Crown land file #4406427

BC Government - Applications, Comments & Reasons for Decision

Comment by December 3, 2023

https://comment.nrs.gov.bc.ca/applications?clidDtid=4406427&id=6529b28b646c73002270b4ab#details

The Issue:
Environmentally valuable and irreplaceable rangeland and grassland in the East Kootenay Trench is once again under threat from major development.

A company wants to develop utility-scale solar power plants on ecologically productive grassland and rangeland home to the threatened Long-billed Curlew, Lewis’ Woodpecker, the endangered Williamson’s Sapsucker, and American Badger.

Almost 5,000 hectares throughout the Kootenay River valley are being sought.  That’s the same area as over half of what will be flooded by the Site C dam.  The East Kootenay has already lost significant tracts of land to dam building.
 
For now, the developer wants only to measure the amount of sunlight, termed solar irradiance, to see if there is enough for industrial-scale solar farms.  But this information is already available and can be measured from satellites so there is no real need.

Similar tenures, requested in 2016, were rejected by the Province of BC and not supported by the Regional District of East Kootenay after many groups and individuals submitted comments.  The reasons the Government gave for not allowing the tenures included the following:

“The area selected is within an endangered grassland ecosystem which is being actively managed and restored.  This ecosystem provides critical habitat for ungulates (primarily elk) and species at risk and is an important cattle grazing area”

“…any future solar energy facility would be incompatible with protecting the grassland due to the need to fence off the facility”

“This project poses an unacceptable risk to an already endangered ecosystem”
 

The Problem:

Solar power is seen as one of the cleanest ways to produce energy.  Developing it can help us manage our climate crisis and that’s a good thing – we must do it.  But we have roof tops, gravel pits, old mine sites, and waste fields that can be used for solar farms; using grassland and rangeland is not necessary.

What’s wrong with a few panels out in a field?  Well, this wouldn’t be a few panels, it would be hundreds of them covering many hectares. They would shade the native grassland plants, adapted to full sunlight, and they would die.

Preventing invasive plants from taking over under the panels would require great care and maybe lots of chemicals.  Sulphur cinquefoil, knapweed, and cheatgrass are already a major problem on our native grasslands.

The solar farms would need to be fenced off for security and fire protection.  This means:

• Loss of winter ungulate range for the elk and deer
• Loss of high-value rangeland from local cattle ranches
• Loss of habitat for species at risk that are dependent on grassland and open pine forest
• Severe costs to protecting those facilities from wildfires and prescribed burning done for ecological restoration

These are just some of the impacts.

The Province of BC still does not have any policies or guidelines for large-scale solar farm developments.

The loss of temperate grassland continues.  In 2021, almost 650 thousand hectares (1.6 million acres) were converted to row crops in the US and Canada, according to the World Wildlife Fund (Plow Report 2023).

Fortunately, we have managed to protect some of the little bits of grassland and rangeland we have left here, so far, and ecological restoration work continues.
 

Why are grasslands so important?

The World Wildlife Fund (WWF) expresses this very well; they say:

“Grasslands are essential to people, nature and climate.  They hold approximately one-third of global terrestrial carbon stocks and provide critical resilience in the face of climate change, including drought, heat and wildfire.”

They hold carbon, filter water, provide breaks between forest stands, grow things where trees can’t grow, help increase biodiversity, provide natural food for deer and elk, to name a few benefits.

The International Union for Conservation of Nature and Natural Resources describes temperate grasslands as the world’s most endangered ecosystem – more endangered that tropical reefs or the Amazon Rainforest.  

The WWF says that more than 70% of America’s prairies have been destroyed.

The North American Bird Conservation Initiative, in their "State of Canada's Birds, 2019, reports that grassland birds have declined by 87% and 300 million birds have disappeared since 1970, or 2 out of every 3 birds.

 
Skookumchuck Prairie KBA

The fields between Lantz’s farm and Skookumchuck don’t really look like much to us, especially at this time of year – all just a pale, wind-swept yellow grey.

But from early spring to autumn, its a busy place.  Native bees and other pollinators, feral domestic bees, untold numbers and species of butterflies and insects, the usual chipmunks and squirrels, and thousands of birds from a dozen different species all buzzing and singing and mating and incubating and raising their young, frantically trying to get the job done before the snow flies again.

Most bird species in the grassland are the colour of last year’s dried grass still sticking up between the new green stems.  You don’t see them much, because they don’t want to be seen – it’s safer that way for them; but you can sure hear them (at the right time of year).

Dozens of Western Meadowlark and Vesper Sparrow males singing their little hearts out filling the air with their bubbly little songs and flitting between this place and that, catching bugs.

And one of the weirdest birds you might spot is the Long-billed Curlew (Threatened, SARA) (Threatened, Blue, BC), presiding quietly over all the activity.

Yes, they are cousins with the other shorebird species you might be familiar with, like Killdeer, or Avocets; and they do look like just a big sandpiper – but with a very long bill and they're a shorebird ... in the grass ... no beaches or shores in sight.

In the winter, and in the summer between incubating or guarding their chicks, they DO hang-out on the shore, and riverbanks, mud flats, and agriculture fields.

In the winter, the birds from Skookumchuck Prairie fly down to central and southern California – which we know from having put solar-powered satellite transmitters on a half dozen of them and following their movements.  Very cool.

And over against the hillside, where millions of dollars worth of ecosystem restoration work has taken place over the past 35 years, dozens of rosy-breasted woodpeckers make their summer homes.

This is likely Canada’s densest breeding population of Lewis’ Woodpecker (Threatened, SARA) (Threatened, Blue, BC).  I have found dozens of nests and identified almost four dozen nesting trees on the edge of the Prairie over the past 9 years.  They have benefited greatly from the restoration work done here.

There are American Kestrels – our smallest falcon, also nesting in cavities in old trees, sometimes in the same tree as a Lewis’; and Common Nighthawks (Threatened, COSEWIC) (Secure, BC) nesting on the ground, their two little speckled eggs in just a shallow hollow where the parents may have bothered to move a pebble or bark chip out of the way.  And Mountain Bluebirds, and dozens of other species of birds.  It’s a busy place.

Inches deep, all over the fields, there are elk droppings, evidence of their substantial use of the area on long winter nights.  This is what natural diversity looks and sounds like.

Skookumchuck Prairie Key Biodiversity Area (KBA) is recognized internationally as critical to restoring the biodiversity and health of the global ecosystem.  It is one of the few pockets of grassland not privately owned.  The KBA programme was developed by Bird Life International and is administered by BC Nature in British Columbia.  Some countries have incorporated these areas into their conservation protection laws.  Unfortunately, Canada is not one of them, yet.
 

Summary

In the developer’s application for crown land, they claim this land “has previously been disrupted by forest activities or consists of low-lying scrubland” but that is not true.  It’s not scrubland – it’s grassland, rangeland, and winter ungulate range.  It wasn’t disrupted by forest activities – it was healed so that many of our grassland-dependent species once again have homes and feeding areas.

There are so many other places better suited to solar panels:

• reclaimed mine and industrial sites
• roof tops on malls, garages, houses
• over parking lots
• on waste-water reservoirs, and so on
• places we’ve already altered which can’t be reclaimed

So, if covering over critical and ecologically sensitive rangeland and grassland with solar panels doesn’t make much sense to you either, please be sure to make your thoughts known.  Comment on this tenure application and urge the government to implement clear guidelines so renewable energy companies can pursue projects that are ecologically profitable, too.

Please search for or go to the following link by December 3, 2023 to submit a comment and/or write to your government representatives:
​
British Columbia Applications Comments & Reasons for Decisions
Crown land application file number #4406427 at:

https://comment.nrs.gov.bc.ca/applications?clidDtid=4406427&id=6529b28b646c73002270b4ab#details

List of representatives responsible:

Federal, Provincial, and Regional Government Contacts:
Honourable Josie Osborne, Minister of Energy, Mines and Low Carbon Innovation
[email protected]

Honourable George Heyman, Minister of Environment and Climate Change Strategy
[email protected]
 
Honourable Bruce Ralston, Minister of Forests
[email protected]
 
Honourable Nathan Cullen, Minister of Water, Land and Resource Stewardship
[email protected]
 
Doug Clovechock, Columbia River Revelstoke
[email protected]

Tom Shypitka, Kootenay East
[email protected]
 
Rob Morrison MP Kootenay-Columbia
[email protected]

Sonia Furstenau, MLA Cowichan Valley
[email protected]
 
Rep Jane Walter, Electoral Area E, RDEK
[email protected]
 
Rep Rob Gay, Electoral Area C, RDEK
[email protected]
 
Rep Stan Doehle, Electoral Area B, RDEK
[email protected]
 

Summary of reasons to reject / disallow this crown land tenure application:

We strongly support the development of solar power as a renewable energy source to off-set the effects of climate change and global warming.  But rather than large-scale utilities, we believe a decentralized approach with small-scale installments would better fit our priorities of maintaining natural areas and increasing biodiversity.

Parcels requested in this tenure application were previously disallowed.

Parcels requested in this tenure application are:

• within an endangered grassland ecosystem which is being actively managed and restored.  These areas provide critical habitat for ungulates and species at risk and are important for cattle grazing.
• internationally recognized as a Key Biodiversity Area, critical for maintaining or increasing global biodiversity as defined by Bird Life International.

Reasons for concern and protection of these parcels:

• The need for fencing of any future utility-scale solar infrastructure would remove critical habitat, fragment the grassland ecosystem further, and increase challenges for wildfire control, habitat restoration, and invasive plant species management.
• Utility-scale solar plants are an industrial use incompatible with our objectives for managing our agricultural rangelands and natural ecosystems.
• Temperate grassland, of which parcels of this tenure are comprised, is the world’s most endangered ecosystem according to The International Union for Conservation of Nature and Natural Resources.
• Parcels requested in this tenure application contain Canada’s densest breeding population of the threatened Lewis’ Woodpecker, and impacts would be difficult to impossible to mitigate.

We urge the BC Government to develop and implement policies, guidelines, and procedures for the responsible de-centralized development of solar power in British Columbia so that

• the challenges of climate change and global warming are not exacerbated by the removal of naturally functioning and critical ecosystems
• so that developers can have greater confidence in planning and implementing their projects
• so that energy users can be confident they are minimizing their global warming emissions without avoidable increase in harm to the global ecosystem

​

Summary to Date
16 April 2017

By Dianne Cooper

Introduction

Since the spring of 2015, four renewable energy companies started working towards developing utility-scale solar electricity generation facilities on Crown land in the East Kootenay.

Because greenhouse gasses are not a by-product of solar power production, solar is seen as part of the solution to transition us from a carbon-based economy to a greener one and help us lessen the negative impacts we have had on our biosphere. There is much support for renewable clean energy.

The Ministry of Forests, Lands and Natural Resource Operations (MFLNRO) has granted three companies the use of about 5,600 hectares of Crown land, all in the valley bottom, to investigate the feasibility of solar utilities.  But the B. C. Government does not have any policies regarding solar power development; they are using the criteria for wind power to make decisions on requests for Crown land. Yet, solar array facilities have vastly different requirements and impacts than wind power. They are comparable to hydro reservoirs in their land requirement. The ones proposed here on Crown land would likely be completely fenced in, making the land unavailable for any other use.  Their footprint maybe larger than the fenced area if safety and security buffer zones are required.

First, the renewable energy companies plan on placing monitoring equipment on the land to measure sunlight (even though this can be measured via satellite). During this exploratory phase, according to their application documents, they will begin to look at the environmental, social, and cultural concerns of these developments.  This phase, aside from the business aspects, will test regulatory requirements and efficiency of the B. C. Government and Regional District of East Kootenay (RDEK); and it will reveal the public sentiment on solar development in British Columbia. All of these companies have extensive experience building other renewable energy facilities such as wind and run-of-river projects.

Land Grant Size

Approximately 5,600 hectares (56 km2, 2.2 sq. mi) of valley bottom Crown lands have been granted. How much land is 5,600 hectares?

• about the size of Richmond, west of Hwy 99
• more than Kelowna and Okanagan Mission combined
• almost as much as Northeast Calgary to 64th Ave NE, not including the airport
• a six km strip in Ottawa from the airport to the Parliament Buildings
• a bit less than all of Victoria, Esquimalt, Oak Bay, and Saanich south of McKenzie Ave, (including Ten Mile Point)

Let’s look at the Site C dam for comparison:

• Site C will remove 2,775 ha (6,860 acres) of land from the Agricultural Land Reserve (Wikipedia).
• the surface area of the reservoir will be 9,330 ha according to Wikipedia (corrected: previous stated that 5,500 ha of river valley would be flooded, according to a CBC News online article)
  
• It will generate enough electricity to power 400,000 homes (CBC online article).

What about Lake Koocanusa?  How big is that?

• I could not readily find online how much land in Canada was flooded by the Libby Dam
• 1,922 ha were flooded in the U.S. (Google Book results of a U. S. Army Corps of Engineers paper on the impacts of the Libby Dam, 1971)
• Keep in mind that the East Kootenay has already sacrificed much bottomlands for power production – and is still receiving benefits through the Columbia Basin Trust

Of course, they don’t plan on covering ALL that land with photovoltaic (PV) panels.  To make 1 megawatt of electricity, enough for 200 homes, the Sun Mine in Kimberley, uses 8 hectares. So if all the Crown land granted were used for PV panels, 140,000 homes could be powered.  (Note that solar is less efficient than hydro).

Significant Area

The problem is with the location and type of land being sought and granted.  Almost all of the land granted is NOT on brownfield, such as the Sun Mine, but on ecologically valuable land in the valley bottom.  This land contains native grassland, a continentally endangered, globally significant ecosystem critical for several species at risk and many other species. It is critical winter range for our abundant big game populations. Much of this land and its species have already benefitted from habitat restoration paid for by the B. C. Government and organizations. Also, much is open rangeland for cattle, a viable and esteemed industry in the area run by ranchers, trying to do so in an environmentally considerate way.

One notable grant of 2,500 ha of Crown land is in an area designated as an Important Bird/Biodiversity Area (IBA). Skookumchuck Prairie IBA contains one percent of Canada’s population of Long-billed Curlew (SARA Special Concern, BC Blue-listed). It was officially recognized for its importance to curlew in the early 2000s by Bird Life International and is the only IBA in the East Kootenay at present.

Bird Life International is a global partnership of conservation groups working from the local level to the global level to help sustain all life on Earth. The criteria and data used for declaring an area as an IBA are internationally recognized and rigorous.  The aim is to protect a carefully chosen network of sites that are most critical for the survival of species at risk. All the species dependent on that land will benefit as well. There are over 12,000 IBAs worldwide including marine areas, and 325 in Canada and 85 in B. C. BC Nature oversees the IBA programme in British Columbia and supports the network of IBA caretakers. I am the caretaker of Skookumchuck Prairie IBA.  

Most of the time, the main Prairie, in the northwest section of the IBA, sits quietly unnoticed by humans as they drive by on Hwy 93/95 heading for the pulp mill or going between communities nestled in the Trench.  We see the deer, elk, and cattle and understand these larger creatures’ need for easier forage.  But also living here at various times of the year are the Long-billed Curlew, American Badger (SARA Endangered, B.C. Red-listed), and the Lewis’s Woodpecker (SARA Threatened, B.C. Blue-listed), as well as myriad other birds, animals, and plants forming this grassland community.

Most of the curlew habitat is not part of a solar grant. Half of it is actually on private land, not Crown. But one 59 ha field is totally within a Crown grant. It is home to at least one and likely two pairs of Long-billed Curlew.  This field is also designated as a Wildlife Habitat Area for the curlew and for the antelope brush / bunch grass ecosystem.

Also included in a solar grant is 1,500 ha of habitat suitable for Lewis’s Woodpecker. Most of this habitat was recreated through restoration and enhancement work started in 1987. Most recently, this work has been carried out by the Rocky Mountain Trench Natural Resources Society at significant cost to the B. C. Government and other funders.

Some people would see this open pine grassland as mere scrubland. Some would see it as ungulate winter range. And some would also see it as valuable valley bottom habitat. It is constantly under threat of development because there’s so little of it left to begin with and it’s a hospitable and beautiful place for humans as well. To the Lewis’s Woodpecker, these open fields with small groves and plenty of snags are paradise! The woodpeckers have begun to recolonize the area. Last year, in just two hours of driving through a small section of the restored lands, I found FOUR Lewis’s Woodpecker nests.

It is difficult to understand how the MFLNRO could allow this land to be part of a grant for renewable energy exploration. The Canadian Wildlife Service policy is that IF utility-scale solar power facilities go ahead on any of these lands, mitigation measures MUST be carried out for “identified wildlife”.  That is good, IF it can be done. But better yet, why consider locating these facilities on ecologically valuable land in the first place?

Other Ways of Doing It

At a recent presentation to the Regional District of East Kootenay, Michel de Spot of EcoSmart said “you don’t have to use green virgin land”.  EcoSmart was a partner in developing the Sun Mine in Kimberley, which is on reclaimed brownfield, the site of the former Sullivan Mine’s Concentrator.  EcoSmart is also partnering with the only company proposing a solar array on similar brownfield, a gravel quarry near Fort Steele.

Mr. de Spot gave examples of alternative locations for solar arrays that would have potentially less environmental impacts: mountainsides, floating on reservoirs, on fish ponds, on agricultural fields planted with sun-sensitive crops. He pointed out that communities themselves, such as the T’Sou-ke First Nation, can develop their own solar facilities. But actually, the technology for solar power production gives us another option: a decentralized power grid.  Mr. de Spot stated that eventually it will be cheaper to put solar panels on your roof than to purchase electricity from B. C. Hydro.  While we are waiting for that to happen, rather than first using brownfields and the like, is it time already to sacrifice more ecologically valuable land?

The former Sullivan Mine Concentrator site still has 4,000 ha of land available for solar. With a full build of PV panels that would be enough to produce 12,000 megawatts, said Mr. de Spot.

Application Details Part 1

At the beginning of this article, I stated that FOUR renewable energy companies were working on developing solar power in the Kootenays and that THREE have been granted Crown land.  More specifically, a total of TEN separate applications have been submitted to date.

The first one, by Node Engineering, was for a gravel quarry between Cranbrook and Fort Steele. (I mention the company names so you can Google them to see how big they are and what other renewable energy projects they do.) It was supported by the RDEK and approved by the Land Office (MFLNRO). The next application received was for parcels on Skookumchuck Prairie and around Wasa and Ta Ta Creek. The ears of stakeholder groups, long-familiar with the constant vigilance and effort required to preserve the bottom lands of the Trench, began to perk up. We know we are the line of first defence for this finite resource.

Aside – All British Columbians

The recurring narrative of our economic system, our geography, and our society, of which we are all long-familiar with, seems likely to play out again: development directed by for-profit companies, the imbalance in the distribution of our population between the lower mainland and the rest of the province seemingly pitting us against each other, yet all needing the same thing really – enough resources to live and prosper and a healthy environment in which to do it.

We here in the East Kootenay come at this issue, not just from the perspective of wanting to preserve the valley for ourselves. We are ALL its caretakers, for all the creatures that live here and for ALL the people of the Province. We have choices to make. Let us all ensure this development is directed appropriately, in scope as well as location.

The FIRST guideline for placement of solar arrays, recognized globally, is: avoid ecologically valuable land. The valley bottom is ecologically valuable. There are many other places to put PV panels. Do that first before gobbling up perfectly good land.

Application Details Part 2

But back to the Crown Land applications in the East Kootenay.
That second application, by Company 0885781 (Mark Green), the one on the IBA, started raising flags, not just perking ears, for local groups and their provincial associations. Comments expressing concern started to flow in. Some of them were from BC Nature, the Rocky Mountain Naturalists, the Kootenay Livestock Association and private individuals. Despite the land requested being on an Important Bird/Biodiversity Area, this grant was also supported by the RDEK and approved by the Lands Office.

The next five applications, from Innergex, were also supported and approved. But later, the Land Office realized overlapping grants were not allowed so Innergex voluntarily withdrew ONE of its applications with a parcel on the IBA. Another of its grants still has a parcel on the IBA.

Next, three more requests for Crown Land were made. These ones were by SB Holding Companies (01), (02), and (03), subsidiaries of Sea Breeze Power Corporation. One request was discovered to be for private land, so it was withdrawn. The other two requests triggered many more comments because of their location and size – over 2,000 ha each, again on ecologically valuable land and again on land with investments in habitat restoration and enhancement, just like Skookumchuck Prairie IBA. They were also closer to more populated areas and encompassed significant rangeland for cattle.

Commenters on these Sea Breeze applications were cattle ranchers, BC Nature, Kootenay Livestock Association, BC Back Country Hunters and Anglers, Wildsight, and individuals. Recipients of the comments were the Land Office, MFLNRO, B. C. Government Ministers, the Premier, local MLAs, and the RDEK.

Comments and Their Effect

What happens when people make comments? Who reads them? What are some of the results?

The Land Office says all comments are passed on to each proponent and they mush address each concern and issue raised.

Because there is no provincial policy regarding the development of solar arrays in B. C., the Land Office formed a Working Group to process the volume of comments and to interpret and modify the Wind Power policy and criteria (what they have to work with), for solar applications.  Guidelines they develop will not be official policy, said Land Officer Jessie Lunan, who also gave a presentation at the RDEK meeting (right after Mr. de Spot).
The Land Office has also made online access to solar applications easier by adding a category for solar in their database listing.

Ministry biologists created a checklist of environmental aspects to be addressed should these projects move to the next phase of development –  installing utility-scale solar power generating arrays. This checklist was passed on to the approved proponents so they are aware of some of the assessments and mitigations to be required.

The most significant apparent effect of the latest comments submitted was that the RDEK has reweighed the pros and cons of supporting utility-scale solar arrays on Crown Land in the East Kootenay. In their vote whether or not to support the Sea Breeze applications, the board was split 50/50 with no deciding voice.  As a result, and with refined consideration of the environmental and other impacts, the Land Office disallowed the Sea Breeze applications. In their “Reason for Decision” document, they said “The area selected is within an endangered grassland ecosystem which is being actively managed and restored”. They recognize it is critical habitat and an endangered ecosystem and that the need to fence off the facility would remove the land from wildlife use. And because any future solar energy facility would be “incompatible with protecting the grassland”, the project “is disallowed at this earliest stage”.

This decision is a positive sign that sensibility may prevail.

Education and Questions

In Penticton on 22 April 2017, a free symposium on alternate energy is being hosted by First Things First – Okanagan. http://firstthingsfirstokanagan.com/events/register/
Sessions on solar power focus on small-scale installations such as on existing or new buildings. Utility-scale solar development is not in the list of topics. Aside: One topic is “Harnessing Okanagan’s Wind Power” given by Gordon Muir who lists in his CV his experience with the Cape Scott wind farm, developed by Sea Breeze.

Small-scale solar seems to be gaining traction. But perhaps a lot of people don’t want to bother putting solar panels on their houses. It cost money, there are engineering and maintenance concerns, and what would be the benefit really? Electricity is still relatively cheap. Why not let commercial companies do the work, building arrays, maintaining them, negotiating with BC Hydro, and what not? What’s wrong with a few investors making some money? That’s how things work. Let them deal with the headaches, I just want to flick a switch and have my light bulbs light up.

And IS solar really that green? It seems greener than coal-generated electricity, but what if also factored in were the ecological footprint of extracting the materials for PV panels, manufacturing them, and transporting them to point of use? And what if the complete environmental cost of the solar farms themselves were factored in?  These costs would include habitat loss, mitigating impacts, to reclamation at the end of their life-span? Would solar still be profitable?

And look at all those wind farms being built. They have environmental impacts, too. Why shouldn’t we let solar come in too? Isn’t solar better than even hydro dams? It appears Site C, and maybe even Site E, will be built though the debate has been ongoing for decades. How successful are we likely to be redirecting a few PV panels away from good land?

What are the environmental impacts of solar arrays, anyway? How bad could they be? See a brief list of impacts and considerations below this article.
The whole valley bottom is American Badger habitat. It’s impossible to do anything without causing some effect on them.

And what is the big deal with 10 applications? Hundreds are in the works across the country.  Globally, 30,000 PV panels are being installed every hour, says the International Energy Agency, a collective, of which Canada is a member, working to “ensure reliable, affordable and clean energy” for its 29 country members.

Bottom Lines

It’s enough to drive one batty! Each of us must research and consider the answers for themselves. It seems obvious to me that there ARE more sensible places to put PV panels than on good land and we should do that first.

Even if we can’t or won’t, if we give these companies even just a millimetre, they’ll take a mile. This is demonstrated by the sequence of Crown land applications: first a small one on brownfield, second on an Important Bird/Biodiversity area and enhanced lands (ears perked), then a set of five on the IBA and other parcels of enhanced lands (red flag raised), then three requesting vast swaths of enhanced and ecologically sensitive lands (big “whoa” on that). Each request getting larger, impacting more of the ecologically valuable valley bottom ecosystem. They are exploring the limits of our tolerance for solar arrays on Crown land and the strength of our will to protect it, I believe. Their primary concern is profits, naturally, for themselves and their investors.

In our system, our culture, we still DO NOT account for all the environment costs of the products we consume nor of our activities. If we did, I believe considering ecologically valuable land for solar power production would be unimaginable. Let’s pretend “as if” we do! Let’s keep telling them where they can and cannot put solar arrays. Let’s see what happens.

We, here in the East Kootenay, have made a tiny but good start toward directing this technology appropriately.  There will be more applications coming though, no doubt, and in other parts of the province as well. Any British Columbian can submit comments, and KEEP submitting comments! … to Land Office, MFLNRO, the appropriate government Ministers and the Premier, local MLAs, the regional districts, and municipalities. Consider asking them to:

• identify places where solar arrays would have the least environmental impact
• Place a moratorium on solar array development until policies are developed
• Review the six Crown land grants already approved in the East Kootenay and consider rescinding them or modifying them based on the decision to disallow the Wycliffe and Galloway applications.
• Exclude the Skookumchuck Prairie IBA, endangered habitat, critical areas for species at risk, and restored or enhanced lands from investigations into the feasibility of solar power generation and any similar and further development proposals.

 
Some Environmental Impacts and Their Causes:
Causes:

• Clearing land and enclosing it with fences
• Access roads and power line construction and year-round usage of roads
• Position of this land relative to actively managed areas

Physical and Logistical concerns:

• Changes to runoff, snow regimes, spring melt, wind patterns, and temperatures
• Soil compaction and erosion
• Reflection off panels and noise from inverter cabins
• Further alteration of natural wildfire regimes
• Impediment of prescribed burning used for habitat enhancement in adjacent lands
• Invasive plant monitoring and control
• Fire protection in outlying areas

Impacts

• Removal of and damage to the endangered grassland ecosystem impacting all species living there
• Further fragmentation of American Badger (SARA Endangered, BC Red-listed) habitat
• Further damage to the dry grasslands’ microbiotic crust, which takes decades to regrow
• Removal of ungulate winter range impacting their populations
• Population changes of riparian insects attracted by polarized light with further impacts to their fish prey
• Loss of open rangeland impacting cattle ranchers’ livelihood