMON-3 monitoring results that there was no difference in incubation success due to copper contamination between the baseline and observed flow release. The effect on rearing was assessed as part of JORMON-2, and it was determined that salmonid rearing that could not occur in the copper-affected region of the river pre-flow release could occur post-flow release due to greater dilution.

JORMON-4 What are the benefits to rainbow trout condition associated with a reduced allowable drawdown?

Yes JORMON-4 monitoring results indicated that there was no significant change in condition factor of rainbow trout due to reduced allowable drawdown. However, the monitoring results did show that abundance of rainbow trout within the Diversion Reservoir increased significantly with reduced allowable drawdown, and it was suggested that abundance may be a better performance measure than condition factor.



33 November 2016



JORMON-4 What are the impacts on rainbow trout condition associated with a prolonged extensive drawdown?

Partially The impacts on rainbow trout condition associated with prolonged extensive drawdown could not be assessed directly as the prolonged drawdown planned for year 6 of the study did not occur. Therefore, the JORMON-4 monitoring program was limited to inferring the changes in rainbow trout condition based on the predicted changes in limnological parameters that would occur under prolonged drawdown. Based on this approach it was concluded that extensive drawdown could negatively impact rainbow trout if the habitable region (appropriate temperature and dissolved oxygen levels) of Diversion Reservoir was reduced by extensive drawdown.



34 November 2016

DISCUSSION 1

Although the studies were not able to fully answer one of the 11 management questions the 2 monitoring studies were completed as required and BC Hydro met the performance measures 3 associated with this Requirement. Accordingly, implementation of this Requirement contributed 4 to the Water Use Plan objectives to maximize the quality of surfing and maximize resident fish 5 populations, invertebrates, and aquatic life in reservoirs. No potential issue was identified. 6

CONCLUSION 7

Performance 8



The monitoring conducted by BC Hydro found the following in relation to installation and 11 operations of the hollow cone release valve to release minimum flows (Requirement 1, 2, and 6) 12 and limiting reservoir drawdown as stipulated in Requirement 3: 13

• JORMON-1 found that the flows used in the Water Use Plan overestimated August 14 inflows and underestimated losses to groundwater by approximately 0.1 m3/s. If 15 minimum flows of 0.25 m3/s had been released, this would have resulted in in-stream 16 flows lower than planned (if the assumptions regarding base flows had been correct). 17 However, due to the need to leave the control valve in the open position, releases 18 averaged 0.35 m3/s, which ultimately resulted in the target instream flows expected as a 19 result of the minimum flow releases originally planned (0.25 m3/s) (D. Burt and 20 Associates 2015). 21

• Following the implementation of the flow releases, JORMON-2 found that the density of 22 1+ and 2+ rainbow trout increased, juvenile trout and Coho fry repopulated the copper 23 impacted zone and habitat continuity was improved in the system. Although changes to 24 the condition factor of rainbow trout relative to baseline observations were not 25 observed following flow releases their condition factor was similar to fish outside the 26 impacted zone (D. Burt and Associates 2015). 27

• JORMON-3 spawner surveys observed low counts of adult salmon and steelhead in the 28 Lower Jordan River during the study years; however, there was an increase in the 29 number of Coho present during 2014 surveys. Flow release did not increase the quantity 30 of available spawning habitat, but did dilute pollutants enough in some reaches to 31 facilitate rearing (based on fish presence) where it was previously too contaminated (D. 32 Burt and Associates 2015). 33

• JORMON-4 found that there was no significant increase in rainbow trout condition 34 factor within the Diversion Reservoir due to reduced allowable drawdown; however, 35 abundance did increase significantly. It was also found that the fish habitable zone 36



35 November 2016

(appropriate levels of dissolved oxygen and temperature) of the reservoir could be 1 negatively impacted by extensive drawdown (D. Burt and Associates 2015). 2


ISSUE? The licensee shall provide annual reports to the Comptroller, beginning 1 year from the effective date of this Order, documenting pertinent information regarding surfing conditions during the days outlined in Requirement 5 above.


FINDINGS 4


Was the reporting completed per design? Reporting was completed as specified in the surfing quality monitoring plan approved by the Comptroller.

Reporting on surf quality monitoring was completed in accordance with Requirement 11 and 5 JORMON-5. The annual reports documenting surfing quality monitoring and interim results were 6 prepared for monitoring years 2006–2011 (Recreation Resources Limited, 2006–2010 and 2013). 7 In addition, a summary of the surfing quality monitoring activities was provided in the Annual 8 Monitoring and Works Reports produced by BC Hydro (2006–2012). 9


Did the surfing quality monitoring answer the management question(s)?

The annual surfing quality monitoring results suggest potential benefit from discharge constraints.

As specified in JORMON-5, a comprehensive report was prepared at the end of the review 10 period. It synthesized all 6 years of monitoring data to assess the merits of Requirement 5, and 11 to determine if the recommendation should be revisited, or if further monitoring is required (D. 12 Burt and Associates 2015) (Appendix F). The JORMON-5 annual monitoring reports did not offer 13 explicit interpretations of the monitoring results in terms of the benefits to surfing quality from 14 discharge constraints (Recreation Resources Limited, 2008-2010 and 2013). In the synthesis 15 report (Appendix F), D.W. Burt and Associates aggregated all of the data and drew conclusions 16 regarding the benefit of discharge constraints to the surfing quality. 17


Based on surfing quality monitoring results, have the operational requirement(s) resulted in a beneficial change to the target resource (i.e., surfing quality)?

Surf quality monitoring from 2006–2011 indicate that Requirement 5 discharge restrictions may have benefited surfing quality.

Table 4 presents a summary of the study outcomes relative to the JORMON-5 management 18 question. The results of the monitoring efforts indicate some benefit to Jordan River surfing 19 quality from the maximum discharge constraint of 30 m3/s. Other environmental factors also 20 affect surf quality and the benefit associated with discharge constraints. However, the range of 21



36 November 2016

environmental conditions and the variability in their nature and occurrence limit the ability to 1 predict when flow constraints would improve surf conditions (Appendix F). 2

It appears that data gathered from the full range of potential flow conditions (from no flow to 3 flows around 70 m3/s), and modification to the survey instrument and data collection and 4 analysis could improve the usefulness of conclusions drawn as a result of monitoring. For 5 example: 6

• Surveys conducted in 2006 and 2007 included numerous inexperienced surfers who claimed 7 to be affected by discharge when discharge was absent or constrained. 8

• Surf user comments included in the 2008 and 2010 reports indicated that some respondents 9 who noticed effects from discharge characterized those effects in negative terms, but others 10 who noticed effects characterized those effects in positive terms (Recreation Resources 11 Limited, 2008 and 2010). 12

• Experienced surfers more accurately identified the effect of constrained or unconstrained 13 flows and provided detailed information on the interaction between environmental 14 conditions and flows (Recreation Resources Limited, 2008–2010). 15



37 November 2016

Table 4. Study Outcomes Relative to Each Management Question for JORMON-5 1

Associated Monitoring Program

Management Question or Objective


JORMON-5 Do constraints on generation benefit surfing quality at Jordan River?

Yes Monitoring results indicate that constraints on generation have potential benefit to surfing quality. However, some uncertainty remains: • Benefits of constrained flows were generally only detected by

experienced surfers familiar with the conditions of the site, and when surf quality was not overridden by other environmental variables (weather, tides, wind, wave height, etc.).

• Results indicated that discharge can be perceived positively under some conditions.

• The majority of surveys did not report Jordan River Generating Station discharge to be a factor in their surfing experience, but pointed to other environmental variables as factors affecting surf quality (Recreation Resources Limited, 2006–2011).

• The range of potential conditions monitored during this study was limited: no survey data was gathered during fully unconstrained flows.

• Some surf user surveys and informal reports by experienced surfers indicated that under some conditions discharge flows can enhance surfing quality at the Points Left surfing location, and can aid surfers by carrying them out to the locations of breaking waves.

• The effects of discharge flows on surfing quality appear highly dependent on other environmental factors (tidal action, wave size and interval, wind, and weather).

If all other factors are consistent, constrained flows provide more favourable surf conditions (D. Burt and Associates 2015).

Note: The intent of the management question is to focus on “Whether constraints on generation benefit surfing,” and not on “How constraints on generation benefit surfing,” i.e. in terms of environmental factors (wind direction and speed, wave height, swell interval and tidal action [flood or ebb]) that contribute to or negate the effects of constraints on surfing.

2



38 November 2016

DISCUSSION 1

JORMON-5 was designed to assess whether constraints on generation benefit surfing quality at 2 Jordan River. Monitoring results suggest that discharge constraints have potential benefits to 3 surfing quality. BC Hydro met the performance measures associated with this Requirement. 4 Based on the adherence to operating specifications and timing requirements and data outlined 5 in the annual conveyance reports, implementation of this Requirement contributed to the 6 Water Use Plan objective to maximize the quality of surfing. No potential issue was identified. 7

CONCLUSION 8

Performance 9


Identified Outcome 11

JORMON-5 found that constraints on generation stipulated in Requirement 5 have potential 12 benefit to surfing. However, other factors such as environmental conditions (weather, tides, 13 wind, etc.) greatly limited the ability to predict when flow constraints would successfully 14 improve surf conditions. If all other factors are consistent, constrained flows provide more 15 favourable surf conditions (D. Burt and Associates 2015). 16


ISSUE? The licensee shall operate the works in an alternate manner in the event of an emergency, a dam safety requirement, or an extreme hydrological event. N/A


FINDINGS 18


Were operational specifications and timing requirements—flows, reservoir levels, volume(s), control specification(s), restriction(s)—met as prescribed?

BC Hydro operated in an alternative manner outside the requirement specified in the Jordan Order once in anticipation of a hydrological event. Otherwise, operational specifications and timing requirements were met as prescribed.

Requirement 12 is not measurable. It allows BC Hydro to operate works in an alternate manner 19 in the event of an emergency, a dam safety requirement or an extreme hydrological event. 20

BC Hydro operated works in a manner outside the requirements specified in the Order once due 21 to an anticipated hydrological event. On January 17, 2005 the Diversion Reservoir was drafted 22 below the minimum 372.0 m for 3 hours in order to prepare for a substantial storm and 23 forecasted inflows (BC Hydro, 2006) (Appendix G). In addition, although BC Hydro did not 24 operate works in an alternate manner, dry weather and reduced natural inflows in September 25



39 November 2016

2012 lead to the Bear Creek Reservoir levels being below the elevation of 411.0 m as required 1 by Requirement 4. The only way in which the reservoir could be reinstated was following 2 precipitation and subsequent runoff (BC Hydro, Conveyance Report 2012) (Appendix G). All 3 other conveyance reports indicate that it was not necessary to alter operations due to any 4 emergency, dam safety requirement, or extreme hydrological events. 5

DISCUSSION 6

BC Hydro met the performance measure associated with this Requirement. There is no direct 7 connection between this Requirement and any Water Use Plan objectives. No potential issue 8 was identified. 9

CONCLUSION 10

Performance 11



BC Hydro operated the works in an alternate manner on one occasion when the Diversion 14 Reservoir was drafted below the minimum elevation of 372 m for 3 hours in order to prepare for 15 a substantial storm event and forecasted inflows (BC Hydro, 2006). 16


ISSUE? The emergency operations or other deviations from this order shall be reported to the Comptroller in a timely manner.


FINDINGS 18


Were required report(s) and notification(s) completed and submitted as required?

The majority of operational specifications and timing requirements were met as prescribed in the Order. However, on one occasion, reporting of a deviation to the Comptroller was not completed in a timely manner. This was the first year of operation under the WUP Order and reporting expectations were still being defined.

Requirement 13 requires BC Hydro to report emergency operations or other deviations from the 19 Order to the Comptroller in a timely manner. Reporting was necessary on three separate 20 occasions, and on two of those occasions it has been confirmed that the Comptroller was 21 informed in a timely manner (Appendix G). On one occasion, BC Hydro did not inform the 22 Comptroller of the deviation event, which occurred on January 17, 2005, until the March 2006 23 annual report. Given that this was over a year after the occurrence, the conditions of 24 Requirement 13 were not met. However, this was the first year of operation under the WUP 25



40 November 2016

Order and reporting expectations were still being defined. Additionally, given the brief and 1 minor nature of this deviation, no adverse effect was reported in the annual compliance letters 2 (Comptroller of Water Rights, 2006). 3

DISCUSSION 4

While BC Hydro did not inform the Comptroller of one deviation event in a timely manner, BC 5 Hydro met the remaining operational specifications and timing conditions of this Requirement. 6 There is no direct connection between this Requirement and any Water Use Plan objectives. 7

CONCLUSION 8

Performance 9

With the exception of reporting one deviation approximately a year after occurrence, BC Hydro 10 complied with Requirement 13. No adverse effects were reported or expected regarding the 11 delay in the reporting of the deviation. Following this delay in reporting BC Hydro have 12 implemented procedures to address reporting requirements and responsibilities which has 13 resulted in no further reporting deviations occurring. 14


BC Hydro reported emergency operations or other deviations on three occasions. On one 16 occasion, reporting was not completed in a timely manner (Comptroller of Water Rights, 2006).17

41 November 2016

4 Financial Metrics 1

2 This section describes the costs associated with implementation of the JORWORKS-1 physical works 3 program and the JORMON-1 through JORMON-5 monitoring programs. It compares actual costs relative 4 to the initial commitments BC Hydro made during the Consultative Committee process and subsequent 5 agreements contained within the Terms of Reference. During the planning process, BC Hydro made an 6 initial commitment of financial resources. This commitment was based on estimated direct and indirect 7 costs. In developing the Terms of Reference, a more detailed and accurate cost estimate was created 8 that better reflected the construction, data collection, and analysis costs, and these revised costs were 9 submitted to the Comptroller for approval (JORWORKS-1 Addendum #1; JORMON-1 Addendums #1-3). 10 The Comptroller-approved costs became the budget for the physical works project and each monitoring 11 study. Table 5 provides BC Hydro’s estimated initial financial commitment, Comptroller-approved costs, 12 actual costs, and the variance between Comptroller-approved and actual costs. As shown in the table, 13 the physical works project and all studies were completed within budget and exceeded the initial 14 commitment. 15

Table 5. Jordan River System Physical Works and Monitoring Program Financial Metrics 16

Physical Works

Project or Monitoring

Program

BC Hydro Estimated

Initial Commitment1

Comptroller-Approved

Costs Actual Costs

Variance Between Comptroller Approved and Actual Costs

Dollars Under Budget

Percent Under Budget

JORWORKS-1 N/A $675,982.00 $559,768 $116,214 17%

JORMON-1 $39,240 $178,412 $164,158 $11,254 6%

JORMON-2 $156,961 $175,923 $138,837 $38,086 22%

JORMON-3 $52,320 $144,894 $120,829 $24,065 17%

JORMON-4 $65,400 $121,543 $80,162 $41,381 34%

JORMON-5 $4,578 $65,362 $35,757 $31,247 48%

TOTAL $318,499 $686,134 $539,743 $146,033 24% 1 BC Hydro’s estimated initial commitments do not include direct management costs or account for inflation. 2 An estimated initial commitment was not estimated for JORWORKS-1.

17

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43 November 2016

5 Summary and Analysis of Results 1

2

To comply with the Jordan River System Order, BC Hydro completed required actions related to 3 operational constraints and environmental monitoring over an 8-year period to address fishery and 4 recreation objectives and reporting requirements. BC Hydro’s implementation of the Jordan River 5 System Order was conducted within the Comptroller-approved budget. The overall outcome of BC 6 Hydro’s implementation of the Jordan River System Order was positive, and resulted in benefits to 7 fisheries resources and recreational interests. The objectives of the Order appear to have been satisfied. 8 The operational constraints were implemented and the expected benefits were tested and analyzed. 9 The monitoring studies successfully answered the fisheries and recreation questions, with the exception 10 of benefits to fish habitat from 0.25 m3/s minimum flows and the observed effects of extensive 11 drawdown on rainbow trout. 12

As shown in Table 6, the Order Review has determined that BC Hydro fully complied with seven of the 13 13 Order Requirements. One requirement was non-measurable. There were no documented adverse 14 effects associated with the non-compliances for the remaining four Requirements. Two of the outcomes 15 associated with two of the non-compliant ratings were negative. Based on these findings, a potential 16 need for follow-up action has been identified for Requirements 2 and 13. There is a potential need for 17 follow-up for these two Requirements because aspects of the overall objective of the actions mandating 18 these Requirements were not achieved. The findings are presented in the table below. 19



44 November 2016

Table 6. Jordan River Order Review Results 1



1 Design Plans - The licensee shall submit, to the Comptroller, design plans, prepared by a professional engineer registered in British Columbia, for the alteration of works to enable a flow release into Jordan River through Elliott Dam.


The design plans were developed as specified for a flow release valve to provide a minimum flow rate of at least 0.25 m3/s through Elliott Dam into lower Jordan River (BC Hydro, 2008b).

2 Physical Works - The licensee shall alter the works in accordance with the approved plans after leave is given in writing by the Comptroller.

With the exception of operational issues with the valve, BC Hydro complied with Requirement 2. No adverse effects were identified or were expected on the broader intended outcome of a minimum flow of 0.25 m3/s. The operational issues that constituted the non-compliance resulted in a potential issue, as repairs to the control valve may be required.

The flow release valve, once installed, could not be operated as originally designed, as it was intended to be powered using onsite electrical sources, but emergency backup power was not reliable until a replacement backup generator was installed in 2010. To ensure minimum flow compliance in the event of a power failure including failure of emergency backup power at Elliott Dam, the valve was locked in the full open position until the backup power could be replaced. However, by the time the backup power was replaced the valve regulation controls had corroded and were not functional. This resulted in a release discharge averaging 0.35 m3/s (D. Burt and Associates, 2015). The higher volume of release discharge resulted the intended instream flows needed to achieve the Water Use Plan rearing area and wetted stream length targets, providing benefits to target fish species and their habitat (JORMON-1 is the associated monitoring study to evaluate instream flows. Refer to Requirement 10 for details on monitoring results).



45 November 2016



3 Minimum Operating Levels - Between July 1 and September 30 of any year, the minimum operating elevation of Diversion Reservoir shall be 376.0 m, measured at the dam using the Geodetic Survey of Canada (GSC) datum. Between October 1 and June 30 of any year, the minimum operating elevation of Diversion Reservoir shall be 372.0 m, measured at the dam using GSC datum.

With the exception of one non-compliance, BC Hydro complied with Requirement 3. No apparent adverse effects were identified or were expected as a result of the non-compliance.

Reduced drawdown was implemented as specified with the exception of the one non-compliance noted. JORMON-4 is the associated monitoring study conducted to evaluate the effects of reduced drawdown on rainbow trout. Refer to Requirement 9 and 10 for details on monitoring results.

4 Minimum Operating Levels - The licensee shall leave the low-level outlet at Bear Creek Reservoir closed and shall obtain approval of the Comptroller in advance of any draft below 411.0 metres, the full supply level.


The low-level outlet at Bear Creek Reservoir was kept closed; as such, there was no monitoring of this requirement.



46 November 2016



5 Maximum Discharge Rate - The licensee shall ensure that, on a minimum of 4 weekend days during the month of March, the combined maximum discharge rate under licenses FL117999 and FL118000 shall be 30 cubic metres per second (m3/s) between the hours of 06:00 and 18:00. This maximum discharge rate may be exceeded in emergency situations and the Comptroller shall be notified at the earliest possible convenience in this event.


Constrained flows stipulated in this requirement were implemented. JORMON-5 is the associated monitoring study conducted to evaluate the effects on surfing quality, refer to Requirement 9 and 11 for more details on monitoring results.

6 Minimum Flows - The licensee shall release a minimum flow of 0.25 m3/s into Jordan River at the Elliott Dam outlet (PD31684), at all times, commencing within 2 years of the date of this order (hereinafter referred to as the "commencement date"), the works having been altered as per Requirements 1 and 2 above.


The minimum flow release requirement was met. JORMON-1, 2 and 3 are the associated monitoring studies conducted to evaluate the effects of in-stream flows in Jordan River below Elliott Dam and the effect of these flows on target fish species, or their habitat, refer to Requirement 9 and 10 for details on monitoring and results and Requirement 2 for more information on minimum flows and how they relate to physical works.



47 November 2016



7 Alternate Operations - The minimum release specified in Requirement 6 takes precedence over the minimum operating elevation specified in Requirement 3 in the event that both conditions cannot be met. The licensee shall notify the Comptroller when the reservoir elevation falls below that minimum elevation as a result of this precedence.


It was not necessary for BC Hydro to prioritize the minimum release flow over reservoir elevation levels.

8 Monitoring Plan - The licensee shall submit a monitoring plan for acceptance by the Comptroller within three months of the date of this order outlining details of the monitoring proposed, including what is to be measured, the frequency, location and how it is to be reported.

With the exception of the fisheries and surfing quality monitoring plan Terms of Reference not being submitted on time, BC Hydro complied with Requirement 8. No adverse effects were identified or were expected as a result of the delay in the submission of the Terms of Reference.

The Terms of Reference to conduct five monitoring studies were developed and approved by the Comptroller. Monitoring studies were developed with input from regulators, stakeholders and First Nations.



48 November 2016



9 Monitoring - The licensee shall implement monitoring in accordance with the plan as accepted under Requirement 8.

With the exception of a non-compliance because JORMON-4 was not fully implemented in accordance with the approved plan and the Comptroller was not notified, BC Hydro complied with Requirement 9. No adverse effects were identified or were expected as a result of this non-compliance.

Monitoring was implemented as specified in the Terms of Reference with the one exception noted. The last year of JORMON-4 monitoring was planned to include an extensive drawdown to look at the response in aquatic productivity, but this treatment drawdown did not occur for operational reasons.

An additional identified outcome is that for the surf quality monitoring (JORMON-5) a variety of factors (low flows, absence of surfers, marginal wave height and poor weather conditions) limited the monitors ability to gather data on surfing quality under unconstrained flow conditions during odd years, as a result monitoring of unconstrained flow conditions was conducted on several days during even years.



49 November 2016



10 Reporting - The licensee shall provide annual reports to the Comptroller beginning 1 year after the commencement of the monitoring as per the plan accepted in Requirement 8, including the following information: a) Size and abundance of rainbow trout in Lower Jordan River below Elliott Dam. b) Salmonid spawner surveys in Lower Jordan River. c) Fish stress indicators in Diversion Reservoir in comparison to the inventory measured during the preparation of the Jordan River Water Use Plan.


The monitoring conducted by BC Hydro found the following in relation to installation and operations of the hollow cone release valve to release minimum flows (Requirement 1, 2, and 6) and limiting reservoir drawdown as stipulated in Requirement 3:

JORMON-1 found that the flows used in the Water Use Plan overestimated August inflows and underestimated loses to groundwater by approximately 0.1 m3/s. If minimum flows of 0.25 m3/s had been released, this would have resulted in in-stream flows lower than planned (if the assumptions regarding base flows had been correct). However, due to the need to leave the control valve in the open position, releases averaged 0.35 m3/s, which ultimately resulted in the target instream flows expected as a result of the minimum flow releases originally planned (0.25 m3/s) (D.Burt and Associates 2015).

Following the implementation of the flow releases, JORMON-2 found that the density of 1+ and 2+ rainbow trout9 increased, juvenile trout and Coho fry repopulated the copper impacted zone and habitat continuity was improved in the system. Although changes to the condition factor of rainbow trout relative to baseline observations were not observed following flow releases, their condition factor was similar to fish outside the impacted zone (D.Burt and Associates 2015).

9 1+ and 2+ refers to fish that are at least one year old and at least two years old, respectively.



50 November 2016



10

JORMON-3 spawner surveys observed low counts of adult salmon and steelhead in the Lower Jordan River during the study years, however there was an increase in number of Coho present during 2014 surveys. Flow release did not increase quantity of available spawning habitat, but did dilute pollutants enough in some reaches to facilitate rearing (based on fish presence) where it was previously too contaminated (D. Burt and Associates 2015).

JORMON-4 found that there was no significant increase in rainbow trout condition factor within the Diversion Reservoir due to reduced allowable drawdown; however, abundance did increase significantly. It was also found that the fish habitable zone (appropriate levels of dissolved oxygen and temperature) of the reservoir could be negatively impacted by extensive drawdown (D. Burt and Associates 2015).

11 Surfing Reporting - The licensee shall provide annual reports to the Comptroller, beginning 1 year from the effective date of this Order, documenting pertinent information regarding surfing conditions during the days outlined in Requirement 5.


JORMON-5 found that constraints on generation stipulated in Requirement 5 have potential benefit to surfing. However, other factors such as environmental conditions (weather, tides, wind, etc.) greatly limited the ability to predict when flow constraints would successfully improve surf conditions. If all other factors are consistent, constrained flows provide more favourable surf conditions (D. Burt and Associates 2015).

12 Alternate Operations - The licensee shall operate the works in an alternate manner in the event of an emergency, a dam safety requirement, or an extreme hydrological event.

N/A2

Requirement 12 is not measurable.

BC Hydro operated the works in an alternate manner on one occasion when the Diversion Reservoir was drafted below the minimum elevation of 372.0 m for 3 hours in order to prepare for a substantial storm event and forecasted inflows (BC Hydro, 2006).



51 November 2016



13 Deviations from the Order - The emergency operations or other deviations from this order shall be reported to the Comptroller in a timely manner.

With the exception of one deviation not being reported in a timely manner (Comptroller of Water Rights, 2006), BC Hydro complied with Requirement 13. No adverse effects were reported or expected regarding the delay in the reporting of the deviation.

BC Hydro reported emergency operations or other deviations on three occasions. On one occasion, reporting of a deviation, which occurred in January 2005, was not completed until the March 2006 annual report. This was the first year of operation under the WUP Order and reporting expectations were still being defined. Following this delay in reporting BC Hydro have implemented procedures to address reporting requirements and responsibilities which has resulted in no further reporting deviations occurring.

1 A check mark indicates where there is a potential issue. 2 The performance rating is not applicable because this requirement is not measureable. It provides for operational flexibility, but does not stipulate specific actions on the Part

of BC Hydro. Performance Rating System

Non-compliant with adverse effect (occurs when there is an identified or reasonable expectation of adverse effect on social or environmental resources based on documents reviewed and information accessed for the assessment).


Compliant.

Potential Issue?


1



52 November 2016

The Terms of Reference for the fish studies (JORMON-1 through JORMON-4) and recreation (JORMON-5) 1 were submitted 8 months later than specified in the Order, as the development, review and approval 2 process for the Terms of Reference took more time than originally anticipated. This process included the 3 separate reviews and approvals by the Monitoring Committee, the Ministry of Environment, and 4 Fisheries and Oceans Canada before it could be finalized and submitted to the Comptroller. The 5 Comptroller approved the Terms of Reference once they were submitted. 6

There were also several deviations from the operating and reporting requirements. These deviations 7 included failing to meet operational specifications for reservoir levels, and Comptroller notification of 8 drafts below specified levels, and related to a change in the JORMON-4 monitoring program. 9

Issues were encountered with the performance of the water release valve for release of minimum flows. 10 BC Hydro decided to operate the valve in a locked fully open position due to reliability concerns with the 11 backup power system. As a result, flows exceeded the minimum flow limit of 0.25 m3/s, but the 12 minimum flow and timing requirements were met. By 2010 when the backup power system was 13 replaced, corrosion issues with the valve control system prevented BC Hydro from operating it as 14 designed. In order to ensure minimum downstream flows are met, the water release valve continues to 15 be locked open. There is a potential issue because aspects of the overall objective of the Requirement 16 was not achieved and the valve cannot be operated as designed. 17

The issues with the installation of the cone valve meant that it was not possible to confirm the benefits 18 to resident fish in the Lower Jordan River at the minimum flow limit of 0.25 m3/s. The habitat benefits 19 that were observed in the Lower Jordan River were associated with higher flow releases (approximately 20 0.35 m3/s) from the control valve, not the 0.25 m3/s minimum flow release. 21

On one occasion BC Hydro did not report a deviation in a timely manner and potential action is required 22 to clearly define “timely.” Due to their relatively minor nature, the deviations that occurred (late 23 submission of the Terms of Reference, one-time or very infrequent deviations in operating or reporting 24 requirements) do not detract from the overall conclusion that BC Hydro satisfied the requirements and 25 expectations for the Jordan River Order implementation. 26

The following conclusions were made based on monitoring conducted to answer management 27 questions: 28

• The flows predicted for the Lower Jordan River in the Water Use Plan were 258% to 289% higher 29 than the flows subsequently observed due to an overestimation of local inflows and an 30 underestimation of losses to groundwater. As such, it was determined that minimum flow 31 release would need to be 0.39 m3/s instead of 0.25 m3/s in order to achieve the target set for 32 weighted usable area of fish habitat. 33

• The minimum flow release restored habitat continuity throughout the Lower Jordan River and 34 increased abundance, but not average condition factor, of rainbow trout within the Lower 35 Jordan River. 36

• The minimum flow releases did not greatly improve salmon spawning habitat, but could aid in 37 the passage of adult salmonids. 38

• Flow releases did not improve effective incubation habitat for salmonids, but did improve 39 rearing habitat in some areas by diluting deleterious copper concentrations within the Lower 40 Jordan River. 41



53 November 2016

• Reduced allowable drawdown at the Diversion Reservoir was not observed to lead to a 1 change in rainbow trout condition, but a significant increase in abundance of rainbow trout 2 was found. 3

• Extensive drawdown at Diversion Reservoir could negatively affect rainbow trout if the 4 habitable region of the reservoir was drafted. 5

• Constraints on generation could potentially benefit surfing quality at the Jordan River. 6 However, surfing quality appears to be highly dependent on environmental factors such as 7 tidal action, wave size and interval, wind, and weather. 8

This Page Intentionally Left Blank.

55 November 2016

6 References 1

BC Hydro. 2002. Jordan River Water Use Plan – Consultative Committee Report. February. 2

BC Hydro. 2003. Jordan River Water Use Plan. Revised for Acceptance by the Controller of Water Rights. 3 April 30. 4

BC Hydro. 2015. Water Use Plan Order Program Correspondence Log. Database output file. 5

Province of British Columbia. 1998. Water Use Plan Guidelines. Available at: 6 http://www.env.gov.bc.ca/wsd/plan_protect_sustain/water_use_planning/cabinet/wup.pdf 7

Physical Works (Requirements 1 and 2) 8

BC Hydro. 2006. Jordan River Water Use Plan, Monitoring Programs and Physical Works Annual Report: 9 2006. 10

———. 2007. Jordan River Water Use Plan, Monitoring Programs and Physical Works Annual Report: 11 2007. 12

———. 2008a. Jordan River Water Use Plan, Monitoring Programs and Physical Works Annual Report: 13 2008. 14





BC Hydro. 2006. Jordan River Water Use Plan: Physical Works Terms of Reference Water Release 23 Mechanism at Elliott Dam. 24

———. 2007. Jordan River Water Use Plan: Physical Works Terms of Reference, Addendum 1 to 25 JORWORKS-1 Water Release Mechanism at Elliott Dam. 26

———. 2008b. Jordan River Water Use Plan, Jordan River Generating Station Elliott Dam Fish Water 27 Release, Engineering Completion Report JOR06MTC 103. 28

Burt, D. and Associates. 2015. Evaluation of the Environmental Program Ordered for the Jordan River 29 Water Use Plan (Conducted from 2005 to 2011). 30

Order Water Act, Section 39, File No. 0281532 filename: Jordan WUP Order.PDF 31

Operations (Requirements 3, 4, 5, 7, 12, and 13) 32

BC Hydro. 2006. Annual Conveyance Report 2005. 33

———. 2007. Annual Conveyance Report 2006. 34



56 November 2016









BC Hydro. 2006. Email to the Comptroller. March 2, 2006. 9

———. 2008. Email to the Comptroller. September 15, 2008. 10

———. 2012. Email to the Comptroller. September 26, 2012. 11

Comptroller of Water Rights. 2006. Annual Compliance Letter. 12

———. 2007. Annual Compliance Letter. 13








Fisheries (Requirements 8, 9, and 10) 21

BC Hydro. 2006. Jordan River Water Use Plan Monitoring Programs and Physical Works Annual Report: 22 2006. 23

———. 2007. Jordan River Water Use Plan Monitoring Programs and Physical Works Annual Report: 24 2007. 25






57 November 2016



BC Hydro. 2004. Monitoring Program Terms of Reference JORMON#1 LOWER JORDAN RIVER INFLOW 5 MONITORING. 6

———. 2004. Monitoring Program Terms of Reference JORMON#2 FISH INDEX: LOWER JORDAN RIVER. 7

———. 2004. Monitoring Program Terms of Reference JORMON#3 LOWER JORDAN RIVER SALMON 8 SPAWNING ASSESSMENT AND ENUMERATION. 9

———. 2004. Monitoring Program Terms of Reference JORMON#4 DIVERSION RESERVOIR FISH 10 INDEXING. 11

———. 2007. Jordan River Water Use Plan Monitoring Program Terms of Reference: Addendum 1 to 12 JORMON-1 Lower Jordan River Inflow Monitoring. 13



Britney, Erika and Mattock, Bruce. pers. comm. 2015. 18

Burt, D. and Associates. 2006. Lower Jordan River Fish Index Study Year 1 (2005). 19

———. 2007. Lower Jordan River Fish Index Study Year 2 (2006). 20





Burt, D. and Associates. 2015. Evaluation of the Environmental Program Ordered for the Jordan River 25 Water Use Plan (Conducted from 2005 to 2011). 26

Burt, D. and R. Hudson. 2008. Lower Jordan River Inflow Monitoring: Year 2 Results (2007–2008). 27

———. 2009. Lower Jordan River Inflow Monitoring: Year 3 Results (2008–2009). 28

———. 2010. Lower Jordan River Inflow Monitoring: Year 4 Results (2009). 29

———. 2012. Lower Jordan River Inflow Monitoring: Year 5 Results (2010). 30

———. 2013. Lower Jordan River Inflow Monitoring: Year 6 Results (2005-2011). 31

Cascadia Biological Services. 2006. Lower Jordan River Salmon Spawning Assessment and Enumeration 32 Year 1. 33



58 November 2016

———. 2007. Lower Jordan River Salmon Spawning Assessment and Enumeration Year 2. 1





Comptroller of Water Rights. 2015. Miscellaneous communications. Comments on draft Gaps Analysis 6 results. 7

Hudson, R. 2006. Lower Jordan River Inflow Monitoring: Final Report 2005-06 Year 1. 8

Leake, A. miscellaneous communications, 2016 9

Lough, MJ, RB Collins, SE Rutherford. 2006. Diversion Reservoir Fish Indexing Year 1- 2005. 10

———. 2007. Diversion Reservoir Fish Indexing Year 2- 2006. 11


———. 2009. Diversion Reservoir Fish Indexing Year 4 - 2008. 13



Recreation (Requirements 8, 9, and 11) 16

BC Hydro. 2004. Jordan River Water Use Plan Monitoring Program Terms of Reference: JORMON #5 17 Monitoring Surfing Quality Below the Jordan River Generating Station. 18

———. 2006. Jordan River Water Use Plan: Monitoring Programs and Physical Works Annual Report. 19







———. 2004. Jordan River Water Use Plan, Monitoring Terms of Reference, JORMON-5: Monitoring 26 Surfing Quality below the Jordan River Generating Station. 27

Britney, Erika and Mattock, Bruce. pers. comm. 2015. 28

Burt, D. and Associates 2015. Evaluation of the Environmental Program Ordered for the Jordan River 29 Water Use Plan (Conducted from 2005 to 2011). 30



59 November 2016

Kelly, John. 2006. Correspondence with Pieter Bekker, Deputy Comptroller of Water Rights, Victoria, 1 B.C., regarding Jordan River System Water Use Plan Monitoring Programs and Physical Work Annual 2 Report. 3

Recreational Resources Limited. 2006. JORMON-5, Monitoring Surfing Quality Below the Jordan River 4 Generating Station, February–April 2006. September. Prepared for BC Hydro. 5

———. 2007. JORMON-5, Monitoring Surfing Quality Below the Jordan River Generating Station (Year 6 2), February–April. December. Prepared for BC Hydro. 7

———. 2008. JORMON-5, Monitoring Surfing Quality Below the Jordan River Generating Station (Year 8 3), March 1-30. April–Revised December. Prepared for BC Hydro. 9

———. 2009. JORMON-5, Monitoring Surfing Quality Below the Jordan River Generating Station (Year 10 4), March 1–April 12. December. Prepared for BC Hydro. 11

———. 2010. JORMON-5, Monitoring Surfing Quality Below the Jordan River Generating Station (Year 12 5), March 5–April 1. 2006. September. Prepared for BC Hydro. 13

———. 2013. JORMON-5, Monitoring Surfing Quality Below the Jordan River Generating Station (Year 14 6), March–April, 2011. October. 15

A-1 November 2016

Appendix A: Original Water Use Plan Order 1

Provided as a separate PDF 2

File No. 0281532

Province of British Columbia Water Act

Order Water Act

Section 39

WHEREAS British Columbia Hydro and Power Authority (BC Hydro) is the operator of the Jordan River hydroelectric system, in respect of which it holds the following 5 licences: FL117999, FL118000, FL118001, FL118004, FLl18005;and

WHEREAS the licensee has submitted the Jordan River Project Water Use Plan, which recommends changes to the operations of Jordan River hydroelectric system and which are intended to provide benefits to fisheries and wildlife habitat and recreation; and

WHEREAS I have accepted the Jordan River Project Water Use Plan dated Apri130, 2003; and

WHEREAS BC Hydro has proposed a monitoring programme to determine whether operating the facility in accordance with the operating parameters and procedures in the Jordan River Water Use Plan will provide the expected benefits;

I HEREBY ORDER THAT:

1. The licensee shall submit, to the Comptroller of Water Rights, design plans, prepared by a professional engineer registered in British Columbia, for the alteration of works to enable a flow release into Jordan River through Elliott Dam.

2. The licensee shall alter the works in accordance with the approved plans after leave is given in writing by the Comptroller of Water Rights.

3. Between July 1 and September 30 of any year, the minimum operating elevation of Diversion Reservoir shall be 376.0 m, measured at the dam. using the Geodetic Survey of Canada (GSC) datum. Between October 1 and June 30 of any year, the minimum operating elevation of Diversion Reservoir shall be 372.Om, measured at the dam using the Geodetic Survey of Canada (GSC) datum.

. .... 2

23 June 2004

4. The licensee shall leave the low level outlet at Bear Creek Reservoir closed and shall obtain approval of the Comptroller of Water Rights in advance of any draft below 411.0 metres, the full supply level.

5. The licensee shall ensure that, on a minimum of 4 weekend days during the month of March, the combined maximum discharge rate under licences FLl17999 and FLl18000 shall be 30 cubic metres per second between the hours of 06:00 and 18:00. This maximum discharge rate may be exceeded in emergency situations and the Comptroller of Water Rights shall be notified at the earliest possible convenience in this event;

6. The licensee shall release a minimum flow of 0.25 cubic metres per second into Jordan River at the Elliott Dam outlet (PD31684), at all times, commencing within 2 years of the date of this order (hereinafter referred to as the "commencement date"), the works having been altered as per conditions 1 and 2 above;

7. The minimum release specified in condition 6 above takes precedence over the minimum operating elevation specified in condition 3, in the event that both conditions cannot be met. The licensee shall notify the Comptroller of Water Rights when the reservoir elevation falls below that minimum elevation as a result of this precedence. .

8. The licensee shall submit a monitoring plan for acceptance by the Comptroller within three months of the date of this order outlining details of the monitoring proposed, including what is to be measured, the frequency, location and how it is to be reported.

9. The licensee shall implement monitoring in accordance with the plan as accepted under condition 8 above.

10. The licensee shall provide annual reports to the Comptroller beginning one year after the commencement of the monitoring as per the plan accepted in condition 8 above, including the following information: a) size and abundance of rainbow trout in lower Jordan River below Elliott

dam, b) salmonid spawner sllrveys in Lower Jordan·River, c) fish stress indicators in Diversion Reservoir in comparison to the

inventory measured during the preparation of the Jordan River Water Use Plan.

11. The licensee shall provide annual reports to the Comptroller beginning one year from the effective date of this Order documenting pertinent information regarding surfing conditions during the days outlined in condition 5 above.

12. The licensee may operate the works in an alternate manner in the· event of an emergency; a dam safety requirement, or an extreme hydrologic event.

13. All emergency operations or other deviations from this ordered shall be reported to the Comptroller of Water Rights in a timely manner.

Dated at Victoria, B.C., this~day ofJu.\~ ,2004.

Glen Davidson, P. Eng Deputy Comptroller of Water Rights

B-1 November 2016

Appendix B: Crosswalk of Jordan River System Water Use Plan Objectives and Recommendations, 1

and Order Requirements 2

As per Step 4 of the Water Use Plan Guidelines, the Consultative Committee stated specific objectives for the desired outcomes in dealing with 3 water issues. In defining the objectives, the Consultative Committee articulated what they sought to achieve through incremental changes in BC 4 Hydro operations (e.g., maximize fish production). The Consultative Committee then developed different operating alternatives for addressing 5 the various objectives compared their costs and benefits before providing consensus recommendations regarding operating parameters. The 6 proposed conditions in the Water Use Plan reflected the consensus recommendations of the Consultative Committee, and the Water Use Plan 7 was accepted by the Comptroller in July 2004. 8

Water Use Plan Objective Consultative Committee Recommendation Order Requirement

Maximize the value of power generation. (Report of the Consultative Committee Executive Summary)

N/A No direct connection between Water Use Plan Order requirements and this objective. (Jordan Water Use Plan Order. File #0281532)

Increase socio-economic welfare of the local community (Report of the Consultative Committee Executive Summary)

N/A No direct connection between Water Use Plan Order requirements and this objective. (Jordan Water Use Plan Order. File #0281532)

Maintain recreational opportunities in the reservoirs. (Report of the Consultative Committee Executive Summary)

BC Hydro shall not operate the low level outlet in a manner which drafts the elevation below 411 m, except in emergency situations. (Report of the Consultative Committee, Table 7-1)

4. The licensee shall leave the low level outlet at Bear Creek Reservoir closed and shall obtain approval of the Comptroller of Water Rights in advance of any draft below 411.0 metres, the full supply level. (Jordan Water Use Plan Order. File #0281532)

Maximize resident fish populations, invertebrates and aquatic life in the reservoirs. (Report of the Consultative Committee Executive Summary)

N/A 1. The licensee shall submit, to the Comptroller of Water Rights, design plans, prepared by a professional engineer registered in British Columbia, for the alteration of works to enable a flow release into Jordan River through Elliott Dam. (Jordan Water Use Plan Order. File #0281532)

N/A 2. The licensee shall alter the works in accordance with the approved plans after leave is given in writing by the Comptroller of Water Rights. (Jordan Water Use Plan Order. File #0281532)



B-2 November 2016


Maximize resident fish populations, invertebrates and aquatic life in the reservoirs. (Report of the Consultative Committee Executive Summary) – Continued

Minimum normal elevation of 376 m (1 July-30 Sep). Minimum normal elevation of 372 m (1 Oct-30 June). BC Hydro shall not operate the reservoir below the stated minimum elevations except in emergency situations, when undertaking works associated with maintaining the integrity of the dam for dam safety reasons or in low water situations to provide flows downstream. In low water situations, when the reservoir elevation is expected to drop below the normal minimum operating level, BC Hydro shall notify the appropriate federal and provincial agencies. BC Hydro will then proceed with providing a 0.25 cubic metres per second (m3/s) flow below the Elliott Dam during the 4-year river monitoring program, or reduce flows and reservoir levels according to a flow decision rule when the monitoring program is not in place. (Report of the Consultative Committee, Table 7-1)

3. Between July 1 and September 30 of any year, the minimum operating elevation of Diversion Reservoir shall be 376.0 m, measured at the dam using the Geodetic Survey of Canada (GSC) datum. Between October 1 and June 30 of any year, the minimum operating elevation of Diversion Reservoir shall be 372.0m, measured at the dam using the Geodetic Survey of Canada (GSC) datum. (Jordan Water Use Plan Order. File #0281532)



B-3 November 2016


BC Hydro shall not operate the low level outlet in a manner which drafts the elevation below 411 m, except in emergency situations. In low water situations, when the reservoir elevation is expected to drop below the normal minimum operating level, BC Hydro shall notify the appropriate federal and provincial agencies. BC Hydro will then proceed with providing a 0.25m3/s flow below the Elliott Dam during the 4-year river monitoring program, or reduce flows and reservoir levels according to a flow decision rule when the monitoring program is not in place. (Report of the Consultative Committee, Table 7-1)

4. The licensee shall leave the low level outlet at Bear Creek Reservoir closed and shall obtain approval of the Comptroller of Water Rights in advance of any draft below 411.0 metres, the full supply level. (Jordan Water Use Plan Order. File #0281532)


Base target flow of at least 0.25 m3/s with an accepted deviation to 0.225 m3/s. In low water situations, this flow may need to be reduced (see Diversion Reservoir Section). (Report of the Consultative Committee, Table 7-1)

6. The licensee shall release a minimum flow of 0.25 m3/s into Jordan River at the Elliott Dam outlet (PD31684), at all times, commencing within 2 years of the date of this order (hereinafter referred to as the "commencement date"), the works having been altered as per conditions 1 and 2 above. (Jordan Water Use Plan Order. File #0281532)

N/A 7. The minimum release specified in condition 6 above takes precedence over the minimum operating elevation specified in condition 3, in the event that both conditions cannot be met. The licensee shall notify the Comptroller of Water Rights when the reservoir elevation falls below that minimum elevation as a result of this precedence. (Jordan Water Use Plan Order. File #0281532)



B-4 November 2016


N/A 8. The licensee shall submit a monitoring plan for acceptance by the Comptroller within three months of the date of this order outlining details of the monitoring proposed, including what is to be measured, the frequency, location and how it is to be reported. (Jordan Water Use Plan Order. File #0281532)

N/A 9. The licensee shall implement monitoring in accordance with the plan as accepted under condition 8 above. (Jordan Water Use Plan Order. File #0281532)


Fish Index: Lower Jordan River - Determine direction of rainbow trout standing stock dynamics (fish size and abundance) following 'treatment' with a base flow release. Qualitative Habitat Survey for Salmonids in the Lower Jordan River - Monitor for successful spawning and rearing of anadromous salmonids in the Lower Jordan River below the first passage barrier. Fish Index: Diversion Reservoir - Gill netting and minnow trapping at end of each growth season to assess indicators of stress. Includes associated water chemistry (dissolved oxygen and temperature). Includes a planned drawdown to elicit response. (Report of the Consultative Committee, Table 8-1)

10. The licensee shall provide annual reports to the Comptroller beginning one year after the commencement of the monitoring as per the plan accepted in condition 8 above, including the following information: a) size and abundance of rainbow trout in lower Jordan River below Elliott dam, b) salmonid spawner surveys in Lower Jordan River, c) fish stress indicators in Diversion Reservoir in comparison to the inventory measured during the preparation of the Jordan River Water Use Plan. (Jordan Water Use Plan Order. File #0281532)



B-5 November 2016


Maximize the quality of surfing. (Report of the Consultative Committee Executive Summary)

BC Hydro shall plan to operate the generation with a discharge of not greater than 30 m3/s from 6:00 a.m. to 6:00 p.m. on a minimum of 4 weekend days during the month of March. Higher releases are permissible when required to manage basin inflow, or emergency situations. A surfing representative may advise BC Hydro of a good weekend day in March and BC Hydro shall make reasonable attempts to apply this constraint on that day. (Report of the Consultative Committee, Table 7-1)

5. The licensee shall ensure that, on a minimum of 4 weekend days during the month of March, the combined maximum discharge rate under licenses FL117999 and FL118000 shall be 30 m3/s between the hours of 06:00 and 18:00. This maximum discharge rate may be exceeded in emergency situations and the Comptroller of Water Rights shall be notified at the earliest possible convenience in this event. (Jordan Water Use Plan Order. File #0281532)

N/A 8. The licensee shall submit a monitoring plan for acceptance by the Comptroller within three months of the date of this order outlining details of the monitoring proposed, including what is to be measured, the frequency, location and how it is to be reported. (Jordan Water Use Plan Order. File #0281532)

Maximize the quality of surfing. (Report of the Consultative Committee Executive Summary) - Continued

N/A 9. The licensee shall implement monitoring in accordance with the plan as accepted under condition 8 above. (Jordan Water Use Plan Order. File #0281532)

N/A 11. The licensee shall provide annual reports to the Comptroller beginning one year from the effective date of this Order documenting pertinent information regarding surfing conditions during the days outlined in condition 5 above. (Jordan Water Use Plan Order. File #0281532)

Optimize littoral habitat in reservoirs and riparian habitat along streams for wildlife. (Report of the Consultative Committee Executive Summary)

N/A No direct connection between Water Use Plan Order requirements and this objective.



B-6 November 2016


No direct connection to a Water Use Plan objective.

N/A 12. The licensee shall operate the works in an alternate manner in the event of an emergency, a dam safety requirement, or an extreme hydrological event. (Jordan Water Use Plan Order. File #0281532)

No direct connection to a Water Use Plan objective.

N/A 13. The emergency operations or other deviations from this order shall be reported to the Comptroller of Water Rights in a timely manner. (Jordan Water Use Plan Order. File #0281532)

1

C-1 November 2016

Appendix C: Program Evaluation Approach Used for the BC Hydro 1

Water Use Plan Order Reviews 2

Program evaluation is a systematic method for gathering, evaluating, and using information to answer 3 questions about the effectiveness and/or efficiency of programs, projects, and/or policies. Evaluations 4 are typically conducted by a third party to ensure objectivity. The program evaluation needs to have a 5 clearly defined scope, objectives, and criteria for assessing the performance of the program. Program 6 evaluations use multiple lines of evidence to provide a high degree of accuracy and validity to the 7 evaluation findings. Not all types of information are relevant or applicable to all program evaluations. As 8 a result, scoping is very important to ensure that the evaluation is appropriate for the nature, size, and 9 type of program to be evaluated. 10

Typical lines of evidence and how they were used in the Water Use Plan Order Evaluation Program 11 (Order Review Program) evaluation are shown in Table C1. 12

Table C1. Typical Lines of Evidence and Application to BC Hydro Order Review Program Evaluation 13 Information Use in Order Review Program Document reviews Included – Phase 1 Order Review Program.

Key informant interviews (interviews with individuals involved in program management or delivery)

Included – Phase 1 Order Review Program.

Regulatory agencies and First Nation consultations

Included at the initiation of Phase 1, and additional consultations will be conducted in Phase 2 to validate evaluation results.

Surveys Included in Phase 2 as a questionnaire.

Performance monitoring Not included within the Order Review Program, but performance monitoring has been undertaken throughout the duration of the Water Use Plan (e.g., annual reporting). This information has been reviewed as part of the Order Review.

Case studies (in-depth review of selected elements of a program or specific projects)

Not included within the Order Review Program but included as part of monitoring studies involving detailed investigations of the program impacts (e.g., assessment of changes in fish population) over a period of time to assess project impacts. A synthesis report reviewing completion and outcomes of the monitoring studies is prepared by a third party (Appendix F).

Benchmark studies Due to the unique nature of the Orders, the Order Review does not include or reference studies to benchmark other Orders. As successive Order Reviews are conducted, past Order Reviews will be taken into consideration where applicable.

Focus groups May be included in Phase 1 or 2 to validate evaluation results and to develop conclusions and recommendations.

Benefit-cost analysis This has not been included in the scope of this review, as cost vs. benefit was not an Order Review issue.

14

D-1 November 2016

Appendix D: Water Use Plan Order Review Process – Finding 1

Development 2

Figure D1 outlines the Water Use Plan Order Review (Order Review) process. The objectives of the Order 3 Reviews are to: 4

1. Synthesize and document the outcomes of the physical works and monitoring studies conducted 5 in response to the Orders. 6

2. Evaluate BC Hydro’s compliance with the Orders. 7

3. Identify any areas where it was not possible to fully comply and why. 8

4. Compare Water Use Plan-recommended costs to actuals and provide a variance analysis where 9 required. 10

5. Describe what remaining actions, if any, are required to fulfil the Water Use Plan Order 11 Requirements (Requirements). 12

6. As required, prepare recommendations for next steps. 13

This appendix provides additional information on each of the Order Review process steps followed 14 during Part 1 of the process to develop the Findings Report (step 6). 15

1. Kickoff Meeting to Identify Priority Issues 16

The purpose of this step is to ensure that the scope of the Order Review is appropriate for the Order and 17 the priority issues that have arisen as a result of its implementation. The kickoff meeting includes BC 18 Hydro management, technical and communications staff involved in the Order Review Program, and the 19 ICF-Triton team. Kickoff is also used to conduct an initial interview with BC Hydro staff involved in Order 20 implementation, verify the regulators and First Nations who will be involved in the Order Review, and 21 establish a schedule for the review. 22



D-2 November 2016

Figure D1. Issue Analysis and Development of Recommendations1

2



D-3 November 2016

2. Confirm Requirements 1

This step focuses on developing a comprehensive inventory of Requirements and monitoring study 2 management questions and verifying it with BC Hydro and regulators to be sure the basis for the Order 3 Review is firmly established. The inventory of Requirements is compiled based on review of: 4

• Order (Appendix A), 5 • Monitoring Terms of Reference, 6 • Monitoring reports, 7 • Annual reports on work conducted since the Water Use Plan was issued, 8 • Conveyance reports and water management constraints data, 9 • Compliance letters, 10 • British Columbia Comptroller of Water Rights (Comptroller) communications clarifying or 11

approving modifications, 12 • Variances10, and 13 • Other foundational documentation as applicable (e.g., Consultative Committee Report, Water 14

Use Plan). 15

In addition, Requirements are reviewed to identify and confirm Requirements that are not measurable, 16 e.g., a requirement that provides BC hydro with operational flexibility, but does not also specify 17 reporting or notification requirements, such as allowing BC Hydro to operate works in an alternate 18 manner in the event of an emergency or a dam safety incident. The inventory is reviewed internally by 19 BC Hydro technical staff and project managers, and verified with the following regulatory agencies: 20 Comptroller, B.C. Ministry of Environment, B.C. Ministry of Energy and Mines, and Department of 21 Fisheries and Oceans. 22

3. Identify Performance Measures 23

Based on the inventory, standard performance measures were assigned and detailed verification 24 questions were developed to evaluate the procedural, technical, and financial aspects of BC Hydro 25 activities relative to the Requirements. Table D1 presents the standardized set of Performance 26 Measures that have been developed based on the Program-wide Requirements for use throughout the 27 Order Review Program. 28

A Common Performance Measure may be used more than once in each Order Review. For example: 29

• When independent Requirements exist for monitoring studies associated with water flows and 30 cultural resources, and /or 31

• When separate budgets were approved for different activities. 32

10 A variance is temporary or permanent modification to an Order Requirement (e.g., changes to timelines or changes

in ramping rates) or associated Terms of Reference requested by BC Hydro and granted by the Comptroller.



D-4 November 2016

Table D1: Order Review Standard Performance Measures 1

Type of Requirement

Type of Requirement / Objective

Form of Evaluation Common Performance Measure

Type of Response

Gap Analysis

Monitoring Management Question

Outcome Did the monitoring answer the management question(s)?

Yes/No/ Not Fully Met

Planning Approach (Terms of Reference)

Process/ Implementation

Were plan(s) developed and submitted in accordance with requirements?


Execution/ Reporting


Was the monitoring/reporting completed per design?


Budget Process/ Implementation

Was the monitoring completed on budget?


Operational Flow(s)/ Level(s)/ Control(s) and timing of these


Were operational specifications and timing requirements met as prescribed (flows, reservoir levels, volume[s], control specification[s], restriction[s])?


Reporting Process/ Implementation

Were required report(s) and notification(s) completed and submitted as required?


Physical Works Design(s) Process/ Implementation

Were design(s) developed and submitted in accordance with requirements?


Construction Process/ Implementation

Were the works constructed/implemented as required/on schedule/as designed?


Reporting Process/ Implementation

Were required report(s) and notification(s) completed as required?


Evaluation – Synthesis

Impact Based on monitoring results, have the operational requirement(s) resulted in a beneficial change to the target resource (e.g., fish, archaeological, recreation quality)?


The performance measures and verification questions support systematic determination of performance 2 relative to the Requirements, and the use of standard performance measures helps to ensure that 3 responses are straightforward and succinct. These measures provide an appropriate level of detail to 4 characterize adherence to Orders and the effectiveness of Requirements relative to resource priorities. 5



D-5 November 2016

4. Collect Data on Performance Measures 1

Performance relative to each Requirement is determined by an evaluator with applicable subject matter 2 expertise as described below. 3

a. Findings relative to each performance measure are developed by comparing the evidence contained 4 in the documentation compiled in step 2 against each performance measure to determine whether 5 it was satisfied. Information in the compiled documentation is also confirmed and clarified, as 6 needed, through follow-up interviews with key staff to ensure accuracy of each finding. Findings are 7 then reviewed together to determine a performance rating (Table D2) and draw a conclusion 8 regarding BC Hydro compliance with each Requirement. 9

b. Outcomes (positive, neutral, or negative; intended or unintended) resulting from the Order 10 Requirements are reviewed and documented. Intended outcomes need to be consistent with the 11 Water Use Plan objectives. These outcomes are determined based on review of actual data or 12 anecdotal observations based on documents reviewed and information accessed for the Order 13 Review (e.g., synthesis or monitoring reports). 14

c. Potential Issue as a result of BC Hydro’s compliance is also assessed: 15

• A Potential Issue occurs if an identified or reasonable expectation of adverse effect on social or 16 environmental resources occurs, regardless of if BC Hydro is compliant or not. 17

• A Potential Issue occurs if an objective of a mandated action defined by a Requirement under 18 the Order, and approved by the Comptroller was not achieved. 19

d. Conclusions are developed by first developing a finding relative to each performance measure 20 associated with that Requirement. The findings are then reviewed together to determine a 21 performance rating (Table D2) and draw a conclusion regarding BC Hydro compliance with each 22 Requirement. 23

Table D1. Performance Rating System 24

Non-compliant with adverse effect (occurs when there is an identified or reasonable expectation of adverse effect11 on social or environmental resources based on documents reviewed and information accessed for the assessment).


Compliant.

25

Potential Issue?


Performance rating for each Requirement is determined as follows: 26

11 An adverse effect is an undesirable effect to social or environmental resources



D-6 November 2016

Compliant 1 • BC Hydro is deemed to be compliant with its Water Use Plan Order if all actions mandated 2

within a Requirement were completed. This includes any actions that were to be defined by a 3 Requirement under the Order, and approved by the Comptroller. For example, where the Order 4 required a monitoring study be designed and conducted, the study was designed by BC Hydro, 5 and then approved by the Comptroller. BC Hydro subsequently completed the study as 6 approved. 7

• If the actions mandated within a Requirement were completed but did not achieve the expected 8 outcome, BC Hydro is compliant with the Requirement. For example: if monitoring studies 9 designed to answer management questions were completed as designed and approved but did 10 not answer or fully answer all management questions, BC Hydro is considered to be compliant 11 with the related Requirement. 12

• If deviations from the Order occurred under a variance, BC Hydro is compliant with the 13 Requirement. Only a deviation from the Order without an approved variance is considered a 14 non-compliance. 15

• BC Hydro is deemed to be non-compliant if it failed to complete all actions mandated within a 16 Requirement. For example, if one of a series of mandated actions either in the text of the Order 17 or subsequently agreed to as part of a monitoring study was not completed. 18

• If an identified or reasonable expectation of adverse effect12 on social or environmental 19 resources occurs based on documents reviewed and information accessed for the Order Review 20 and if all actions mandated within a Requirement were completed, BC Hydro is deemed to be 21 compliant. However, the adverse effect would be noted as a “negative outcome” and the need 22 to identify potential follow-up actions identified. 23

Non-compliant with no adverse effect 24 • Non-compliant with no adverse effect occurs when there is no identified or reasonable 25

expectation of adverse effect on social or environmental resources based on documents 26 reviewed and information accessed for the assessment. 27

Non-compliant with adverse effect 28 • Non-compliant with adverse effect occurs when there is an identified or reasonable expectation 29

of adverse effect on social or environmental resources based on documents reviewed and 30 information accessed for the assessment. 31

5. Gap Analysis Informed by Performance Measures 32

A Gap Analysis is a tool that provides BC Hydro and regulators with a high-level overview of initial 33 findings based on information provided to the independent evaluation team. The Gap Analysis is used to 34 do the following: 35

• Provide a preview of the more detailed findings that will be included in the Findings Report. 36 • Verify initial findings with the Comptroller and BC Hydro. 37 • Identify missing information or discrepancies in the interpretation of Requirements or the Terms 38

Of Reference. 39

12 An adverse effect is an undesirable effect to social or environmental resources.



D-7 November 2016

• Identify and prompt preliminary discussion of issues, potential alternatives, and potential 1 recommendations with the Comptroller and regulators. 2

The Gap Analysis forms the basis for the Findings Report. Feedback from BC Hydro and the Comptroller 3 is addressed to ensure that there is general agreement on the findings methodology before the 4 evaluation team begins preparing the Findings Report. 5

6. Findings Report 6

Part 1 of the Order Review process culminates in the preparation of a report that provides findings-7 based on documentation of activities undertaken by, or on behalf of, BC Hydro to comply with the Order 8 and the outcomes of those activities. 9

The purpose of the Findings Report is to respond to step 13 of the Water Use Plan process and provide a 10 complete, factual record of BC Hydro’s compliance with the Orders. Specifically, it is designed to: 11

• Summarize BC Hydro’s compliance with the Orders. 12 • Identify areas where it was not possible to fully comply, reasons why, and the associated effect. 13 • Identify the outcomes of BC Hydro’s compliance with the Orders. 14 • Identify actions, if any, still needed to fully satisfy the Requirements. 15 • Assess financial performance relative to original commitments made by BC Hydro. 16

The Findings Report also describes whether the monitoring program developed during implementation 17 of the Orders successfully answered the management questions and highlights what was learned. 18 Because the Findings Report focuses on factual information, it does not identify new issues or 19 alternatives, or make recommendations for next steps. Analysis of issues and development of 20 recommendations will occur following the 60-day public review and comment period. 21

Financial analysis included in the Findings Report has been limited to comparison of direct and indirect 22 costs from design and implementation of monitoring or works projects versus historical budget 23 estimates. Changes in power generation/related revenue per year have not been included as a part of 24 the financial analysis. Annual power generation at each facility depends on many variables including 25 rainfall fluctuations, and the facilities are operated as a part of the broader electricity grid subject to 26 energy demand and pricing which are not tied to the operation of individual generation operations. If 27 impacts of Order compliance on power generation is raised as a priority issue during Part 2 of the Order 28 Review process, then the need for further analysis will be decided on a case-by-case basis. The scope of 29 this Findings Report is limited to the BC Hydro actions conducted in response to the Order and is based 30 solely on data and documentation produced by, or on behalf of, BC Hydro to comply with the Order, 31 notes from interviews with BC Hydro staff, and feedback from the Comptroller. Independent data 32 collection or observation to verify monitoring study findings was not performed. Similarly, statements 33 regarding the benefit of operating constraints on target resources are based on monitoring 34 documentation, interviews with BC Hydro technical staff, and professional judgement. These statements 35 are solely intended as comparisons of reported versus expected effects. 36

E-1 November 2016

Appendix E: Table of Jordan Monitoring Studies and Associated Management Questions 1

Table E1. Jordan Monitoring Studies and Associated Management Questions 2

Terms of Reference Summary of the Monitoring Study Objectives of the Monitoring Study Key Management Questions

JORMON-1 Monitoring study to confirm predicted downstream flows and assess current flow effects in the Lower Jordan River, and assess habitat connectivity, with and without a fish flow release.

Assess the Water Use Plan Order decision to release a minimum flow of 0.25 cubic metres per second (m3/s) into the lower Jordan River. Use instream flow measurements as the performance measure.

How accurate were the assumptions of local inflows used for Water Use Plan recommendations? What implications, if any, are there on the Water Use Plan recommendations based on revised inflow data? What are the reasons for the differences, if any, between the monitored and modelled flows?

JORMON-2 Monitoring study to assess and compare habitat connectivity and fish condition of rainbow trout populations in the Lower Jordan River (below Elliott Dam) between the current condition and a minimum flow release of 0.25 m3/s fish flow release from Elliott Dam.

Assess the Order decision to release a minimum flow of 0.25 m3/s into the lower Jordan River. Use stock abundance and fish condition as performance measures.

Does the flow release restore habitat continuity (i.e., are all habitat units connected by flowing water)? How will the planned flow releases affect the standing stock of the rainbow trout population? How will the planned flow releases affect the distribution of fish condition (weight to length) by age within the rainbow trout population?

JORMON-3 Monitoring study to assess and compare salmon spawning use and effective incubation habitat.

Assess the Water Use Plan decision to increase flows in the lower Jordan River from leakage/local inflows to greater than or equal to 0.25 m3/s. Use spawning success (number of returns to out-migrants) as the performance measure.

Will the planned flow releases improve spawning habitat for salmon and steelhead in the anadromous reaches of the Lower Jordan River? Will the planned flow releases improve effective incubation habitat for spawning salmon and steelhead? What effects, if any, do the planned flow releases have on chronic toxicity of rearing and incubating salmonids?



E-2 November 2016

Terms of Reference Summary of the Monitoring Study Objectives of the Monitoring Study Key Management Questions

JORMON-4 Monitoring study to assess fish condition response to an opportunistic and extensive reservoir drawdown during the summer months in comparison to conditions recommended in the Water Use Plan.

Evaluate the effects of extensive drawdown on Diversion Reservoir. Use rainbow trout fish condition as the performance measure.

What are the benefits to rainbow trout condition associated with a reduced allowable drawdown? What are the impacts on rainbow trout condition associated with a prolonged extensive drawdown?

JORMON-5 Assess and compare the quality of surfing at the mouth of the Jordan River between unconstrained and constrained operations during March.

Assess the Water Use Plan decision to constrain maximum discharge opportunistically during the surfing season using surf quality as the performance measure.

How do constraints on generation benefit surfing quality at Jordan River?

1

F-1 November 2016

Appendix F: Synthesis Report 1

Provided as a separate PDF2

G-1 November 2016

Appendix G: Jordan Water Use Plan Order Implementation Timeline 1

Organized chronologically. 2

Table G1. Jordan Water Use Plan Order Implementation Timeline 3

Date Requirement Topic Milestone/Item Description

2002 All All Jordan River System Water Use Plan Consultative Committee Report produced.

February 2002 All All Jordan River System Water Use Plan was submitted to the British Columbia Comptroller of Water Rights (Comptroller).

July 20, 2004 All All Jordan Order signed by the Comptroller. BC Hydro was ordered to implement the conditions proposed in the Jordan River System Water Use Plan and prepare the monitoring programs and physical work Terms of Reference.

October 20, 2004 8 Fish, Recreation

Monitoring Terms of Reference due to Comptroller for approval.

December 2004 8 Fish, Recreation

JORMON-1 through JORMON-5 Terms of Reference prepared for review and approval.

2005 Fish Monitoring associated with JORMON-1 through JORMON-4 started.

January 17, 2005 3 Works Diversion Reservoir water level dropped below the specified 372.0 metres (m) due to human error. The reservoir was drafted below 372.0 m for approximately 3 hours in preparation for a substantial storm event and forecasted inflows.

February 25, 2005 8 Fish, Recreation

The Comptroller was notified by BC Hydro regarding revised delivery dates for the Terms of Reference.

March 16, 2005 8 Fish Department of Fisheries and Oceans signed off on JORMON-1 through JORMON-4.

March 31, 2005 8 Fish Ministry of Environment signed off on JORMON-1 through JORMON-4.

May 19, 2005 8 Fish, Recreation

BC Hydro notified the Comptroller that the Terms of Reference would be submitted in June 2005.

June 10, 2005 Fish, Recreation

JORMON-1 through JORMON-5 submitted to the Comptroller.


JORMON-1 through JORMON-5 resubmitted to the Comptroller.


JORMON-1 through JORMON-5 approved by the Comptroller.

2005 Fish Monitoring associated with JORMON-1 through JORMON-4 started.

2006 6 Works Initiation of fish release pipe, pneumatic gate valve, and gauging instrumentation.



G-2 November 2016

Date Requirement Topic Milestone/Item Description

March 2, 2006 3 Works Comptroller was notified of the January 17, 2005, Diversion Reservoir water level non-conformance.

May 31, 2006 2 Works BC Hydro requested a schedule extension for commencement of minimum flow releases until July 20, 2007.

July 14, 2006 The revised physical work Terms of Reference was submitted to the Comptroller as the construction schedule would be delayed 1 year until Spring 2007.

July 20, 2006 6 Works, Fish Commencement date of minimum flow releases specified in the Order.

July 20, 2006 1 Works, Fish Comptroller approved schedule extension for commencement of minimum flow releases until June 30, 2007.

September 18, 2006 1 Works Comptroller approved revised JORWORK-1 Terms of Reference.

May 28, 2007 A study cost increase was approved for the JORMON-1 Terms of Reference.

July 15, 2007 BC Hydro requested an extension in the schedule for commencing minimum flow releases until October 15, 2007, and a Terms of Reference revision for a cost increase for JORWORK-1.

July 16, 2007 BC Hydro requested a schedule extension for commencement of minimum flow releases until October 15, 2007.

July 24, 2007 1 Works Comptroller approved budget increase for JORWORK-1 and schedule extension for commencement of minimum flow releases until October 15, 2007.

October 2, 2007 2 Works BC Hydro requested a schedule extension for commencement of minimum flow releases until January 30, 2008.

October 29, 2007 2 Works, Fish Comptroller approved schedule extension for commencement of minimum flow releases until January 30, 2008.

November 20, 2007 A revision to JORMON-1 costs was requested in consideration of increased costs in start-up, reporting, and field work resulting from changing contractors.

January, 2008 2 Works Construction of fish release pipe, pneumatic gate valve, and gauging instrumentation completed.

January 2008 6 Works Minimum flow release from Elliott Dam commenced prior to the ordered date of January 30, 2008.

April 24, 2008 The revised JORMON-1 costs were approved.

September 2008 3 Works Between September 14 and 19, 2008, the Diversion Reservoir water level dropped below the specified 376.0 m due to human error during preparations to



G-3 November 2016

Date Requirement Topic Milestone/Item Description take the Jordan generating unit out of service, which lead to the reservoir being drafted 0.5 m below the 376.0 m minimum elevation. The Comptroller was notified of this non-conformance, and the initial and long-term corrective action that was taken on September 15, 2008.

December 12, 2008 1 Works Engineering Completion Report prepared and submitted to the Comptroller.

2010 Fish Monitoring associated with JORMON-1 through JORMON-4 concluded.

2010 6 Works Backup power was installed to regulate flow through the valve.

May 19, 2010 A revision to JORMON-1 costs was requested in consideration of harsh environmental conditions within the Jordan River Canyon prompting the contracted resources to upgrade safety equipment and procedures and repair and recalibrate the hydrometric stations.

July 8, 2010 The revised JORMON-1 costs were approved.

September 2012 4 On September 17, there was a deviation from Requirement 4 involving the Bear Creek Reservoir dropping below the specified 411.0 m elevation. On September 26, the deviation in the Bear Creek Reservoir level was reported to the Comptroller.

Sources: BC Hydro. 2006–2012. Jordan River Water Use Plan, Monitoring Programs and Physical Works Annual Reports BC Hydro, 2006–2014. Annual Conveyance Report BC Hydro. 2015. Water Use Plan Order Program Correspondence Log. Database output file. Comptroller of Water Rights, 2006–2014. Annual Compliance Letters

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