ENVIRONMENTAL PROTECTION COMMITTEE MEETING Thursday, January 1$ , 1985 4:50 p.m. AGENDA ITEM NO. I S. I iTEM Terms of NOTES Reference for En vironmentaI Protection Committee 4~ P~ —; cE N 17 1985 ~ 'am ee . " j I ~ j Its ' 33 11 11 ~ ~I I I II 'll "% 31 '13 Ai e. a- ~ ~ ;;gy-- i I I el :e II!/~ M 3 I 1131 I I lii:. me9 3 I ~ (i IR.I %1'1f ~ .'I — meeeew1 '.. Il ~e&i»p la's 3!HI 1 I I;i I, '@l 11 I TIIE CORPORATION OF TIIE CITY OF PORT COQOITLAM MEMORANDUM B. TO: Kirk, January 18, 1985 City Administrator T.M. Chang, P. Eng., FROM: Assistant City Engineer 'I'm 0 SUBJECT: I'. Terms of Reference for Environmental and Staff Resource Person Protection Committee RECOMMENDATIONSI 2. 3. I uee et 4. I» II I I I li II'll Prior to proceeding with prosecution in matters oi Environments Protection, Counc shel be briefed by the Environmental Protection Committee on the historical background and detai is of the infraction. An addi tlonal $ 2,500 be budgetted in 1985 as a separate item for I I I I Protect on Cont i ngency Fund . Env I ronmen ta I I Assistant City Engineer be authorrzed to s'pend Funds budgsttsd for Environments 'rotect or. in instances Contingency where mitigat ive measures have to be implemented quickly in deal ing with pol lotion incidents of potential serious environmental consequences. The I i At the Counci meeting immediately fol low i»g an inc!dent the expend i ture of Environmental Protection CorItingency Funds, involving Counci she be advised of ths de+a i Is of the incident. I I I I BACKGROUND AND COMMENTS: At its Committee meeting of January 14th, 1965 Councr recommendations presented i:y the Environmental Protection Committee several in its memorandum on this subject of the same date. The following recommendations were not adopted by Counci I I adopted I 1. The decision to prosecute in matters involving the Environmental Protection Committee rests with Council and not stafl. 2. Ths Assistant City Engineer be authorized to expend City funds previous y budgstted in instances where mitigative measures have tonot be implemented quickly in deal lng with pol lution incidents with potential serious environmental consequences. I d i scuse The Env ironmsnta Protection Committee met on January 17th, these two recommendations further. I 1985 to ) 7 Iqpq a — gl I I ~ i'. Regard ing item I, the agreed that the was somewhat inappropriate in that they impl iedCommittee the delegation of a normal wording 'b' staff r s ounci . is, of course, was not the intention of the Committee. he intent behind this recommendation was to ensure that Coun 'I b c e orouohly informed of the background ramifications of such prosecutions and that should Counci I, acting in and ' the best un c pa ec de noi to proceed with such prosecutions 't y, d cch arges are already laid by staff. b Counci should be aware that prosecutions in Environmental matters are very different from many of the other Cit at io ions, in haf they are not only technical ly more g comp icated but they are also I-defined by the law as to where the local government's rnmen s au auth ority view of the fact that the nature of such prosecutions are often expens i ve and high profile, the Committee felt that counc has the ri ht t b g y to staff proceeding with such prosecutions prior . The Committee has therefore re-worded the recommendation to reflect this intent. Regarding item 2, the Committee appreciates the difficulties of some members of Counci in accepting the recommendation Again, perhaps t e intent was incorrectly presented. To clarify; f asirstlpresented. fact was askinng is th e authority necessary for the Staff what the Co his newly assigned responsibi ities. Should Council Resource Person to mee, decide that it Is not the responsibi ity of the Staff Resource Person to respond n and take an a e th e necessary actions in eemergency e env ronmenta pol I ut ion 'roblems then such author oriit y too spen d funds need not be given. iv IIowever, the would agree that should an emergency Committee felt that most members of Counci environmental pol lution problem occur, the Staff Resource Person would be expected and to take the necessary Initial actions as required to alleviate totherespond situation. For this reason, the authority for the Staff Resource Person to spend funds after such incidents is again recomn'ended by the Committee. Secondly, to to rest the concern that this authority may be subject to abuse in that 'I'he put recommendation fails to identify where the funds will come from and how muchprevious the Staff Resource Person will be authorized to spend, the Committee makes the following recommendations: i i i i I l i I i I i I I I I i I I I. An additional $ 2, 500 be budgetted in 1985 as a Envirormental Protection Contingency Fund. separate i tem for 2. The Assistant City Engineer be authorized to spend Contingency Funds budgetted for Environmental Protection in where mitioative measures have to be implemented quickly ininstances deal ing incidents of potential set'?ous environmental consequences.with pollution 3. Council meeting immediately following an incident involving the expenditure of Environmental Protection be advised of the details of the incident.Contingency Funds, Council shall TMC/sgg At the T.M. Chong, P. Eng~ Assistant City Engineer MAIN.R9 JA 19% ~ P+ I 'r%il ~ 'e ~ 1 k I IIei I II@ I I I !' I I i! i l'I Laa i ; ! 0 I'I II! =!IIIIII N IIIVII IIIE — -k» jj' al ' IS III "55 lh ill ii '. e all m'! ERR I Ii 4! Lr RETAIN THIS COPY FOR FOLLOW-UP ( DATE vrA.. w~~m~~MC. QDFLPFFLrr 'n 7C:C rQ+~ o DoaFncFIr dern s osa v MF Fane«EP F MESSAGE ~ gp M +Me ~~~ V f -+:~ ~ ~~ ~ ~+ rgb" pC~ CZ~~~ WEE. PFFF~S & ~J F EMYVEN, ~r~y WrW~ ~d cD~~~~ JAII L'SE LOWER PORTION FOR REPLY REPLY FROM igq, pi — -':. -..s aaar.-.. 'I!I 'I — , l 'lIgili llllll , '; Pa, ! - DATE I7 1985 ! 3 ' ' s' I I Rjttt!, I',tjggi¹st III RES!5 Igj gr II . 'ms», iirej — — " w~I II 'jijggpgI )f I l o I ~ ~y ''ad /n+wvnmtim/Ac6on Chntrc C~C! 1915 Pltt River Road, Port Coqultlarn, B.C. 941-541 'f V3C1R2 ACTIVITY REPORT DECEMBER MsRRi t[ 1. 0. ACTIVITIES BY PROJECT j'IFlil 1. 1. Internal Energy Management e Municipal Seminar — scheduled f ar February 20, 1988. attached Agenda 'I ~ I II I ~ 111 ,9 lt,l'I I e o' I ! "I See e Audit Report — Port Caquitlam Recreation Centre Audit 'r IL I I 1984 Report copies available from the Centre. This report will be included in Municipal Seminar. ~ City Hall HVAC Study — awaiting data fram B.C. Hydra on 1984 consumption to compare 1982 &pre-retrofit measures) with 1984 post-retrof it mess!.rrss) . nJ & 1. 2. Supply-!Side Projects B.C. Regional Energy Management Task Farce in Canadian Cammercial and Of f ice Buildings. — Yvonne involved in committee putting together Quarterly Newsletter to be distributed January 1985. ol, i. B. Demand-Side Protects s Consultat.ians New Construction Retrofit Other Churchwarmings 9 16 4 TOTAL: ~ Site Tours/Inspections Toured Al Koehli's home under construction in White Rack. Inspected condensation pr oblem in house. Severe water problem in ground of cr awl space„caupled with neither a kitchen nor a bathroom exhaust fan. Q+ ~ eooorooe Cieeee Ooeooe!oeo Ceeole Tie ceroeeNlee el mo Cllrol Port Cooolilero JAtl 17 jo&&" , tiei7 a@ ! SI m 8 I! ! 'Pill( ~ I I I~ SI I !I I) I! If II I I% II '81 I e Sci;oo1 Carol visited the Grade 5 class at Nestor Elementary School . They saw sA Piece s f i 1m, of Sunshine B. C. Hydro displays and discussed alternate energy. I e Thermography Two evenings irathers early mornings) spe n t th ermograp h ing homes. Both VHS and Polaroid and white prints taken. Questionnaires now coming black in by Thermography evenings to be scheduled forreturn mail. January. e Ma i 1 Drop CHIP update dropped to 00 homes in Mary Mill area of Port Coqui tl am. e Churchwarmings Grace Gospel Church — Arnold Shaw had previously visited Centre and installed caulking and weather" tripping in his own home. Discussed ap,!.ication of specific products. St. Catherine's Anglican Church — Bill McCausland, sheet metal worker, is familiar w'th draftproofing a materials, so he visited our Centre for a tour and to pick up their Churchwarming Kit. e Product Manual Revision sent in for approval fonow be presented as an Appendix to HEP monies. 'Manual'ill CHBA National Catalogue on Products and Services. theAppendix will contain listings of distributors, manufacturers and retailers in B.C. organised according to region. ~ Ventilation Product Showdown Initial planning completed with invitations go ng out tu all Canadian manufacturers Air-to-Air Heat Exchangerss with carbon copies to their oflocal distributors. Schedul ed f or March 7, 1985. ,a!i l fili@. !ms l ~ Centre i'l AI Our Centre has the advantage of bein g aablee too rrely i)n some agencie and to make use ssome o our Ceentre displaysorganizations and information after we oofclose. ( I tlIT& I I I I I l S ~ I ~ i'I'I i, ! I I i II I I I ! 'ontinuation'ro I ect m! g' S.O. In order to dispurse these materials bee best es possible o en user„ end user we plan to have these group~too sign a receipt of donation form which will state that the end user of the material will make them 'accessible the public in the same way that our Centre was abletoto. kie also to take the time to fully to these end usersplan how we see them making use el',plain of the materials. Activiter- Planned I if e.7hermography Evenings — January s Breathing Easy Seminars Abbotsford in February Ifhite Rock in March Richmond in March a Ventilation Product — March e Municipal Recreation Showdown Seminar — Februar e ruary 885 ml ee4U / '! ~ 1I I I (EIEIB I I l I 4I 41 e 44 ' "%1 l@t4 I J eiiA ieee ~ l' l I.-3 I— '=35/ ~ee Il~==: .... w / I IN/4 el ~ eg ll( ARRI ~ I ~! .,4 ~ e'~ I 'I I- 44 e ,",; 4 I 4 4 4IN( I ~ il l.~ll ~dl lllll I „4 I ~ ~~gg~ ERAE Cbgui Elneee &spy i~me ~/A«E/o~ ~c fl Ill! ll SPEM(I AX: ENUACENENIS I /el WQBKSB(XIS I 'II( E. I II I « PB(SE CALIS« ~ NEETI(X4 RXN USE« C(NSUGPATICNS e I ill, IIL Ii 1 OUESTICE/E! lI5~ (XSP ~ CXÃIRACTC$8 OIBER B(EIINESSES NEW B(USE (XE(ST(EJCZI(5 HYDRO I/URN ( HEWIXNG IEEULATICN WIND(NB ~ HEAT P(%PS BEAT EKi I(AMlERS W(m EUEL SUPPLY I l4 SERVICES REPE3BKE %6ERIAL PRODUCT IEEXEN(TI(E( (ISA//PAY BACKS WELD(EBS TRIPPINC GENERAL s MXU SXUiiEB I iaido gkgyra ILC CegnCatNNeo Tacan hhaa. Eattaee%asc 6Rc 0 Hkia. RIOR NsaonkahW 4-HLCSCHQA Nhinj5% ~ 4eil „ ff M I ~ 5IL 4 I 4 'I I l I ~I tlafl II 1I!III ) ~ ~~ Cagui UTBPPI 1&aYVtlCthQrl/@6Qn I)IIII~ IIIII NB. IIfi!IS Ei II lr4 NI4I '4 ~NONTN 'ISTTORS If ~ SUHHART TOURS CONSULTATIONS AT CENTRE IN-HONE APPZL t 'PY 'f8 NORKSHOPS NESTING ROOH SHUNS USE a6e) ~)SA4A'%NERGY 'caa ew Oker e I i4e I SPEARTHC ENCAGEf. IENTS ~4e 4g PONE I Or «CTTVTTZES ne4fr egg OACr e nC4C e go PA~e 'AUCUST neer SEPTENBER e nor ~ PRS EN%cI OCTOBER I7c444 NOVEHBER BECEHB ER net- o chef - R. WWIPHLA'C ~(~s) I It S4) CASI eQ'f nce4.- p HARCH TOT«LS 4 I Ill 44 I I ~ I ~ ~ I !iL IgP. II I 4~:: ! 4lI 15 LR i I I eB II lk' K4 I ' I IW, I 4. „, $ NI 4=. I Pll~) As'~s~ 1%%84PHL@W „.PI', ( v ~e~r~ ~PS( I&~ ~dl ( rrrlRt'40rt/AC6CJrrt 1815 Pltt River Road, Port Coquitimra, B.C. 841-5411 l ENERGY "NNAGPIENT FOR RECREATION FACILITIES DATE: WEDNESDAY, FEBRUARY TIME: 8I30 am. - 4IOO p.m. P LAC E I .- VSC 182 ~~j ~~. '=~IS ~ 20, 1985 TERRY FOX LIB RARY 2470 MARY HILL ROAD, PORT COt|UITLAM, B.C (corner Wilson Avenue) COSTI 88.00 per person (includes lunch aad coffee) RSVP: BY FEBRUARY 7, 1985 AGENDA 8I30 — 9IOO 9IOO — 9I15 9: 15 — 10I15 Regis tration Introduction Recreation Facilities Audit, Monitoring aad Measuring Energy Consumption - Bruce Joiner, Port Coquitlam Energy Information/Action Centre Coffee 10 I 15 — 10 I 30 10 I 30 — 1 1 I 30 11I30 — for Swimmiag Pools - Lyle Maaagcmeat McClelland, P.gng., B.C. Hydro 1IOO Lunch 1IOO — 2IOO 2 IOO — 3 IOO 3IOO — 3I30 3 I 30 — 4 IOO Beat Recovery from Ammonia Refrigeration Units - Richard Green, P.Eng., President — Neptune Dynamics Ltd. How To Save from Knowing What Watts - Ken McLeod, Adesco Design Ltd. Question and Answer Period Touzr Port Coquitlam Recreation Centre m Waste Heat Recovery System ~ Computer Control System Eaergy This Seminar will be of interest to City Engineers, Building Superintendents, Trades Foreman, Building Operators, Recreation personnel. and Politicians. I+ JAN 17 198 Smemvsv Cases Ilsvsvmvm Cameo L '4" ~ JI11 Ill - = w i 1 s s ml II u~ 1 oi Canada Government Gouvememenl du Canada Flshenes Paches and Oceans elOceans Rm. 311-549 Columbia Street New Westminster, B. C. V3L 183 C» CC 0 C CCC» CCC» c»o cI»ww November 26, 1984 Hr A Griest Port Coqui t 1am Hunting and Fishina Club P.O. Box 122 Port Coquit 1am, B.C. V3C 3V5 Dear Hr. Griest: R EI Nixon and Or Creek Diversions Hr. eel led me today and requested of the Oe pOtway e thaat f art r ment of Fisheries and you a copy Oceans'osi tion onorward diversions of the above streams GVMDIs ro e ms too t e oquit 1am Reservoir. fin ind attached our letter Please of October T984 t o t h e B.C. Branch. 1 .. 1Iater Hanagement 1 Should you any information or clarification of our position as require it relates t further the protection of salmon me at 524-7146. please call r&n Or POSEr COquSnAat 'I EIVQllljEEQING DEPT. JAN 15 1985 ."1LE 8 —— Yours truly, 5u~ l Nead, Habitat Management Unit OEL/kmr cct F.J. Fraser D. Capllfg'. Ceccoc.II Aural s. Ir. 1'cci,f B. Cox IL/s Yc: Canada ~i; H: Clam.t CIrcuImfeJ mf Pisa safIcssl of 8 IJ. EcofcS I llml '::~ll 8~.1 flBsm ~: I Sew I f If Q'l5 Cc I Y Cs ealf JAV. 17 5 I Il all II '«F1 ~i p 44 5 18}P Ns ~ 7r Iy Goverlpneni OI Canada Fisheries and Oceans du Canada Pi}ches e} Ocearm Rm. 311 549 Columbia New Westminst«r, V3L 183 B.C. Street FW ~ FF F«F FF&FFF» October 15, 1984 J.E. Farrell Water }Panagement Branch 765 Broughtorr VictoriaF 8 C Street VBV lX5 Dear Sxr RE: Application by GVWD to Divert r Wste ster from f Hixon and Or Creeks F I I, Ill Further to our letter of June une 28 198 and your of }uly 23, 1984 we can now provide , 1983 inquiry you with 'h = e f'isheries inp cts that may by the ma bee a iona if aa~proved r that theabove applications as applied for.caused ln ill o t on th a u h Or Creek Diversion Proposal receipt of. the application ica ion our ou initial review indicated a e t h at little new data hsd or f'low requirements now know}ed e gee was wa 'n available in the on e beyond that presented i n Or Creek-Coquitlam Riverr ssystem s the 1978 co Upon 4 II oq ui se ows into the Coquitlam River. flow formutla wss recomm .oughh a tentative ten ommen d e d in 1978 forAlthou Coquitlam River, little Or Creek and i the e has been done tFF tr and those recommended y ln aachieve imum ows duriFFV the P ast 6 vears. Also the 'on f orr installing a vice on Orrecommendation a flow measure Creek was not acted unon1 . u sng de- min'l The application by the GVWD to divert from om thee last ast remaining flows major source of na tadditional ura 1 flow into the Canada Jr4.}! I % ll!IVI} , „'544!FFF}l'f} eliHi I'II ~ IWI I I '. ' IP ' I I 4 .s (t) 1985 Ir~g — 3Rk- i ~ m&I&I(l '(( III I( ~ ' I I M 'I l IIlII I Ill Ill II )»ll IIV(( SII~( ( I /[glib i) li I; Coquitlam River flows are already to B.C. Hydro and diverted out of the system with no committed provision for minrmum fishery flow releases out of their reservoir. GvwD application covers much of the remaininc natural flow The in river and puts fishery requirements into confirct withtheGVWD water requirements. Specifically, approxrmately 64 domestic of un1 rcensed water remain ing in the system which is essential vival and the maintenance of fish production will to the surreduced. Th only way the two uses can possibly be further be accommodated would be by an agreed upon better seasonal release of avai 'labia water. Unfortunately lack of storage on Or Creek makes the delivery of assured a minimum flows in Or creek very diff icult or and should the reduced f ishery water (ie proposed impossible annuaI Average flows of 24 cfs) be discharged to obtain maximum benefit, of water must be considered a- part of the agreement.storage The diversion will remove some peak flows that can fish habitat, however, the diversion will affect base damage flows that are necessary to maintain and restore this river system. It. is apparent that the Or Creek diversion vill divert maximum tunnel capacity (370 cfx) when available (50 cfs annual average) yet maintain residual for fishery purposes. Discussions with the GVWD have flows indicated that the point l f release (ie Coquitlam Dam or Or Creek Diversion) of fishery flow" is open for discussion. River puts great pressure on the remaining 'icensed flows in that over 904 of the total Coquitlamun- Our studies during the past 14 months have indicated th a t t he tentative minimum fishery flows recommended in 1978 for the lower Coquitlam River may be adequate estimates as minimum fi shery flows for most purposes. certain times of the year additional flows will possibly be )itrequired for fish protection, quality recreational fishing, and flows for tg p»tpl te .. This formu]a howrvcr, doI nr t ""-. cr nt. flushFlr w needs to maimtain or improve fish habitat in Or Creek and in the Coquitlam River immediately downstream of the dam. The attempt to satisfy fishery flow needs as well as planned domesti c needs may be difficult or impossible if one only water considers Or Creek flows even in combination with Coquitlam storage. This will occur because not all Or Creek Reservoir waters will and released to a prescribed formula. much beof contained the fishery releases will occur when they are not needed and when are less than those proposed in an realistic available flows formula; the formura numbers are mean)nqless without storaoe. of all concerned parties may be impossible to Water needs unless all users are willing to contribute to and ensure meet that a minimum fl ow formula will occur so as to aid in the re((estabrishment of former fishery runs in the river and also serve hydro electric, domestic, flood control, and recreational needs. I . ? 1985 Simply trying to divide Or Creek waters between fishery recreational needs and domestic supplies may be difficult without involving 8-C. Hydro in the and in an agreement on a flow release formula discussions similar to that was recommended in the 1978 Water Management Study. We which believe this is necessary because until it can be shown to ourselves and the public that fishery production and other uses can be maintained or improved in Or Creek downstream of the point of diversion as well as in the Coquitlam River downstream of the dam and downstream of its confluence with Or Creek, we cannot support the proposed diversion at this time. We are prepared to alter our position once it can be shown by the Water District that natural low flows in Or Creek below a certain agreed upon level can and be available downstream of the proposed point ofbypass diversion. These minimum flows must be augmented by seasonal flush and a diversion structure that will allow free downstreamflows bedload movement. This is essential should downstream spawning areas assured recruitment source of spawning gravel. Hixon Creek Diversion Historical streamf low dates limited the period of 1912 -1920 as recorded on a daily or weekly tobasis. and 1974 DFO conducted investi~ations f or possible In 1972 hatchery sites on the Indian River near the mouth of Hixon Creek. recent records of salmon presence existed for Hixon Creek No prior to our 1983- 84 surveys. The Indian River downstream of Hixon Creek supports ex tremely important runs of coho, pink and chum salmon and smaller populations of sockeye and spring salmon and steel head trout. Over 50,000 adult salmon commonly spawn in this river and spawning populations of over 100,000 fish occur on peak years. Pish utilisation in Hixon Creek is limited the bottom 1 km. Our surveys have indicated that juvenileto coho and trout rear in this section of Hixon Creek and small numbers of adult coho, pink and chum salmon also spawn in this area. have an Avai labia data indicates that the stream to be diverted (Belknap Creek which drains Belknap Lake) is o of Mixon Creek. Data for 1913 indicates tributes 10 74% of the flow to Hixoon C ree kthat Belknap Creek conThee 19133 metering site on Hixon Creek abovee ( annual average 38%). thee bifur the Hixon Creek fan i urcation in an is the same site used in the studies. The empirical 1983-84 DFO collected in '983/84 e knap Creek actually data shows that contributes 47 t o 8999 off the flow in Hixon Creek (annual average 75%) . Th e d i' f erence in the data sets say be in part due to the clear cut place in the area. However the that took differencelogging to ignore. As well, realising that is too significant Hixon o Creek ni ficantl ree 1 oses sigtly more water to between the bifurcation and its mouth, a diversion of groundwater 100 cfs could reatl owe n lover Creek which may harmfully habitat in late Hixon alter fish summer and early fall. a . I or example 12, 1983, Hixon Creek on October (logging bridge) vere measured cfs whereas the flow atfflows at 14 mouth was only 1.6 c f s. Any sion of flows under such its divera flow rag'me wou ld flow. eliminate surface Data collected 1983-84 demonstrates es that a tth e area of ixon reek alluvialinfan contributes significant ican groun d water the in o he Indian River. groundwater contribution is essential to the maintenance this nf thee Indian n ian River fishery resource and Hixon Creek flows will contribute u e too t h e annual rec argee of the local groundwate" reservoir. 'r. For or examp October 12, 1983 the Indian exam flows increased fromlee 40on cfs (50 m above Hixon Creek) to River's 100 cfs some 3900 m below Hixon Creek) . Si 9 nificant i n creases ' were recor'ded in each of f our mein flow due to groundwater inpu s erings e below ow the e Hixon Creek. con fl uence of A review of 1912 data indicates that thee con cont b ution of Hixon ixon Creek Cree surface flows to Indian River (as rimeasured ii.s tidal mouth) is relativelythen.incr. near !ii. t!ii" in cin influence uence, the ccumulative effect of groundvater r' Indian R iver would have reached its ross 'to maximum while Creek 1 ows remained i e th e H'ixon constant. as the cumulative groundwater effect on the IndianConversely, River decreases dir in an upstream irection f rom its the contributions ofsesHixon ace water becomes mouth, Creek surmore si gnif i cant to important sa1 sa mon spawn= R'echar contribut'he Should the proposed Belknap Creek diversion be pursued, ve that a the be requested to provide information would show that i f GVWD th't a diversion is to take place f 'sh ery h a itat in Lower ower Hi. Hixon o Creek can be maintained. Also since the Indian River is of ten plagued by lov natural flows for early salmon recommend b's spawners in the August to mid time period, the GVWD must demonstrate that the magnitude October of the proposed or a reduced level of diversion will not further lower River flows during this critical time period or during Zndian prolonged cold winter spells. In conclusion we are very concerned that the Hixon diversion can have greater impacts on the fisheries resource than the Or-Coquitlam diversion and presents opportunity for mitigation - or compensation options. less Our discussions with the Water District has indicated that their consultants are developing a computer model and have prepared a series hydro graphs to address certain of the above concerns that we ofhave identified. Our concern with studies is that they are based on good empirical data. Wethese have suggested to tl e Water not District that probably adequate data and an understanding of possible impacts exist so as they can consolidate the material into a format to address our concerns mitigation or compensation measures where necessary. andAs present to the GVRD over a year ago it is still our feeling thatindicated additional collections of hydrologic data is required at a number offield points on these systems to properly relate to and agree on various discharge formulae. Once this is done, we will be prepared to re-assess our position on these diversion proposals. However, until this information is made available-and it can be shown that our concerns can be addressed, the water license applications should not be granted at this time. Yc rr ". ="ly, c Otto E. Langer Head, Habitat Management Vnit OEL/kmr cc: F.C. Boyd F.J . Praser B. Cox ZPSFC D. Aural S. Roxburgh Jlih 17 885 i