To: Ms. Autumn Cousins Manager, Policy and Compliance BC Environmental Assessment Office, via Email to autumn.cousins@gov.bc.ca and eao.compliance@gov.bc.ca PO Box 9426 Stn Prov Govt Victoria, BC V8W 9V1 October 30, 2014 From: Mr. Graham Holt, ACMG, Professional member CAA General Manager, RK Heliski Invermere, B.C. RE: Extreme Avalanche Hazard at New Jumbo Glacier Resort (JGR) Daylodge Building Site RK Heli-Ski Panorama Inc. has prepared a summary report in order to provide accurate and detailed information with respect to the substantial construction, for Jumbo Glacier Resort (JGR). Our company has operated for 44 years providing heli-ski adventures to clients from 52 different countries. The purpose of this report is to communicate to you our most recent and important findings with respect to the public avalanche danger and the new location of the JGR daylodge and service buildings in an obvious high frequency, high magnitude avalanche path. We believe that the location is in direct contravention of the EA Certificate condition #36: the proposed residential and commercial structures will be located completely outside the avalanche hazard area. RK Heliski has been a land steward of the Jumbo Region for a remarkable 44 years. We have diligently monitored wildlife and worked with government agencies with respect to species at risk and other environmental initiatives. RK also has been professionally engaged in the exchange of information regarding transportation (BC Ministry of Transport), forestry, public safety and other topics of concern in the region for many years, far before the Jumbo Glacier Resort was started. It is our professional opinion and our direct experience that avalanches will continue impacting public safety on the Toby Creek Road, Jumbo Creek Forest Service Road and the Upper and Lower Jumbo Valley. We serve our community as a search and rescue agency for backcountry user groups, commercial business or stakeholders. Over the past four decades, we have provided numerous rescues where the outcome would have been different if we were not in the area.
We are uniquely and expertly qualified to comment on public safety in this remote wilderness area, most specifically with respect to avalanche danger. It is in this regard that we write to you. On Sept.5, 19, and Oct. 25 2014, we toured the Upper Jumbo Valley to witness the state of affairs with JGR. To our shock, we saw a valley being destroyed by this last ditch effort to show substantial progress on this project. We noted that the building site for the daylodge was changed at the last minute; this new location is now within a large and active avalanche path. Given the new location for the building site, we would like to share RK s valuable 44yr history of witnessed natural avalanches and explosive triggered avalanches that will provide significant evidence to show that this new lodge location poses a significant public safety and related infrastructure risk. Please note that although the video footage (YouTube, here) and supporting photographs included in this letter are from explosive triggered avalanches, the Jumbo area also experiences numerous naturally occurring avalanches that produce the same or more destructive potential, as those illustrated in this letter. The potential for similar, naturally occurring size 4 avalanches is clear and is evident historically through typical avalanche mapping techniques, trim line evaluations from previous events as well as tree coring to determine stand age throughout the valley. Class 4 avalanches are defined as follows: https://www.avalanche.ca/cac/library/research-and-articles/avsize Size 4 Avalanches Could destroy a railway car, large truck, several buildings or up to 4 hectares of forest. Typically: Mass: 10,000 tonnes Run: 2,000 meters Force: 500 kilopascals Every year, RK Heliski witnesses numerous natural large scale avalanches in the Upper and Lower Jumbo Valley. The location of JGR-building sites, workers, guests are at significant risk from large scale avalanches. RK Heliski maintains a data base of yearly weather in the Upper Jumbo Valley, which is at the height of the Purcell Mountain range with peaks of over 10 000ft. Weather systems from the West cross over these 10 000ft peaks, producing heavy snowfalls. Typical storm cycles can range from 24hrs-days/weeks, with snowfall accumulations of over 2.5m during these time periods.
Avalanches are common during these time periods. Snowfall can range between <1-8cm/hr Significant storm cycles can produce snowfall deposits of 1.5m or greater in 48hrs Attached within this document are photos taken within the Upper Jumbo Valley of an explosive control run completed by RK staff following a significant storm cycle. We do not complete avalanche control work after every storm as our operation allows us to choose terrain with a lower risk of avalanche potential thus limiting our exposure and vulnerability for workers and guests. On some occasions, we may choose to control the terrain (reduce the potential risk through helicopter bombing), to ensure the safety of guests, workers and the aircraft (this is a common practice done throughout the heliski industry). A stationary facility such as the daylodge in the new proposed site, would not have the option of avoidance. In the Purcell Mountain range, it s expected that you can have these size 4 avalanches or larger, naturally occur at anytime of the year when the conditions are optimal. RK Heliski regularly uses avoidance of certain terrain during these time periods because the avalanche potential cannot be mitigated due to weather. This is a luxury not available in the case of a permanently and dangerously sited building, as is the case with the newly constructed and hastily relocated daylodge. New JGR Daylodge siting in Class 4 avalanche path Pink Panther Below is a Google Earth snapshot and supporting KML file which outlines the current JGR daylodge building site and smaller building site (service building) in relation to historical avalanches. The red square in the following images is the current location of the daylodge building site for Jumbo Glacier Resort (see also photograph page 6 for building location sites approved in the JGR development plans). The included photos are from 2009 during an explosive controlled avalanche in a ski run named Pink Panther for reference. Glacier Resorts Ltd. recently removed a significant number of trees that used to limit the vulnerability from avalanches at this site. Now that there are no trees in the valley bottom due to JGR clearing the area for its building sites, anything at this site will be at a higher degree of exposure, vulnerability and associated risk of avalanches. The building sites, workers and potential guests are at a very high degree of risk from avalanches impacting the area.
2009 Pink Panther Avalanche approaching 2014 daylodge site
The size 4 avalanche shown here from 2009 was a dry powder avalanche; estimated speed at maximum velocity approximatly 200 km/hr. 2009 Pink Panther Avalanche striking 2014 daylodge site See also attached high resolution photographs, photograph #s 018, 014, 016, and photo titled towards building site south view.
The Google Earth snapshot below shows the precise GPS d location of the main building site and the smaller building site that were undertaken this summer of 2014 by Glacier Resorts Ltd. The Blue outline represents the current avalanche path. The red outlines the 2009 avalanche that covers the building sites. The other outline highlighted avalanche path in the Google Earth snapshot is the avalanche path called Rod s (shown in Purple). This current outline, shows the avalanche potential over time and large tracks of forest that have been obliterated towards the original proposed building site for JGR (see photo 29). The hyperlink below shows the size 4 avalanche on the Google Earth map above from Mt. Karnak. In the last 15sec of the video, you see the area where the existing building site is for JGR (lower left of video). This avalanche hit the valley bottom and climbed up the other side of the valley by another 300m (Pink Panther avalanche path). Significant avalanche debris flowed left or South, downstream towards the
building site. Avalanche debris deposits in the valley floor were approximatly 5-15m in depth. This video was from 2013-February. Size 4 avalanche. http://youtu.be/8kyu-l6vdyy While the direct risk of severe avalanche in the Jumbo Valley is of clear concern, this is not the only example we wish to bring to your attention. Rocket Slide Path Km 14 Toby Creek Road The Google Earth image below is an avalanche path that produced a natural size 4 avalanche in January (see two attached high resolution photos of the Rocket slide path impacting the Toby Creek Road in January 2014). The location was at km 14 of the Toby Creek Road and blocked access beyond for the entire winter. This is one avalanche example of many last winter that had destructive force to obliterate mature stands of trees, widening and lengthening potential avalanche paths to historical run outs. Last winter, there were many historical events that impacted the Toby Creek Road and the Jumbo Creek Forest Service Road.
Toby Creek Damming KM 18 Another significant example was the damming of Toby Creek at km 18, with a deposit of 15-20m of avalanche debris that backed up Toby Creek for a period of 10 days as well as stacking mature trees and avalanche debris on Toby Creek Road (again blocking access until this past June). We felt that this had potential to back up flood water, posing a risk downstream. Our concern was the rapid erosion of the backed up flood water of the dam caused by the avalanche debris and the potential safety risk downstream towards the community of Panorama village. This avalanche caused enough concern to warrant contacting provincial emergency services to investigate the damming of Toby Creek, so that downstream, innocent public, hiking, cross country skiing or snowshoeing would not be at risk.
Conclusion: While RK Heliski delivers adventures of a lifetime for our clients, we also maintain the highest standards of safety for employees and guests. Public safety is our highest priority. We provide a trained wilderness emergency response capability and we are proven land stewards of the area. In short, we are uniquely and expertly qualified to comment on avalanche hazard in the Jumbo Valley. We state very clearly, Jumbo Glacier Resort infrastructure, workers, and potential guests are at risk of large scale avalanches that cannot be mitigated. EAO Certificate condition #36 states: The Proponent has committed that the proposed residential and commercial structures will be located completely outside the avalanche hazard areas. With the amended daylodge siting, this condition has been dangerously violated. Thank you for your time and consideration. If you need any additional information, please feel free to contact me. 250 342 3889 Sincerely, Graham Holt General Manager RK Heliski Cc: Kathryn Teneese, Chair, Ktunaxa Nation Council Norm Macdonald, MLA-Columbia River-Revelstoke Doug Caul, EAO Associate Deputy Minister Paul Craven, EAO Executive Director of Policy and Quality Assurance Minister of Environment, Honourable Mary Polak Minister of Community, Sport and Cultural Development, Coralee Oakes Psyche Brown, Sr. Manager, Mountain Resorts Branch