TSAWWASSEN RESIDENTS AGAINST HIGHER VOLTAGE OVERHEAD
LINES
C/O 1558 – 53A Street
Delta, BC V4M 3G2
May 26, 2005
Ms. Jane Peverett
British Columbia Transmission Corporation (“BCTC”)
Suite 1100, Four Bentall Centre
1055 Dunsmuir Street
PO Box 49260
Vancouver, BC V7X 1V5
Dear Ms. Peverett,
We appreciated the opportunity to meet with Dennis Maniago and yourself on Friday, May 20th, 2005 to discuss the business case proposals that were included in our April 12th letter to you. We have put considerable effort into looking for ways to constructively resolve the VITR project routing issues and to suggest options that are amenable to BCTC, the residents of South Delta, the municipal and provincial governments.
As a follow up to our meeting with you and our impromptu meeting with Dennis on May 25th, 2005, we wish to express to our concerns and restate our position regarding the recommended route of the VITR Project through South Delta that we understand BCTC will announce at its public information meeting on May 31, 2005 at South Delta Secondary School (“SDSS”).
We have three main areas of concern that we wish to share regarding the new transmission lines through South Delta:
1. Routing the new 230kV high voltage transmission lines underground in the existing right-of-way is entirely unacceptable to TRAHVOL – Regrettably, BCTC did not announce in its letter dated March 17th, 2005 that it will also not recommend constructing the new 230kV transmission lines underground in existing right-of-way.
Indeed, we are gravely disturbed to hear that BCTC is still considering, and has not abandoned, using this right-of-way as an alternative underground route for the new 230kV transmission lines through Tsawwassen. This alternative route is entirely unacceptable to TRAHVOL.
This alternative route would create immeasurable damage and disruption during construction and, more importantly, in perpetuity to over 200 residential, school, park and other properties in the existing right-of-way. No doubt BCTC would have to build a temporary and permanent access road cutting across these properties to construct and service the underground transmission lines (including long term access to manholes). Presuming BCTC’s estimate of a minimum 8-9 meter wide “swath”, the route would leave an unmistakable scar across Tsawwassen. It would result in owners losing their rights of privacy, enjoyment and flexibility in using their properties and the destruction of trees, gardens, hedges, fencing and other amenities that property owners have placed, planted and tended at substantial cost over the past 30 to 40 years to beautify their properties. At the same time, BCTC has not indicated that it will concurrently remove the existing 138kV overhead transmission lines. This suggests that we may be expected to live with both overhead and underground transmission lines in the same corridor for many years to come. No amount of compensation by BCTC could correct something so unsatisfactory and objectionable.
As well, the placement of underground transmission lines through backyards, school grounds and parks does not overcome our concerns about EMF—and in fact exacerbates them. BCTC has stated that there are no effective methods of shielding underground transmission lines from emitting EMF radiation. Although EMF from underground transmission lines dissipates much faster in a horizontal direction, the EMF directly above underground transmission lines is considerable. Indeed, BCTC locating the transmission lines underground and “out of sight” in the existing right-of-way would be insidious. It would provide the opportunity for inadvertent damage by homeowner activities and provide a constant potential threat to the health and safety of same from unwitting exposure to EMF and possible contact with unseen high voltage facilities.
As you know, we have suggested a number of alternative routes for the 230kV transmission lines though South Delta that addresses our objections and fulfills BCTC’s mandate to provide additional, sustainable electrical power to Vancouver Island. These alternative routes included underground routes in public road allowances through Tsawwassen.
The placement of utilities in road allowances has been a standard practice for over 100 years in BC and provides benefits to the utility, residents, businesses and the municipal jurisdiction affected.
Firstly, the impacts upon adjacent properties are temporary during initial construction and later when new utility cable installations or maintenance is required. As well, our research of underground transmission line in road allowances in Vancouver found that EMF levels at the pavement edge were 2-4mG, i.e.within the precautionary thresholds recently recommended by the World Health Organization (W.H.O.), thus negating any potential health risks from long term exposure to EMF.
Secondly, the utility company has unlimited access to the infrastructure on a 7x24 basis, an important factor when emergency maintenance is required. The infrastructure is also protected from inadvertent intrusion by unwary citizens or construction by the management of the roadways through permitting and other governmental processes.
Thirdly, (as demonstrated in our business cases), the potential revenue stream to the municipality, the province and the economy from potential reuse of the existing right-of-way, increased tax revenues and opportunities for future enhancement of the community over the next 60 years, and indeed in perpetuity, through new or replacement development is available.
Lastly, underground construction in roadways is consistent with current legislation and direction mandated in virtually all jurisdictions in North America and around the world, therefore not presenting any unusual or restrictive precedents.
2. BCTC remove the existing 138kV high voltage overhead transmission lines through Tsawwassen as part of the first phase of constructing the VITR Project – We remain deeply concerned about the existing 138kV overhead transmission lines through Tsawwassen. BCTC has stated that these lines will remain, and will not be removed when it completes and activates the first of two phases of the VITR Project in about 2008. BCTC has stated that the existing 138kV lines will remain until either the existing submarine cables across Georgia Straight fail or the second phase of the VITR Project (the second new 230kV transmission lines to Vancouver Island) is constructed in about 2018—in other words, the existing 138kV lines will remain for another 13 or more years.
Tsawwassen residents have gained considerable insight over the past six months into the issues surrounding high voltage overhead transmission lines and their potential impacts on human health, property values and the overall quality of life. We are aware that the WHO recommends that “precautionary measures” be taken with the construction of any new high voltage transmission lines. These insights, along with our heightened awareness of the existing 138kV lines through Tsawwassen, continue to raise concerns among residents about the heath impact of EMF and other impacts of these lines on people in schools like SDSS, homes, daycares and extended care facilities that are on or near them.
As discussed with you in our meeting, EMF levels in homes along the right-of-way are currently in the 25-50mG range. This far exceeds levels normally found in homes in North America (less than 1% of the population in the United States live in homes with levels over 6mG). BC Hydro has taken steps to address concerns about EMF levels for other residents in BC and we expect the same consideration given the uniquely close proximity of the existing lines to our homes, parks and high school.
At SDSS for example, our EMF readings there have repeatedly shown levels of 30 to 75 mG beneath the existing 138kV lines, and 12-14 mG at the closest school building wall. These levels are in excess of the 2-10 mG exposures suggested by many health-related EMF studies. As well, students have expressed concern about the potential “fall zone” issues in the event of an earthquake associated with the existing poles and lines possibly falling across and blocking the school’s emergency exits due to their proximity to it.
In view of these concerns, we have requested BCTC to remove the existing 138kV high voltage overhead transmission lines through residential Tsawwassen, including where they cross SDSS and Dennison Park, as part of constructing the first phase of the VITR Project.[1] We recognize that cost and reliable service to the southern Gulf Islands are very important for BCTC, and that the existing 138kV transmission lines through Tsawwassen currently provide this service. We also recognize that long term costs are a very important part of project considerations. In that regard, as you are aware, we presented two suggested options that would yield significant positive financial and other benefits to BCTC and South Delta, while advancing the removal of the existing 138kV lines as part of the first phase. We estimate that the net financial benefits, after accounting for costs, would be in the order of $20 million to $28 million depending upon the option.
We have briefed our MLA, Mayor and Council, the CAO of Delta and the Delta School Board regarding our concerns about the impacts of the existing 138kV transmission lines remaining, our two suggested options and their benefits and continue to update them on the progress of our discussions.
3. Insufficient public consultation by BCTC in the process for planning the route of the VITR Project through South Delta – Mr. Costello and the Minister of Energy, Richard Neufeld stated that BCTC would provide opportunities for public input into the final route selection for the VITR Project, both from residents and Delta municipality. We were disturbed to be informed at our meeting on Friday, that BCTC is holding a public information meeting in Tsawwassen on May 31, 2005, at which it will announce the final route of the VITR Project through South Delta that it will recommend to the BC Utilities Commission (the “BCUC”) when it submits it application, scheduled for late June. Based upon our discussions with you, our understanding is that this meeting will be the full extent of the public consultation with South Delta residents before BCTC submits its application to the BCUC. You also advised us, that should your decision not be amenable to the residents of South Delta, that we can intervene at the BCUC hearings later this year. We believe that this method of consultation is not in keeping with either the spirit of the 21st century or the provincial government’s commitment that crown corporations will hold meaningful and open dialogue on such important issues.
We are disappointed that Delta Municipality, TRAHVOL, and others will not have had an opportunity to provide feedback and input on the recommended route that BCTC is considering before the public announcement, as Mr. Costello and Minister Neufeld had earlier promised. Furthermore, while we do not know which recommended route will be announced at the meeting and are not pre-judging it, we are concerned that BCTC is not allowing Delta Council, South Delta residents and others sufficient time after the meeting on May 31th to provide thoughtful and constructive feedback and input to BCTC regarding its recommended route before it submits its application to BCUC in late June.
We have worked constructively over the last 6 months to ensure a resolution to this issue that satisfies the requirements of BCTC to provide reliable power to Vancouver Island and also addresses the socio-economic concerns of the residents of South Delta. We are determined to continue to do so until these goals are accomplished.
We remain optimistic that BCTC’s recommendation on Tuesday, May 31st will recognize the concerns of the residents, schools and the municipality for the continued and future prosperity, health and well being of the South Delta community.
We remain available for further consultation at your convenience.
TSAWWASSEN RESIDENTS AGAINST
HIGHER VOLTAGE OVERHEAD LINES
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Neil Atchison, P.Eng. |
Cecil Dunn |
Cc. Honourable Richard Neufeld – Minister of
Energy and Mines.
Honourable Bill Barisoff – Minister of
Water, Lands and Air Protection
Honourable George Abbott – Minister of Sustainable Resource Management
Honourable John Cummins – Member of Parliament
Honourable Valerie Roddick – MLA Delta South
Chief Kim Baird, Tsawwassen First Nations
Mayor Jackson and Council –
Corporation of Delta
Dr.
Sheila Wynn, Deputy Minister of Energy and Mines
Gordon Macatee, Deputy Minister
of Water, Lands and Air Protection
Chris Trumpy – Deputy Minister of Sustainable Resource Management
Joan Hesketh - Executive
Director, BCEAO
Dave Carter – Senior Program Officer
-CEAA – Pacific Office
George Harvie – CAO – Corporation of
Delta
Michael
Costello, Vice Chair, BCTC
Bob Elton – President and CEO –
BC Hydro
Dennis Maniago- Vice President –System
Planning- BCTC
Bruce Barrett – Program Manager – VITR Project