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LLG sends letter to Mr. Mark Johns of AltaLink

December 2014

Below is as letter LLG sent to Mr. Mark Johns of AltaLink.

To read AltaLink's response to this, go to "Response to LLG".  Also below is the letter to Premier Prentice.


Mr. Mark Johns
Director, Stakeholder Engagement & Special Initiatives
AltaLink
2611-3 Ave SE
Calgary, Alberta T2A 7W7

December 15, 2014

Dear Mark,

We thank you for the time you and your colleagues, Colin Harvey and Kyle Klages took to meet with us on Saturday, Dec. 6 at the home of Norma Dougall regarding the proposes Castle Rock to Chapel Rock transmission line.  We are writing this letter to confirm the discussion and to confirm the subsequent expected actions AltaLink undertook.  We would appreciate a written response to ensure our understanding of your approach is clear.

Our questions were as follows:

  1. The currently proposed routes, for the large part, do not follow existing disturbed corridors or use existing infrastructure for their entirety.  Given that this priority has been stated both by AltaLink and the AUC, why are there not any proposed routes following this direction?
  2. The proposed routes do not offer any alternatives other than standard lattice towers traversing one of the most prized viewscapes in Alberta.  Why are there no alternatives using underground or monopole designs to minimize the negative impact to a view enjoyed by hundreds of thousands of people who specifically use Highway 22 because of the viewscapes?
  3. The South Saskatchewan Regional Plan was recently brought into force and in a recent public presentation by AESO, it was stated that all proposed development would need to be reviewed in light of this.  Have you or are you planning to undertake this review and if so, who would undertake it and would the results be available to LLG?
  4. For a number of years, the Province has been developing plans to twin Highway 3.  It would make complete sense to partner with the Ministry of Transportation uto accomplish both your proposed line and their development into a single transportation utility corridor, minimizing linear disturbance and disturbance of native land.  Have you considered this? 

You had two requests of us.

First, whether we could provide the environmental maps that LLG had developed.   The files are very large so I have not attached them, however you will see an email from Bill Trafford with a DropBox link to access the maps and documentation.  If you should have any difficulty please feel free to contact Bill Trafford directly at (403) 804-8841.

Second, you had asked us whether we had done any work regarding mapping the viewscape.  As we said, we are considering this but have no LLG expertise in doing this and would look to the Miistakis Institute who developed the above referenced maps on our behalf.  We would suggest you contact Miistakis directly (whose expertise is mapping, to further your understanding of the possibilities.  Our contact is Greg Chernoff . His contact information is:

Greg Chernoff, BA2, MSc – Senior Research Associate / Spatial Analyst
Miistakis Institute
Mount Royal University, Rm U271
4825 Mount Royal Gate SW
Calgary AB  T3E 6K6
ph 403.440.8444 – fax 403.440.8446 – email greg@rockies.ca – www.rockies.ca
Innovative Research. Engaged Communities. Healthy Landscapes.

We look forward to your response.

Respectfully,

Livingstone Landowners Guild
Ted Smith, President.


Following is LLG's letter to Premier Prentice, outlining our position on the current planned AltaLink routes.


January 26, 2015
The Honourable Jim Prentice
Premier of Alberta
Legislature Building
307 - 10800 97 Avenue 
Edmonton, Alberta T5K 2B6

Dear Mr Prentice,

The Livingstone Landowners Guild (LLG) is an association of approximately 80 landowners in Southern Alberta between the Livingstone Range, the Porcupine Hills the Whaleback and Oldman Dam to the west, east, north and south respectively.  These members range from 3rd generation ranchers to acreage owners and property owners who have moved into the area from other parts of the world. Our goal is to ensure that any necessary development in this area respects this unique environment and if development is deemed appropriate, that it is done with best practices to ensure the native habitat and landscape is protected for our members but as importantly, all Albertans.  We have worked with a number of proposed development proponents over the years and to a large degree they  have significantly altered their plans as a result of our efforts.

The LLG is writing to request that you question the Alberta Utilities Commission on the need for the proposed Castle Rock Ridge to Chapel Rock transmission line in southwest Alberta. The basis for the line is described in the Southern Alberta Transmission Reinforcement plan developed more than 7 years ago.  Since then many of the precepts and assumptions used to develop the plan have changed significantly, particularly as it relates to in the wind energy industry in the Pincher Creek area. AESO’s recent cancellation of a major power line in the area (attached), and AESO’s recent announcement that the addition of the Shepherd gas-fired generation facility and the development of new wind farms has vastly reduced the impact of an event such as occurred in 2011 (attached), point out the degree of change that has occurred since 2007. 

The premise in SATR for the Castle Rock to Chapel Rock transmission line has been a) to allow more wind development in the Pincher Creek area and b) to provide “redundancy” to avoid a repeat of the 2011 power generation shortage.  Both of these are no longer true or needed based on AESO’s own analysis. New wind development in the area is not needed and the new generation capacity (wind and natural gas in other areas) has effectively negated the redundancy issue.  It would certainly appear that moving forward with this line is largely in AltaLink’s interest but has very little to do with the public interest. In a time of economic restraint, unnecessary infrastructure development would be imprudent.

The LLG believes that existing wind generation in the Pincher Creek area is functioning well with recent transmission upgrades and does not need this added Castle Rock Ridge-Chapel Rock line. Over 90% of the proposed wind projects in the Alberta Electric Service Operator (AESO) queue were initially stalled by lack of transmission access; however as explained above, these projects are no longer economically viable. The AESO must stay current with market realities to insure costly transmission projects are not built using outdated rationale.

The Highway 22 corridor and surrounding areas have some of Alberta’s most precious ecological and cultural assets.  The Government of Alberta recently approved the South Saskatchewan Regional Plan.  The development of the proposed transmission line, as currently proposed by AltaLink, transgresses a number of the tenets put forth in the SSRP. This proposed line is not simply an issue of transmission line engineering, but rather an issue of greater social and economic implication to Albertans and visitors to the area. As you, personally, have a long history in this area, you are no doubt aware of the importance of maintaining the natural integrity of the Eastern Slopes and the viewscapes seen by tens of thousands of Albertans and tourists every year.   AltaLink’s proposals offer few alternatives other than to cross miles of native, undisturbed land with lattice towers on the basis  of least cost and fewest inhabitants to deal with.  LLG has spent a great deal of effort through the Miistakis Institute to provide factual information from public data bases in the form of maps that show the environmental sensitivity. An example is attached.

We believe that this  project would be a waste of rate -payer dollars and have significant negative impact on one of Alberta’s most scenic and ecologically valuable landscapes. Re-evaluation of need and subsequent cancellation of other portions of the Southwest Alberta Transmission Reinforcement (SATR) has already occurred due to changes in generation forecasts. The LLG argue that this Castle Rock Ridge-Chapel Rock project should  be re- evaluated and potentially cancelled. 

The LLG believe that this project should be viewed in the manner you are reviewing all infrastructure projects.   If a needed cancer facility in Calgary is to be deferred, why would an arguably unnecessary and environmentally damaging project such as this proceed?  Further Increasing the burden on tax payers for electricity at a time when constraint and potential new taxes are necessarily being discussed would seem disingenuous at best.  

Thank you for your time and consideration of this request.

Livingstone Landowners Guild

Ted Smith, President