TABLE OF CONTENTS

INFORMATION REQUEST NO. 2 ...... 2 ENGINEERING MATTERS ...... 2 2.1 Trenchless Watercourse Crossings Feasibility Studies ...... 2 2.2 Trenchless Crossings - Construction Risk Assessment ...... 3 2.3 Trenchless Crossings – Contingency Plans ...... 5 ENVIRONMENT MATTERS ...... 6 2.4 Wetlands ...... 6 2.5 Caribou Range ...... 7 SOCIO-ECONOMIC MATTERS ...... 8 2.6 Historical Resources ...... 8

1 NOVA Gas Transmission Ltd. (NGTL) Sections 58 and 52 National Energy Board Act (NEB Act) NGTL 2021 System Expansion Project (Project) File OF-Fac-Gas-N081-2018-03 02 Filed 20 June 2018 Hearing Order GH-003-2018

Information Request No. 2

Engineering Matters 2.1 Trenchless Watercourse Crossings Feasibility Studies Reference: i) NGTL, Application, Section 8.8.4 Watercourse and Road Crossing Construction, pages 8-9 to 8-10 (PDF Pages 133 to 134 of 244), A92619-1

ii) NGTL, Application, Appendices 8-1 and 8-2 Preliminary Feasibility Reports for and Crossings (PDF pages 1 to 72 of 72), A92619-4

iii) NGTL, Application, Appendices 8-3 to 8-7 Preliminary Feasibility Reports for the Simonette River, , McLeod River, , and North Crossings (PDF pages 1 to 118 of 118), A92619-5

iv) NGTL, Additional Written Evidence, Section 2.1.3.1 Change of Proposed Construction Methodology for the Simonette River, page 2- 10 (PDF Page 19 of 74); Section 2.4 Terrain, Geotechnical and Hydrotechnical Assessments and Section 2.5 Watercourse Crossings, page 2-20 (PDF page 29 of 74), A96812-1

v) NGTL, Additional Written Evidence, Appendix 2-5 Wapiti Feasibility Report (PDF pages 1 to 47 of 47), A96812-6

Preamble: Reference i) states that NGTL will use both trenchless and trenched (isolated and open cut) crossing techniques to cross watercourses along the right of way (RoW). Trenchless crossing methods were originally proposed at the Wapiti River, Smoky River, Simonette River, Little Smoky River, McLeod River, Pembina River, and . NGTL changed the primary crossing method for the Simonette River from a trenchless to a trenched method (Sections 2.1.3.1 and 2.5 of Reference iv). Reference i) states that a trenchless crossing method will also be used to cross Highway 11 in the Brewster Section, Highway 743 in the Karr Section, and Highway 672 and Highway 59 in the Valhalla Section.

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NGTL has submitted preliminary feasibility reports for the proposed trenchless river crossings (References ii) and iii)). The preliminary feasibility reports contain horizontal directional drilling assessments for the crossings based on geological and existing borehole information in the area. Section 2.4 of Reference iv) states that the geotechnical program for the Smoky River, Little Smoky River, McLeod River, Pembina River and North Saskatchewan River is ongoing and that NGTL will submit updated trenchless feasibility reports when they become available. A revised feasibility report for the Wapiti River was provided (Reference v). The NEB (the Board) notes that the information used for these feasibility reports is general and lacks site specific data.

Request: For the trenchless crossings at the Wapiti River, Smoky River, Little Smoky River, McLeod River, Pembina River, North Saskatchewan River, Highway 11, Highway 743, Highway 672 and Highway 59, please provide the following: a) The final selected trenchless crossing method that will be used; b) The geotechnical investigation reports performed by NGTL at all of the proposed trenchless crossing locations; c) The final feasibility reports based on the result of the geotechnical investigations performed at those locations; d) If for any of the trenchless river or highway crossings, the geotechnical investigation or feasibility studies have not yet been performed or ready, provide a timeline when these studies will be available.

2.2 Trenchless Crossings - Construction Risk Assessment Reference: i) NGTL, Application, Section 7.1.3 Project Component Tie-Ins and Routing (PDF pages 95 to 98 of 244), Section 7.6 Terrain, Geotechnical and Hydrotechnical Assessments (PDF page 120 of 244), Section 7.7 Pipeline Watercourse Crossings (PDF page 123 of 244), and Section 8.8.4 Watercourse and Road Crossing Construction (PDF page 133 of 244), A92619-1 ii) NGTL, Application, Appendices 8-1 and 8-2 Preliminary Feasibility Reports for Wapiti River and Smoky River Crossings (PDF pages 1 to 72 of 72), A92619-4 iii) NGTL, Application, Appendices 8-3 to 8-7 Preliminary Feasibility Reports for the Simonette River, Little Smoky River, McLeod River, Pembina River, and North Saskatchewan River Crossings (PDF pages 1 to 118 of 118), A92619-5

3 iv) NGTL, Additional Written Evidence, Appendix 2-5 Wapiti Feasibility Report (PDF pages 1 to 47 of 47), A96812-6

Preamble: Reference i) states that trenchless crossings will be considered at watercourse and highway crossings. References ii), iii), and iv) provide a preliminary and basic assessment of the risks and the main possible mitigation strategies developed to minimize the challenges that may arise during construction. The Board notes that in References ii), iii) and iv), the trenchless construction risk assessment results (i.e. low risk to very high risk) and explanations are not provided for before and after mitigation strategies are implemented.

Request: For the trenchless crossings at the Wapiti River, Smoky River, Little Smoky River, McLeod River, Pembina River, North Saskatchewan River, Highway 11, Highway 743, Highway 672 and Highway 59, please provide the following: a) The construction risk assessments and the risks associated with the selected trenchless method including the following: a.1) probability, consequence and risk categories without any mitigation; and a.2) probability, consequence and risk categories with proposed mitigation. b) Descriptions of risk categories, including: b.1) probability ratings or categories; b.2) consequence ratings or categories, as well as the factors considered (e.g. public and/or workers safety); and b.3) risk categories, as well as the response(s) required for each risk category. c) If applicable, for each identified risk that is categorized as “high” or “very high” after mitigation: c.1) estimated probability of failure associated with the identified risk based on the previous experience; c.2) detailed description of the consequence; and c.3) if the risk is associated with high or very high level of public and/or workers safety, demonstrate that NGTL can safely conduct the construction activities.

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2.3 Trenchless Crossings – Contingency Plans Reference: i) NGTL, Application, Section 8.8.4 Watercourse and Road Crossing Construction, pages 8-9 to 8-10 (PDF pages 133 to 134 of 244), A92619-1 ii) NGTL, Application, Appendices 8-1 and 8-2 Preliminary Feasibility Reports for Wapiti River and Smoky River Crossings (PDF pages 1 to 72 of 72), A92619-4 iii) NGTL, Application, Appendices 8-3 to 8-7 Preliminary Feasibility Reports for the Simonette River, Little Smoky River, McLeod River, Pembina River, and North Saskatchewan River Crossings (PDF pages 1 to 118 of 118), A92619-5 iv) NGTL, Additional Written Evidence, Section 2.1.3.1 Change of Proposed Construction Methodology for the Simonette River, page 2- 10 (PDF Page 19 of 74) and Section 2.5 Watercourse Crossings, page 2-20 (PDF page 29 of 74), A96812-1 v) NGTL, Additional Written Evidence, Appendix 2-5 Wapiti Feasibility Report (PDF pages 1 to 47 of 47), A96812-6

Preamble: Reference i) states that trenchless methods will be used to cross the Wapiti River, Simonette River, Smoky River, Little Smoky River, McLeod River, Pembina River, and North Saskatchewan River. The primary crossing method for the Simonette River was later changed from a trenchless to a trenched method (Reference iv). Pipe thrusting was discussed as a contingency for the proposed Horizontal Directional Drilling (HDD) of the Smoky River (Reference ii), and Little Smoky River, McLeod River and North Saskatchewan River (Reference iii). References ii) and iii) also state that for these rivers, an isolated construction method is proposed if the trenchless method fails. For the Pembina River, the contingency plan was identified as an isolated construction method (Reference iii). No contingency plan was described for the Wapiti River (Reference v) or any of the proposed trenchless highway crossings at Highway 11, Highway 743, Highway 672 and Highway 59. The Board requires additional details regarding contingency plans.

Request: For the trenchless crossings at the Wapiti River, Smoky River, Little Smoky River, McLeod River, Pembina River, North Saskatchewan River, Highway 11, Highway 743, Highway 672 and Highway 59, please provide the following: a) A proper identification of the primary construction method and contingency plan that NGTL plans on performing at each of the listed watercourses and highway crossings;

5 b) The construction procedure associated with the isolated construction method if selected as a contingency plan; c) An identification of the geohazards that might have to be dealt with if the contingency plan is implemented instead of the trenchless installation method; and d) A risk assessment if the contingency plan consists of another trenchless installation approach, including mitigation methods of the identified risks and rating of the associated risks as per IR 2.2.

Environment Matters 2.4 Wetlands Reference: i) NGTL, Environmental and Socio-economic Assessment (ESA), Sections 9 and 10, Section 10 Wetlands, 10.1.3.1 Literature Review, Page 10-2 (PDF page 54 of 114), A92619-12

ii) NGTL, ESA Update, Appendix F: Wetlands, Page 2-2 (PDF page 11 of 63), A94156-8

iii) NEB Filing Manual, Guide A – A.2, ESA, Table A-2 Filing Requirements for Biophysical Elements, Page 4A-51 (PDF page 109 of 285)

Preamble: Reference i) states that the results of the field studies will provide site- specific information to confirm baseline conditions. Reference ii) states that plot locations were chosen within representative wetlands from each category of wetland (bogs, fens, swamps, marshes and open water) within each section of the Project Footprint. Reference ii) further states that a wetland plot form was completed for each wetland encountered within the Project Footprint to describe basic wetland functions. Filing requirements for wetlands outlined in Reference iii) include the current level of disturbance, as well as the identification and description of wetland capacities to perform hydrological, water quality, habitat or other ecological functions. The Board notes that the level of disturbance and wetland functions for the ground-truthed wetlands within and adjacent to the Project RoW were not discussed or provided.

Request: Please provide the following information per pipeline section, for the wetlands located within and adjacent to the Project footprint: a) A discussion and summary of the current level of disturbance; and b) A discussion and summary of the site-specific wetland functions.

6 2.5 Little Smoky Caribou Range Reference: i) NGTL, ESA, Sections 12 to 16, Section 12.3.4 Woodland Caribou, Pages 12-2, 12-50 and 12-51 (PDF pages 6, 54 and 55 of 362), A92619-14

ii) NGTL, ESA, Appendices C to K, Appendix I: Preliminary Caribou Habitat Restoration and Offset Measurement Plan, Section 2.0 Affected Caribou Range and Project Effects, Pages 2-1 to 2-2 (PDF pages 288 to 289 of 559), A92619-19

iii) Government, Draft Alberta Provincial Woodland Caribou Range Plan, 2017, page 59 (PDF page 136 of 212) (PDF copy attached)

Preamble: References i) and ii) state that 95% of the Little Smoky caribou range is considered to be disturbed by anthropogenic and natural (fire) disturbances. The source of this information is noted as Environment (2012) in Reference i) and Environment Canada (2011) in Reference ii). References i) and ii) indicate that the proposed Project will have a RoW width of approximately 42 metres through the Little Smoky caribou range. References i) and ii) state that based on the proposed Project layout and existing disturbance, construction of the Project will result in approximately 98.3 hectares of incremental direct disturbance and approximately 0.5 hectares of incremental indirect disturbance to undisturbed habitat. Reference iii), dated 2017, states that the Little Smoky caribou range is currently considered to be 99% disturbed by natural and anthropogenic footprints, including the federal 500 metre buffer zone. The Board notes the discrepancy between the level of disturbance identified in References i) and ii) for the Little Smoky caribou range with the more recent information provided in Reference iii). The Board needs to understand what the impact of the proposed Project will be based on the level of disturbance identified in Reference iii).

Request: Please provide:

a) A discussion of whether NGTL was aware of this publication (Reference iii) at the time of filing its Project application, and if so, why it was not used or referred to in NGTL’s Project application or Additional Written Evidence filings; b) A copy of the document on the Board’s record for the NGTL 2021 System Expansion Project; and c) An analysis and discussion of how the proposed Project will impact the Little Smoky caribou range using the information

7 provided in the 2017 Draft Alberta Provincial Woodland Caribou Range Plan (Reference iii) above) regarding the current levels of disturbance. The analysis and discussion should include both the ESA (Reference i)) and the Preliminary Caribou Habitat Restoration and Offset Measurement Plan (Reference ii) that were provided in the Project application.

Socio-Economic Matters 2.6 Historical Resources Reference: i) NGTL, Response to NEB Information Request (IR) No. 1, IR 1.29 Historical Resources (PDF Pages 383 and 384 of 384), A96810-1

Preamble: In Reference i), NGTL stated that it will determine interest and potential opportunities for participation of Indigenous peoples in further historical resource work, if any, following the receipt of decisions from Alberta Culture and Tourism (ACT).

Request: When does NGTL anticipate receiving these decisions from ACT?

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