October 6, 2011 E-FILE
Attention: Ms. Anne-Marie Erickson Secretary to the Joint Review Panel Enbridge Northern Gateway Project
National Energy Board 444 Seventh Avenue SW Calgary, AB T2P 0X8
Dear Ms. Erickson,
Re: Northern Gateway Pipelines Application to the National Energy Board Enbridge Northern Gateway Project OH-4-2011 NEB File No: OF-Fac-Oil-N304-2010-01 01 Northern Gateway Responses to Round 1 Information Requests (Other organizations
Northern Gateway Pipelines Limited Partnership (“Northern Gateway”) herewith files its responses to the following Information Requests:
1. BC Nature & Nature Canada IR No. 1 2. District of Fort St. James IR No. 1 3. Federal Government IR No. 1 4. Fort St. James Sustainability IR No.1 5. Kinder Morgan IR No. 1 6. Living Oceans Society, Raincoast Conservation Foundation and ForestEthics (“Eco Justice”) IR No. 1 7. Northcoast Cetacean IR No. 1 8. Northwest Institute IR No. 1 9. Province of BC IR No. 1
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These documents are being filed electronically with the Board and will be served upon all OH-4- 2011 Parties.
Yours truly,
Ken MacDonald Vice President, Law and Regulatory Northern Gateway Pipelines Limited Partnership
Enclosures cc: CEAA Attention: Carolyn Dunn
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Northern Gateway Response to Federal Government IR No.1 Page 1 of 246 Joint Review Panel Hearing Order OH-4-2011 Respecting the Enbridge Northern Gateway Project File No: OF-FAC-OIL-N304-2010-01 01 Information Requests Round # 1 to the Applicant Government of Canada
Information Request Number 1
GENERAL - Engineering, Construction and Operation
Managing known and unknown contaminated sites and materials.
1 Reference: Volume 3, Section 10, Construction In 1993, a spill of crude oil took place on the Pembina Right of Way following a pipeline rupture on the Alexis First nation at 13-13-060-13 W5M.
Preamble: Aboriginal Affairs and Northern Development Canada requires more information on measures to be taken if contaminated materials are encountered during the construction of the proposed Enbridge Northern Gateway pipeline.
Request: Please confirm what measures will be taken if contamination from pre-existing accidental releases (e.g. the 1993 Pembina Pipeline Corporation spill) or other anthropogenic activities, is encountered during construction and operation of the proposed Enbridge Northern Gateway pipeline, including contaminant assessment and management.
Response: Northern Gateway will design and implement monitoring programs including the collection of baseline monitoring data as required by federal and provincial regulations. Prior to construction, baseline data will be collected. Duration and frequency of sampling and list of analytes (e.g., petroleum hydrocarbons (“PHCs”), polycyclic hydrocarbons (“PAH”), and naphthenic acids (“NAs”)), will be finalized before construction begins. However, if despite baseline sampling contamination is encountered during construction a site-specific plan will be developed to address the nature and extent of contamination in consultation with appropriate regulatory authorities.
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Northern Gateway Response to Federal Government IR No.1 Page 2 of 246
Line Pipe and Weld Material Properties
2 Reference: Volume 3 : Engineering, Construction and Operations, Section 5.1 and 5.2, Pages 5-1 to 5-2 Northern Gateway Response to Request for Additional Information from JRP Session Results and Decision dated January 19 2011 (A28714) Sections C.3.1 and C.3.2, Pages 32-33.
Preamble: In the references Northern Gateway provides an outline of the oil and condensate pipeline design parameters along with describing briefly the welding processes to be used. Also of importance is the assessment of fracture initiation toughness of both the weld metal and HAZ regions.
Request: Two areas of essential concern for the design of pipelines that should be addressed though not stated explicitly are the girth weld and pipe steel toughness in order to avoid long-running ductile fracture (i.e., realizing crack arrest).
NRCan requests that Enbridge provide information on the engineering design of these two aspects. This information would help to further assess the techniques that are being used to prevent running ductile fracture and ensure proper toughness requirements are achieved.
Further information is also requested on the development and qualification of welding procedures and related material property testing methodologies.
In reference ii), Page 33, "Line Pipe Welding Design and Quality Control in Geotechnical and Seismic Areas", states that "If necessary, Crack tip opening displacement (CTOD) testing of the weld and Heat affected zone (HAZ) can also be specified and conducted to confirm weld zone toughness." Since it is recognized that there are different standards for specifying and conducting CTOD tests which may result in a significant difference on test results, the reviewer requests that Northern Gateway specify the selected standard.
Response: As the pipeline would transport low vapour pressure liquids, long-running ductile fractures are not anticipated to be a problem and the toughness requirements permitted by CSA Z662-11, Table 5.1 would generally be applied (i.e., Category I pipe without proven toughness is permitted). During detailed engineering, it is expected that the toughness requirements will be subject to further assessment and, if necessary, toughness would be determined based on a leak-before-break criteria. The Battelle Memorial Institute methodology for fracture initiation would likely be used at some high percentage of the flow stress limits, typically 90%, for a through-wall defect in determining the required initiation resistance requirements. Since fracture initiation would be controlled and considering the decompression characteristics of liquids, fracture propagation and subsequent arrest are not expected to be factors.
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Northern Gateway Response to Federal Government IR No.1 Page 3 of 246
CTOD testing would be conducted in accordance with BSI BS 7448 or ASTM E1290 as modified by CSA Z662-11 Annex K.
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Northern Gateway Response to Federal Government IR No.1 Page 4 of 246
External and Internal Corrosion Control
3 Reference: Volume 3: Engineering, Construction and Operations, Section 5.3, Page 5-2.
Preamble: The approaches proposed by Enbridge to control external corrosion by using protective coating is appropriate and as per current industry best practices. However there is some clarification required on how the compatibility between different coatings will be determined to maintain designed coating properties. There is now a focus to determine the corrosivity of crude oils which can influence the required mitigation steps needed to control internal corrosion. Therefore, steps are needed to confirm that proposed transported hydrocarbons are indeed non-corrosive.
Request: NRCan recommends that Enbridge comment on the following:
It is suggested that field girth weld coating will be compatible with the plant- applied external coating. How will this be ensured? Is there any intention of using ISO 21809-3: Field Joint Coatings Standard?
It is suggested in Section 5.3 that additional mechanical protection will be used where needed. When using concrete coating, for example, how will its compatibility with anti-corrosion coating be established? Is there any intention of using ISO 21809-5: Concrete?
Northern Gateway suggests in the above reference that the hydrocarbons transported will not contain significant corrosive substances. How will this be ensured? The reviewer notes a method outlined in, ASTM G205, which can be used to classify crude oil into four classes in terms of corrosivity during pipeline transportation: 1) preventive hydrocarbon, 2) inhibitive hydrocarbon, 3) neutral hydrocarbon, 4) corrosive hydrocarbon.
Response: Para 1) Northern Gateway will use proven pipeline industry joint coating systems (e.g., FBE, shrink sleeves) with a demonstrated track record of compatibility with the plant-applied external coating. The use of ISO 21809-3 or other appropriate industry standards will be determined during detailed engineering. Enbridge has not experienced issues with compatibility between plant applied external coating and field girth weld coating on recent mainline pipeline projects.
Para 2) The use of ISO 21809-5 or other appropriate industry standards will be determined during detailed engineering. Enbridge has not experienced issues with compatibility between plant applied external coating and concrete coating on recent mainline pipeline projects.
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Northern Gateway Response to Federal Government IR No.1 Page 5 of 246 Para 3) Similar to the Enbridge mainline system, Northern Gateway will monitor incoming crude batches to ensure that they meet the tariff requirements for the oil pipeline. All of the crude will be tested on a receipt basis for adherence to the density and sediment and water (“S&W”) tariff, and viscosity tariff where applicable. The actual blending of the commodity will occur upstream of Northern Gateway and will be the responsibility of the producer/shipper. Enbridge will ensure that the hydrocarbons transported in the Northern Gateway pipelines will not contain significant corrosive substances through the setting of tariff limits on potential corrodents (water, sediment, etc.) and by comprehensively monitoring every batch of product entering the system. Enbridge also continues to explore relevant corrosivity test methods for use in tariff quality crude systems, and is the first Canadian pipeline company to undertake the new ASTM G205 crude corrosivity testing protocol. Enbridge will apply these learnings as knowledge and experience in using and interpreting different test methodologies increases.
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Northern Gateway Response to Federal Government IR No.1 Page 6 of 246
Sporadic or Mountain Permafrost
4 Reference: Volume 3: Engineering, Construction and Operations, Section 5.4, Page 5-3. In the above reference Enbridge mentions that the Cathodic Protection (CP) system for the pipelines will be designed and installed in accordance with the applicable codes and regulations.
Preamble: The approaches to control external corrosion are appropriate as outlined in the Northern Gateway application but the reviewer notices no mention of permafrost along the proposed pipeline route. If sporadic and mountain permafrost is encountered then pipeline design parameters would have to be changed to address issues related to Northern climate, i.e. permafrost conditions.
Request: NRCan recommends that Enbridge comment on whether there is any possibility of traversing sporadic or mountain permafrost along the proposed pipeline path and if encountered what contingencies or pipeline design changes including CP system design would have to be made?
Response: With respect to the potential for encountering sporadic or mountain permafrost, please refer to Northern Gateway’s response to JRP IR 4.3 (mountain permafrost) and Northern Gateway’s response to Eco Justice IR 1.25 (general discussion of permafrost). In brief, no significant permafrost has been identified to date along the pipeline route.
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Northern Gateway Response to Federal Government IR No.1 Page 7 of 246
Tank and marine terminal alternatives
5 Reference: Volume 3: Engineering, Construction and Operations Chapter 2 Alternative Means to Construct the Project 2.2
Edmonton Area Station and Terminal Locations 2.2.2 Kitimat Terminal Location, page 2-2
Preamble: A) As estuaries are particularly sensitive receptors and there is an estuary in close proximity to the Kitimat Terminal, it is important to clarify why this location was chosen over alternative locations.
B) NRCan noted that in other sections of the EIS, detailed information about marine clay at the land-based terminal was provided but limited information on the berth.
It is important to justify chosen terminal sites.
C) It would be informative to see a table of advantages and disadvantages of the site 4 versus all of the other potential sites.
D) Disposal of sediment in the marine environment may cause additional environmental concern.
Request: A) Potential sites at Emsley Cove and Bish Cove were also considered but were not selected because of the incremental pipeline length and associated impacts and costs to reach these more southerly sites, the increased access and land constraints associated with these sites, or because other proposed projects were considering these locations.
Enbridge states: "The location for the Kitimat Terminal was selected based on the following criteria: limited potential effect of shoreline oiling"
Explain this 'limited potential' since it is NRCan's understanding that there is an estuary (which represents a sensitive habitat) near this area, in comparison to site 3 which is further from the estuary.
B) Enbridge states: "Subsurface information was not available for Site 3. However, examination of aerial photographs indicate that bedrock is at, or near, ground surface over much of the area. The topography and subsurface conditions appear to be similar to those at the Kitimat Terminal site. However, a greater volume of rock would have to be excavated to develop Site 3 than the Kitimat Terminal site. Site 3 is zoned for industrial use; however, part of this site footprint extends into a floodplain and is zoned for recreation. This site is close to residential areas in Kitimat and is adjacent to disturbed sites with limited value as habitat for sensitive wildlife; but, it is
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Northern Gateway Response to Federal Government IR No.1 Page 8 of 246 adjacent to fish-bearing streams. The associated marine berth location for Site 3 is a site near the existing Eurocan Pulp & Paper Co. berth. It was determined that the berth site is underlain by marine clays and may be prone to settlement. For this site, the marine berth would be located a long distance away from the tank terminal, thereby creating the need for extended linear infrastructure to link the tank terminal with the marine terminal."
Describe the material present where the site 4 berth is proposed. In addition, provide the results of the geotechnical work.
C) This section provides a list of advantages of the selected terminal site (page 2-3). Provide a comparative table for all considered alternative sites. One of the advantages given in section 2.2 page 2-3 is "Suitable foundation conditions are present for tanks and other major structures. Notably, the proposed site has bedrock at a shallow depth that will provide suitable support for the Terminal equipment with minimal foundation depth penetration while generating smaller volumes of disposal material. These conditions will also limit any potential issues associated with potential seismic activity". In comparison, section 3.3 page 3-7 states: "The in-situ strength and compressibility of the clay is highly variable and it may become unstable when disturbed, either by construction activity or seismic events. The material is not considered suitable as a foundation for structures that cannot tolerate substantial settlements".
Clarify if all clay will be removed down to the shallow bedrock.
D) Chapter 10 Construction Section 10.5 Kitimat Terminal Construction Subsection 10.5.1 Construction Sequencing Tank Terminal.
Enbridge states: "Remove overburden and clay starting with material disposal site, new access road and tank lot."
Confirm whether it is anticipated that any material will be disposed into the marine environment.
Response: A) To respond to this Information Request, it is important to note that the Kitimat Terminal will consist of a tank terminal (i.e., on land storage of hydrocarbons and associated infrastructure) and the marine terminals (i.e., berths for tankers and associated in-water and shoreline infrastructure). Together, these two components are referred to as the Kitimat Terminal.
Four locations were considered for the tank terminal (see Application (Volume 3, Section 2.2.2, Appendix D2)). Of the four locations considered for the tank terminal, only one, the Kitimat Terminal Site, includes a marine terminal component. A comparison of these four tank terminal sites is
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Northern Gateway Response to Federal Government IR No.1 Page 9 of 246 provided in Attachment Federal Government IR 5A). The other three sites (alternate Site 1, 2 and 3 on Appendix Map D2) are sites that would still require access to a marine terminal site. For the three alternative sites, an oil spill that reaches water would have potential to affect estuarine and nearby sensitive marine habitats. All sites are upstream of the estuary; therefore river flows would tend to carry spilled hydrocarbons into the estuary, except during a strong incoming tide (i.e., where the tidal effect is stronger than the river outflow).
In contrast, the Kitimat Terminal site is located furthest from the Kitimat River estuary. While there is potential for tidal currents to carry oil into the estuary, the estuary is upchannel from the site. Therefore, this site would have the lowest potential to affect the Kitimat River estuary.
Of note, of the three sites considered for the marine terminal, the Kitimat Terminal site is considered to be the preferred site in terms of lowest potential for oil retention. As shown on the Douglas Channel Operational Maps D01 and D02 in Polaris (2010), the Kitimat Terminal site is dominated by rock and gravel beaches, whereas the Emsley Cove and Bish Cove sites are dominated by sand, gravel and rock beaches. Oil residency (as shown on the same maps) for the Kitimat Terminal Site is rated as medium (i.e., weeks to months) whereas the oil residency time for Emsley and Bish coves is for rated as long term (i.e., months to years). The Emsley and Bish cove sites are also directly adjacent to stream estuaries and sensitive marine habitats such as eel grass beds. In contrast, the Kitimat Terminal Site is predominantly a rocky intertidal zone.
Reference:
Polaris. 2010. Technical Data Report. Coastal Operations and Sensitivity Mapping for the Confined Channel Assessment Area. Prepared for Enbridge Northern Gateway Project by E. Taylor, Polaris Applied Sciences Inc. Bainbridge Island, Washington, USA
B) The proposed berth site at Site 4 (Kitimat Terminal) is located in an area of steep, irregular bedrock slopes with little to no accumulations of sediment. Work to support the geotechnical assessment included evaluation of multibeam bathymetry surveys carried out in the area of the berths in 2006 in a Project commissioned survey and throughout the regional basin by Canadian Hydrographic Service vessels in 2009 and 2010. In addition to the multibeam bathymetry, the Project commissioned a subbottom geophysical survey that confirmed bedrock is generally exposed across the planned berth site.
C) As noted in the Application (Volume 6B, Section 2), the Kitimat Terminal will also include an excess cut disposal area on land for material cut from
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Northern Gateway Response to Federal Government IR No.1 Page 10 of 246 the tank terminal (e.g., rock and marine clays). The same area will be used for the disposal of dredged material from marine areas. The Project does not include disposal of land or marine waste at sea.
D) Northern Gateway does not propose to dispose of cut material excavated during the development of the Kitimat Terminal in the marine environment.
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Northern Gateway Response to Federal Government IR No.1 Page 11 of 246
Proposed Site Development / Marine Clay Considerations
6 Reference: Volume 3: Engineering, Construction and Operations, Appendix E Supporting Geotechnical Reports Appendix E-3 Preliminary Geotechnical Report Proposed Kitimat Terminal Enbridge Northern Gateway Project Kitimat, British Columbia
Chapter 5 Geotechnical Considerations and Comments for Proposed Site Development Section 5.2 Marine Clay Considerations
Enbridge states: "Weak and compressible marine clay sediments are present over portions of the site, mainly the plateaus, to a wide range of depths. The decrease in strength with depth and total thickness (up to 30 m in some locations) will present particular challenges for site development as discussed below.
• Bearing Capacity would be very low due to the high compressibility and low shear strength of the marine clay. The marine clays would provide very limited vertical or lateral support for pile foundations. • Settlement would be large in the marine clay, as it is normally consolidated, and as such would not provide a good foundation for any structure that could not tolerate settlement. • Liquefaction Potential is a concern for sensitive clay and could result if the clay is loaded or disturbed. • Handling, transport, stockpiling and storage of the marine clay deposits will be difficult. The combined effects of very low disturbed strengths, high sensitivities and a wet climate will also complicate disposal efforts, as the material could have little to no ability to be stockpiled to any practical selfsupporting height or on an unconfined slope area. Separation of the material from the underlying deposits or rock may be difficult during excavation work. • Trafficability of construction equipment will be very low as the clay will generally not support traffic loading. The deeper sensitive clays will be particularly difficult in this respect. • Temporary cuts may be limited in height due to worker safety considerations, topography and the strength of the clay. • Slope failures in marine clay soils can result in retrogressive, low-angle, long run-out landslides. Typically these slides are triggered by geometric and loading changes associated with excavations, erosion of material from the toe of clay slopes, or from the dynamic effects of shear-induced pore water pressure changes during an earthquake. Failure can also occur without obvious triggers. • Re-use of clay will be limited. Due to its relatively low strength in a re- compacted state, higher than optimum moisture content, high sensitivity of certain deeper clay layers, excavated marine clays are not considered
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Northern Gateway Response to Federal Government IR No.1 Page 12 of 246 suitable for re-use as structural fill. • Sedimentation issues are likely to arise from excavated marine clay slopes when exposed to high precipitation at the site."
Preamble: Section 5.2 outlines various reasons why site development in marine clay will be difficult. It is important to outline both advantages and disadvantages of each potential site in order to clearly minimize effects to the marine environment.
Request: NRCan notes that this report was thorough from a geotechnical perspective. Given the substantial difficulties for the preferred option, as identified by the above. Provide a stronger rationale for why other sites were not chosen. Explain if all 4 of the terminal options are as susceptible to slope failure as at the preferred location. Provide a table of advantages and disadvantages of the potential sites, including statements on costs.
Response: The Application (Volume 3, Appendix E-3) presents information for the purposes of evaluating the feasibility of the preliminary concepts for the Kitimat Terminal. As a result of the information provided in that geotechnical report, the preliminary layout of the site was adjusted to avoid areas of significant marine clays. The Kitimat Terminal facilities, as discussed in Application (Volume 3, Section 9) and shown on Appendix I, Drawings I-1 and I-2 are now established on terrain underlain by shallow bedrock. Based on this design Northern Gateway does not consider that there are substantial difficulties associated with this site. The process of hazard identification and geotechnical feasibility assessment of the earlier proposed facilities is outlined in, the Response to Request for Additional Information (March 2011), Section C.3.6.1.3, Table C-12 and Figure C-10.
Please refer to Northern Gateway’s response to Federal Government IR 5A) for a detailed comparison of the alternative terminal sites.
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Northern Gateway Response to Federal Government IR No.1 Page 13 of 246
Marine Terminal Sedimentation effects prediction
7 Reference: Volume 6B: Environmental and Socio-economic Assessment - Marine Terminal Chapter 8 Section 8.7 Effects on Marine Vegetation - Habitat Quality Subsection 8.7.2 Effects on Marine Vegetation - Habitat Quality 8.7.2.1 Effect Mechanisms page 8-18 and 8-19 [page 8-18]
Enbridge states: "The overburden removed during dredging will be disposed of on land, at the excess cut disposal area, to the extent practical." … [page 8-19] "Surface water runoff from outside the tank and manifold areas will be controlled so that this water will be released outside the boomed zone of the berthing structures, to the extent practical." "During construction of the marine terminal, disturbance to marine riparian vegetation and intertidal areas will be limited, where practical." …
Preamble: It is important to consider additional measures should conditions in the field be impractical or as expected.
Request: Clarify what will be done in the case that the mechanisms are impractical when the work is actually being conducted.
Response: The current methodologies proposed for managing surface water runoff at the terminal are proven industry practices. The phrase “to the extent practical” is generally in reference to the fact that there may be some small areas on the site from which surface water runoff is not re-directed outside the boomed zone of the berthing structures.
Overburden volumes removed during dredging will be collected and disposed of on land to accepted industry levels, using proven techniques. All practical, reasonable, industry accepted efforts will be made to collect the dredged overburden and dispose of it in the Kitimat Terminal excess cut disposal area on land. A small amount of overburden will not be recoverable and will fall to the ocean floor.
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Northern Gateway Response to Federal Government IR No.1 Page 14 of 246
Marine Environment Environmental Protection and Management Plan
8 Reference: Volume 7A: Construction Environmental Protection and Management Plan Chapter 6 Communication; pages 6-1 to 6-7
Preamble: Chapter 6 discusses an environmental officer and marine wildlife observer.
Request: Clarify if there will be an environmental advisory group or task force.
Response: Although Northern Gateway does envision an environmental advisory group, evolving from the existing Community Advisory Boards that are planned to be maintained throughout the Project, this group will not have an inspection function as discussed in Chapter 6 of the Construction EPMP (see Application (Volume 7A)).
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Northern Gateway Response to Federal Government IR No.1 Page 15 of 246
Stream Crossings – Valves
9 Reference: Volume 3 Appendix F Table F-1
Preamble: It is important to know the amount of control in case of a spill.
Request: Explain why the pipelines at the following river crossings have only have a single valve instead of two valves, and whether this valve is located on the Kitimat or Bruderheim side of the pipelines:
North Saskatchewan River, Pembina River, Sakwatamau River, Chickadee Creek, Two Creek, Deep Valley Creek, Tributary to Deep Valley Creek, Big Mountain Creek, Hiding Creek, South Redwillow River, Sutherland River, Stearns Creek, Klo Creek, Buck Creek, Owen Creek, 24.5 Mile Creek, Crystal Creek, Clore River, Hoult Creek, Wedeene River, and Tributary to Kitimat River #5
Response: The strategy for placement of valves is detailed in the Preliminary Valve Location Engineering Assessment, filed in Northern Gateway’s response to JRP IR 3.3. An updated list of valve locations was filed with the JRP, December 2010.
A consideration for identification of preliminary valve locations was the requirement to limit the potential spill volume at selected watercourses to less than 2,000 cubic metres. In some cases the local topographic profile or the presence of another valve further away from the watercourse may naturally limit the spill volume to less than 2,000 cubic metres, in which case no valve was identified for that watercourse location. For some of the watercourses, such as those listed above, this scenario occurred on one side of the watercourse only. Therefore only one valve was required at the watercourse crossing.
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Northern Gateway Response to Federal Government IR No.1 Page 16 of 246 The watercourse crossings listed above have one valve located on either the Bruderheim side (B) or the Kitimat side (K) as indicated below:
Watercourse Oil Condensate North Saskatchewan River K K Pembina River B & K B Sakwatamau River B B Chickadee Creek K none Two Creek K K Deep Valley Creek B B Tributary to Deep Valley Creek K K Big Mountain Creek K K Hiding Creek K K South Redwillow River K K Sutherland River B B Stearns Creek B B Klo Creek B B Buck Creek B & K B Owen Creek K K 24.5 Mile Creek B B Crystal Creek K K Clore River B B Hoult Creek none none Wedeene River, B B Tributary to Kitimat River #5 B B
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Northern Gateway Response to Federal Government IR No.1 Page 17 of 246
Wildfire
10 Reference: Volume 6A, Section 14.4, Page 14-19
Enbridge states (Vol 6A, Section 14.4.3, p. 14-19):
The potential adverse effects of forest fire on the pipelines, infrastructure and tank terminal can be mitigated by suitable design and operational methods.
Enbridge should recognize that the risk of forest fires cannot be fully mitigated, and should acknowledge the possibility of high-intensity burning across the proposed pipeline route and around the 10 pumping stations. The risks associated with a high-intensity fire along the RoW may be higher than reported in the Application; the likelihood of having one or more high-intensity fires intersect the pipeline route will be high in any given year and under extreme fire behaviour, mitigation measures may very well fail.
Enbridge states (Vol 6A, Section 14.4.2, p. 14-19): operational planning and procedures will include operating considerations relative to forest fires and forest fire conditions
Preamble: Direct exposure of infrastructure to high-intensity wildfire is likely to be an on- going issue during and after the construction of the project. Many fires burn under high to extreme conditions during which direct fire suppression is impossible. According to an atlas of observed fire perimeters >10 ha from 1940 to 2009, several dozen fires have intersected the proposed pipeline route.
Request: NRCan requests that Enbridge: • Explain what operating considerations will be included in operational planning and procedures, with full consideration of the possibility of a high-intensity burn event affecting the pipeline and associated infrastructure, during operation. Response: Please refer to Northern Gateway’s response to District of Fort St. James IR 5 (b), (c).
Enbridge is experienced regarding planning for this type of event. Forest fires do not present a threat to buried pipelines. Above ground facilities will be built with buffer areas and using FireSmart best practices to protect against forest fire damage, therefore it is not anticipated that there will be an increased likelihood of releases during a fire event. Examples of FireSmart best practices include: minimizing slope influence (facilities on a slope with vegetation immediately below are at higher risk of impact), establish vegetation-free setback distances, further establishing minimal vegetation zones outside of the vegetation-free setback area in heavily forested locations, and using fire resistant construction materials.
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Northern Gateway Response to Federal Government IR No.1 Page 18 of 246
Public Consultation
11 Reference: Exhibit B22-2 (Volume 4 - 2010 Update, Section 11 - Landowner Consultation, page 11-1, PDF page 41)
Landowners are entitled to compensation for lands acquired and damages resulting from the activities of a pipeline company (sections 75, 86 and 87 of the NEB Act). Negotiation and Arbitration services are available to landowners and pipeline companies, at the request of either party to the Minister of NRCan, to resolve compensation disputes (sections 84, 88-103 of the NEB Act). When landowners are served notices under S. 87 that their lands may be required for the pipeline, they are to be provided with a description of the procedures available for negotiation and arbitration from NRCan in the event that they and the company are unable to agree on any matter respecting the compensation payable (S.87 1(e)).
Landowners and occupants within the applied-for corridor were provided with project information, pamphlets and landowner guides. A number of concerns identified during stakeholder engagement efforts related to compensation.
Preamble: The Government of Canada would like additional information regarding landowner engagement activities.
Request: Please provide examples of material provided to landowners that describe the damage and compensation provisions of the NEB Act, and in particular the negotiation and arbitration services that are available in the event that compensation matters cannot be resolved.
NRCan requests that Enbridge describe the program to consult with landowners on identified issues that is to begin in Q2 2011. Provide examples of material that will be provided to landowners that describes the damage and compensation provisions of the NEB Act, and in particular the negotiation and arbitration services that are available in the event that compensation matters cannot be resolved. Confirm when the results of this program will be filed.
Landowners no longer within the consultation area as the result of route changes are being notified and disengaged. Provide information on whether disengagement notices describe the damage and compensation provisions of the NEB Act, and in particular the negotiation and arbitration services that are available in the event that compensation matters cannot be resolved.
Landowners no longer within the consultation area as the result of route changes are being notified and disengaged. Provide information on whether the disengagement notices describe the damage and compensation provisions of the NEB Act, and in particular the negotiation and arbitration services that are available in the event that compensation matters cannot be resolved.
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Northern Gateway Response to Federal Government IR No.1 Page 19 of 246
Response: Northern Gateway has provided landowners within the 1 km corridor the NEB publication, “Pipeline Regulation in Canada – A Guide for Landowners and the Public”. A copy of this publication can be found on the NEB website. Damage and compensation provisions of the NEB Act are discussed in the publication, and in particular, the negotiation and arbitration services that are available in the event that compensation matters cannot be resolved are addressed in Section 8, page 52.
The program to consult with private landowners on identified issues commenced in April of 2011 and was substantially complete in July of 2011. Other than the NEB publication referred to previously, no additional information was provided to landowners that describes the damage and compensation provisions of the NEB Act, and in particular the negotiation and arbitration services that are available in the event that compensation matters cannot be resolved.
Landowners no longer within the consultation area as the result of route changes have been notified and disengaged. Other than the NEB publication referred to previously, no additional information has been provided which describes the damage and compensation provisions of the NEB Act, and in particular the negotiation and arbitration services that are available in the event that compensation matters cannot be resolved.
Surface rights acquisition process will begin with the negotiation of surface rights agreements following the Project’s approval and during the detailed routing process. Acquisition of surface rights will comply with the provisions and regulations of the NEB, including Section 87 of the NEB Act. Samples of the Section 87(1) notices for Alberta and British Columbia have been filed in the Application (Volume1, Appendix A). The form of notice describes the procedures available for negotiation and arbitration of compensation payable.
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Northern Gateway Response to Federal Government IR No.1 Page 20 of 246
Economics, Commercial, Financing
12 Reference: Exhibit B1-4-Vol 2, Economics, Commercial, Financing.
Appendix A-1, Muse Stancil report: Market Prospects and Benefits Analysis for the Northern Gateway Project.
The Muse Stancil report identifies a CA$21 billion (present value) benefit to Canadian producers of the Project over the initial 10 years of operation (2016- 2025), stemming from three effects: A price premium in Asian markets over the US Gulf Coast price; a shift in the market-clearing point for remaining Canadian crude oil sold in the US PADD II market, and; alleviating over- supply in the N.A. market post 2020 when Keystone XL and Pegasus are assumed to be at full capacity (i.e., the analysis assumes that the Keystone XL is approved and constructed).
The analysis indicates at page 6 that "As a consequence (of the Gateway start- up)… the Canadian crude producer will not need to ship as far south as the US Gulf Coast during the early years of the Forecast period. A reference to Keystone XL contractual arrangements is made in footnote 3 on page 6, and tables A-9 to A14 contain estimates of deliveries to the US Gulf Coast and Northeast Asian markets with and without the Gateway project.
Preamble: The Government of Canada would like additional information regarding potential economic benefits associated with the project.
Request: The Muse Stancil analysis treats the Gateway project as the last or "incremental" or 'marginal' project out of the basin, and appears to attribute the positive pricing effects of shifting the market-clearing point and alleviating oversupply to the Gateway project alone.
NRCan requests that Enbridge describe more fully the dynamics between the Keystone XL and the Northern Gateway projects with respect to the indicated improvements to Canadian producers' netbacks. Describe how the Keystone XL project would affect the pricing point for Canadian crude oil and the supply situation in the N.A. market, alone and in combination with the Gateway project. Describe how the analysis, or description of benefits, would change if the Keystone XL and Northern Gateway projects were to start-up simultaneously, or if the Northern Gateway project were to start up prior to Keystone XL coming into service.
The Muse Stancil study was done using 2009 information (e.g., the CAPP forecast, crude oil prices and differentials, Canadian dollar value). NRCan requests that Enbridge confirm whether an update to the study would produce significantly different results, and if so, would this be done prior to the commencement of the final hearings.
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Response: There have been a number of developments which have occurred since filing the Application. The most significant change has been the difference between CAPP’s 2009 Forecast and the 2011 Forecast it issued in June. An updated Muse Stancil Study should be available this Fall and information provided at that time should fully respond to this request.
The Muse Crude Market Optimization Model is run twice for each year in the forecast period. The model is first run without Northern Gateway, and the disposition and pricing of all Western Canadian crude grades is ascertained. One of the assumptions for the first run is that Keystone XL is in operation. Consequently, all of the market benefits attributable to Keystone XL (and all other export pipelines) are embedded in the analytical results from the first run. For the second model run for a given year, all model input variables (crude supply, Keystone XL capacity, etc.) are held constant, but the model is now permitted to use Northern Gateway, if desired, up to its design capacity. Accordingly, all differences between the two model runs, such as the resultant Canadian crude prices, are attributable only to Northern Gateway.
The benefits of the Keystone XL project have not been explicitly quantified. Nonetheless, it is Muse’s judgment that Keystone XL will increase Western Canadian crude prices. Keystone XL’s impact on the pricing point for Canadian crude cannot be ascertained without a detailed analysis, and its impact on the pricing point will be influenced by which year in the forecast period is under consideration. In the initial years of Keystone XL’s operation, it may act to shift the pricing point from the U.S. Gulf Coast to the inland markets. Keystone XL is currently scheduled to be commissioned in 2013, well before the startup date for Northern Gateway.
Irrespective of the timing assumption used for Keystone XL (started simultaneously, or started after Northern Gateway), the analytical approach for Northern Gateway would remain the same. The first model run (the Base Case), would not have Northern Gateway in operation, and the second model run (the Change Case) would permit, but not require, the use of Northern Gateway up to its design capacity. However, this description of the analytical approach is not to say that the benefits of Northern Gateway would not be influenced by the Keystone XL assumptions. It is Muse’s judgment that the benefits of Northern Gateway would be higher for every year in which Keystone XL is not in operation.
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Economics, Commercial, Financing
13 Reference: Exhibit B1-4-Vol 2, Economics, Commercial, Financing.
Appendix B-1, Wright Mansell Research report, Public Interest Benefits of the Enbridge Northern Gateway Pipeline Project
The Wright Mansell public interest benefits study uses input-output models to estimate large GDP increases ($270 billion) for Canada over 30 years of project construction / operation. This includes the multiplier effects of the project itself (i.e., the impact of the $5.5 billion in capital expenditures and $176 in annual operating costs), as well as the impact on the economy of a re-investment of 45% of the netback improvement ($28 billion over 10 years) that was discussed in the Muse Stancil study.
The application indicates (page 36) that "the price benefit does not immediately translate into employment or labour income. Rather…the largest employment and labour income benefits come from the indirect and induced impacts arising from…an increase in reinvestment of $44 billion in Canada over the period (2016-2046) as a result of the oil price benefits associated with Northern Gateway".
Page 37 further indicates that "In general, these benefits account for about one half of the total project benefits in terms of GDP and government revenues, and almost 90% of the total 558,000 person-years of employment generated by Northern Gateway".
In the Muse Stancil report, the calculation of the benefit of higher netbacks nets out two 'cost' elements of the project; the project's committed toll, and the 'Canadian Refinery Impact'. The latter is the cost increase born by Canadian refiners (and presumably passed on to Canadian petroleum products consumers) of the higher cost of crude oil in Canada as the result of the Gateway project.
The Wright Mansell study (table 2.4 on p. 29) likewise subtracts the cost to Canadian refineries from its benefits calculation. However, the net benefits in Wright Mansell do not appear to match those reported by Muse Stancil on p7. This negative impact also does not appear to have been run through the input- output model, to determine the negative impact on the Canadian economy of higher petroleum product prices.
Elsewhere in the application (Exhibit B8-2, Volume 6C, Section 4.4, Regional Social and Economic Effects, October 2010) a region-by-region analysis is provided of the economic benefits flowing from construction and operation expenditures and construction and operations employment for the six regions through which the project passes (Edmonton, Central Alta, NW Alta, NE B.C., Central B.C., and Coastal B.C.).
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There is a gap in the analysis and level of detail between the local regional impacts of the direct construction and operation activity, and the impact on the regional and national economy of the project (most notably the procurement of major items such as line pipe, valves, pumps, and monitoring and control systems) and the reinvestment of the improved producer netbacks from the project.
Preamble: The Government of Canada would like additional information regarding potential economic benefits associated with the project.
Request: Describe the linkages between the Wright Mansell study and the Muse Stancil study, specifically how the gross and net benefits described in Muse Stancil were treated in the Wright Mansell modelling, and further, whether the negative impact on the Canadian economy from rising petroleum product prices in Canada was modeled and reported.
Explain why the induced investment in the oil patch from the reinvestment of 45% of the net revenues from increased crude oil netbacks does not increase the size of the oil sands sector output above what is forecast by CAPP, and where these additional revenues would be re-invested.
Describe the impact of this $5.5 billion capital expenditure on the other regions of the Canadian economy not mentioned in Volume 6C, in reference to the procurement of major components for the project. If possible, provide information that goes beyond the results of the input-output models, and which is based on the company's actual procurement plans.
Response: The net incremental revenues (that is, net of the costs to Canadian refineries) used to estimate the economic impacts shown in the Wright Mansell Research (“WMR”) report are given in the last column of Table 2.4 of that study. Details concerning the derivation of these net incremental revenues are provided in Attachment Federal Government IR 13. As indicated there, these are derived using estimates of production of various types and blends of oil and the estimated per barrel price uplifts shown in Tables A16 and A18 of the Muse Stancil study. The estimated cost to refineries is highlighted in yellow on Attachment Federal Government IR 13. These costs were deducted from the total revenue gains to Canadian production to arrive at net incremental revenues. The checks provided in the blue highlighted columns of the spreadsheet indicate that the resulting net incremental revenues used in the WMR study are almost identical to those in Table A21. Note that the total net revenue gain for 2016 shown in Table 2.4 of the WMR report is scaled down to reflect the fact that Northern Gateway was assumed to be operational for only part of that year. The macro economic impacts reported in the WMR study are derived using the incremental revenue gains net of the increased costs to Canadian refineries.
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The impacts reported in the WMR study are based on: (1) the direct and indirect impacts associated with the construction and operation of the pipeline; (2) the direct impact associated with the net revenue gain; and, (3) the induced impacts associated with the reinvestment of a portion (45%) of the net revenue gain. Details are provided below.
The direct and indirect impacts arising from the construction and operation of the pipeline Project (i.e., excluding any oil price impacts) are as follows (in millions 2009 $CAN unless otherwise specified):
PIPELINE CONSTRUCTION IMPACTS BC Alberta Ontario Quebec Sask Other Canada
Investment 3,962 1,579 5,541 Labour Income 1,376 846 200 65 27 29 2,543 GDP 2,160 1,284 315 103 61 51 3,974 Employment (person years) 15,589 9,282 3,026 1,139 468 546 30,049
Federal Government Revenue 379 218 55 13 7 7 680 Provincial Government Revenue 199 88 34 18 5 4 348 Total Government Revenue 578 305 89 31 12 12 1,028
PIPELINE OPERATIONS IMPACTS BC Alberta Ontario Quebec Sask Other Canada TOTAL OVER 30 YEARS
Pipeline Revenue 14,433 5,752 20,186 Labour Income 1,719 471 195 45 7 16 2,453 GDP 14,426 4,806 288 67 21 27 19,636 Employment (person years) 21,745 5,363 2,964 769 121 289 31,251
Federal Government Revenue 1,016 397 52 9 2 4 1,480 Provincial Government Revenue 1,438 467 33 12 2 3 1,954 Total Government Revenue 2,454 864 85 20 4 7 3,433
PIPELINE OPERATIONS IMPACTS BC Alberta Ontario Quebec Sask Other Canada ANNUAL AVERAGES
Pipeline Revenue 481 192 673 Labour Income 57 16 6 1 0 1 82 GDP 481 160 10 2 1 1 655 Employment (person years) 725 179 99 26 4 10 1,042
Federal Government Revenue 34 13 2 0 0 0 49 Provincial Government Revenue 48 16 1 0 0 0 65 Total Government Revenue 82 29 3 1 0 0 114
These estimates were derived using the Input Output model described in the study, along with breakdowns of Project components and inputs provided by Northern Gateway. Detailed procurement plans were not provided to WMR however, Northern Gateway did indicate that it assumed all pipe would be sourced in Canada and this was incorporated in the modeling. The assumed sourcing of other inputs used by WMR is that embodied in the Input Output model.
The direct impacts associated with the net revenue gain are primarily the direct flow through to GDP and government revenues. No incremental employment or labour income is assumed. These direct impacts are shown below (in millions of 2009 $CAN unless otherwise specified):
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DIRECT PRICE BENEFIT IMPACTS
TOTAL OVER 30 YEARS BC Alberta Ontario Quebec Sask Other Canada
Price Benefits 79 103,277 4,133 106 107,595 Labour Income 0 0 0 0 0 GDP 79 103,277 4,133 106 107,595 Employment (person years) 0 0 0 0 0
Federal Government Revenue 12 15,492 620 16 16,140 Provincial Government Revenue 17 20,263 886 22 21,188 Total Government Revenue 29 35,755 1,506 38 37,328
ANNUAL AVERAGES BC Alberta Ontario Quebec Sask Other Canada
Production Revenues 3 3,443 138 4 3,587 Labour Income 0 0 0 0 0 GDP 3 3,443 138 4 3,587 Employment (person years) 0 0 0 0 0
Federal Government Revenue 0 516 21 1 538 Provincial Government Revenue 1 675 30 1 706 Total Government Revenue 1 1,192 50 1 1,244
The induced impacts arise from the reinvestment by the oil and gas industry of a portion of the net incremental revenues. It is assumed that 45% of the net revenue gain is reinvested. This is the average for the industry over the period 2000-2008. Further, in the modeling it is assumed that this reinvestment is by the conventional oil and gas industry (which, in terms of investment, still dominates the oil sands component of the total sector) and based on geographical patterns for that industry in 2008. When these induced investment and associated conventional oil and gas production impacts are added to the impacts described in the two tables above we get the overall impacts of Northern Gateway as portrayed in Table 3.1 on p.32 of the WMR study.
While some portion of this reinvestment may go to additional oil sands projects, the scenario assumed for the study is intentionally conservative. Unlike the conventional oil and gas industry where pipeline constraints are not generally a problem, added oil sands production beyond that incorporated in the modeled case would require an assumption of further pipeline expansion (beyond Northern Gateway). This would result in larger economic impacts than those shown in the WMR study.
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WATER - Navigability
Navigable Waters
14 Reference: Volume 1, Section 6.1.2, Table 6-1, Page 6-2.
Preamble: Information is required to enable Transport Canada to determine potential project effects on navigation.
Request: Enbridge indicates that Approvals under section 5 of the Navigable Waters Protection Act will be required for certain works and that leave under subsection 108(4) of the National Energy Board Act will also be required.
Volume 3, Appendix G.1, Table G-1, not paginated
Enbridge provides, in Table G-1, pipeline watercourse crossing methods for review sites.
Volume 3, Section 6.4, pg. 6-5
Enbridge states that "Vehicle and equipment watercourse crossings will be needed along the RoW and the temporary and permanent access roads will be used during construction and operations" and indicates that crossing methodologies will include temporary and permanent bridges.
Volume 3, Appendix G.1, figures G-8 to G-11
Enbridge provides typical access road crossing methods for a snow fill, ice bridge, culvert and temporary bridge.
With respect to proposed works that are to be built or placed in, on, over, under, through or across any navigable water and that may require leave by the Minister of Transport Canada under the National Energy Board Act (i.e. the pipeline and connected works such as reservoirs, storage facilities and pumps), Transport Canada requests that, where the navigable water has an average width of less than 1.20m or an average depth of less than 0.30m (calculated on a section measuring 100m upstream and 100m downstream of the crossing site and at the high-water level), the proponent submit photograph(s) of the waterway at the crossing site as well as location/route plans showing the waterway and proposed works at the crossing site. Location/route plans must include information with respect to the waterway's average width/depth and latitude/longitude at the crossing site. For waterways that exceed these dimensions, Transport Canada requests that the proponent submit detailed applications for each proposed work. With respect to proposed works that are to be built or placed in, on, over, under, through or across any navigable water and that may require an approval by the Minister of Transport Canada under the
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Information to be provided in an application is listed in Appendix A to this Information Request.
Enbridge may contact the NWPP at: Shannon Vollema Navigable Waters Protection Program
Transport Canada Marine - Prairies and Northern Region 1100 9700 Jasper Avenue, Edmonton, AB T5J4E6 [email protected] 780-495-5549
John Mackie Navigable Waters Protection Program Transport Canada - Pacific Region 800 Burrard Street, Vancouver, BC V6Z 2J8 [email protected] 604-775-8890
______1 Response: Before Northern Gateway can provide this information and submit applications for navigable waters approvals, it will have to complete its detailed engineering which will determine the detailed routing for which Northern Gateway will seek NEB approval. Northern Gateway will submit the requested information and any required applications for navigable waters approvals at that time.
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Navigable Waters 15 Reference: Volume 1, Section 6.2, Page 6-1
Preamble: Information is required to enable Transport Canada to determine potential project effects on navigation.
Request: Enbridge outlines pipeline watercourse crossing methods that will be used for the proposed Project. The proponent should note that where the horizontal directional drilling method is expected, the proponent should include a detailed contingency plan as part of its application for leave by the Minister of Transport Canada under the National Energy Board Act. This plan must include detailed drawings of the work (plan and profile including dimensions), detailed construction methodology (including placement of any isolation works) and construction timing information. If the contingency plan is not reviewed and approved under the initial National Energy Board leave, separate application and approval will be required prior to commencing any contingency work, which may result in delays to the project.
Response: Northern Gateway has provided contingency plans for alternate crossing methods as part of its Application. In the event that these alternate plans are required Northern Gateway understands that more information in support of navigable waters applications may be required before proceeding with contingency work.
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Navigable Waters 16 Reference: Volume 3, Section 8.4, Page 8-3.
Enbridge states that "Powerlines will be constructed to supply electrical power for the pump stations. These powerlines will connect to existing transmission systems operated by various utility companies such as ATCO Power, AltaLink and BC Hydro."
Preamble: Information is required to enable Transport Canada to determine potential project effects on navigation.
Request: For any transmission line crossings that are to be built or placed over any navigable water and that may require an approval by the Minister of Transport Canada under the Navigable Waters Protection Act as opposed to a leave under the National Energy Board Act, Transport Canada requests that the proponent submit detailed applications for each proposed work not covered by the Order. A copy of the Order can be viewed at: http://canadagazette.gc.ca/rp-pr/p1/2009/2009-05-09/html/notice-avis- eng.html#d103
Information to be provided in an application is listed in Appendix A to this Information Request.
Response: Northern Gateway does not anticipate any Project effects on navigation arising from transmission line crossings. If required, applications will be submitted by the party constructing the transmission line.
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Navigable Waters 17 Reference: Volume 3, Section 10.5.4, pg. 10-12
Enbridge provides an outline of tanker berth configuration at the proposed Marine Terminal.
Preamble: Information is required to enable Transport Canada to determine potential project effects on navigation.
Request: Transport Canada requests that Enbridge provide final general arrangement drawings (plan and profile), timing and methodology of construction, legal description location for the berth or latitude and longitude, and proposed ownership of the berths.
Response: TERMPOL Study 3.10, Appendix A, and the Application (Volume 3, Appendix I), provide drawings of the proposed Kitimat Terminal and marine terminal facilities, suitable for an environmental assessment level review. Final general arrangement drawings and timing and methodology of construction will be completed during detailed engineering.
Construction considerations are discussed in the Application (Volume 3, Section 10).
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Environmental Effects
18 Reference: Volume 6A:Part 1: Environmental and Socioeconomic Assessment - Pipelines and Tank Terminal, Section 10.3, page 10-12 Enbridge provides information on environmental effects of the project including watercourse crossings on surface water resources.
Preamble: Information is required to enable Transport Canada to determine potential environmental effects of watercourse crossings, related to the project, on navigation.
Request: Transport Canada requests that Enbridge provide information on environmental effects of the project on navigation pertaining to works to be built or placed in, on, over, under, through or across any navigable water, including temporary/permanent bridges and pipeline.
Response: Where in-stream or aerial pipeline crossing construction, a road crossing, or a transmission line crossing is required on a navigable stream, an application under the Navigable Waters Protection Act will be made to Transport Canada prior to construction.
Proposed crossing methods for all watercourses are provided in the Application (Volume 6B, Table 11C02). Methods for Review sites are also shown in the Application (Volume 3, Appendix G1).
Construction of pipeline watercourse crossings on navigable watercourses may affect navigation when construction occurs during open water periods and aerial, open cut or isolated crossing techniques are used. Concerns could include temporary navigation closures and safe passage around construction works and equipment.
Watercourses crossed during winter, or by trenchless methods are not expected to have any impact on navigation during construction. However, mitigation measures will need to be taken even during the winter to avoid impacts to safe use of the area by recreational users.
Construction of aerial crossings will incorporate requirements of Transport Canada on clearance, and will require careful safety management, and possibly some short-term navigation closures during construction. However, the Murray River is the only navigable watercourse that will be crossed using aerial crossing methods. Navigation clearances, temporary closures, notices to users, and safety will all be reviewed with Transport Canada during detailed engineering and permitting.
Prior to, and during construction, all reasonable efforts will be made to limit impediments to navigation. User groups will be informed regularly, hazards to
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Aquatics
Watercourse Crossings
19 Reference: Volume 6A, 6B, NGP Response to JRP IR No. 1, Section 1.1C
The proponent has identified that the project is likely to require an authorization under subsection 35(2) of the Fisheries Act for the harmful alteration, disruption or destruction (HADD) of fish habitat. The proponent's selection of pipeline crossing techniques follows a riskbased decision matrix. DFO infers that HADDs have been identified at some watercourse crossing locations based on information provided in the current mitigation and compensation sections of the application. Potential impacts are not documented or linked, however, to a proposed crossing method at any given location.
Preamble: Impact tables are necessary to develop a more fulsome understanding of the total potential impact to fish and fish habitat as well as the potential for a significant adverse environmental impact. As noted in DFO's "Proponent's Guide to Information Requirements for Review Under the Fish Habitat Protection Provisions of the Fisheries Act" (April 2009) the proponent should indicate the extent of the area (in square metres) that will be affected by both the proposed structures (permanent or temporary) and the activities. The extent of the affected area should include all areas affected by the proposed development including those potential impacts in or on the water, on the shoreline, coast, bank(s) or in the riparian zone.
Request: The proponent should develop and provide an impact table that reflects the most current information available in the application regarding project activities and that clearly identifies or provides the following:
1. All known and all anticipated HADDs associated with pipeline construction and operation; 2. A tabulation and summary of all HADDs by crossing technique and stream risk category; and 3. The physical extent, duration and magnitude of all HADDs. This should be done for all watercourse crossings, including those associated with pipeline roads (new and upgrades), powerlines and any other project component with the potential for a HADD.
The proponent should also identify and include in the above-mentioned table watercourse crossings and/or project activities that may result in the destruction of fish by means other than fishing and potentially require an authorization under section 32 of the Fisheries Act.
In addition, the proponent should develop and provide a similar impact table for project elements in the marine and estuarine environment.
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Response: Potential HADDs in freshwaters include all permanently lost or altered habitat, all temporary losses or alterations of habitat occurring at medium and high risk crossings, and any HADDs at lower risk crossings identified by DFO after application of all other available mitigation. The precise extent of potential HADDs will remain unknown until the final watercourse crossing designs are completed during the detailed engineering. Final HADD values for watercourse crossings will be determined prior to submission of applicable permits and authorizations. All powerline and road crossings can be completed without a harmful alteration, disruption or destruction of fish habitat by following DFO Operational Statements or by applying best management practices as described in guidance documents published or approved by DFO.
The Risk Management Framework (“RMF”) analysis designated the watercourse crossings into the following four risk management categories:
• Low risk – no HADD likely after mitigation • Medium risk – HADD likely and a streamlined authorization process can be used • High risk – HADD likely and site-specific authorizations will be needed. • Significant risk – HADD will occur and DFO policy to redesign or relocate is applied.
A detailed description of the RMF analysis process and results is described in the Application (Volume 6A, Section 11.5).
HADD values will be calculated by using the formulas in the Application (Volume 6A, Appendix 11B).
1. Amount of instream area affected will be calculated according to the formula:
BFW x (TW * Elevation)
Channel width (BFW) will be multiplied by width of trench disturbance (TW) and final elevation (Elevation) to define the HADD to instream habitat (Bonnington and Boag 2006). For estimation purposes trench disturbance width was estimated at 7 m for isolations and 10 m for open cut crossings (large watercourse crossings only). Elevation was assumed to be 3 m. Final HADD values will be calculated once detailed design is complete.
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Northern Gateway Response to Federal Government IR No.1 Page 35 of 246 2. Amount of riparian area affected will be calculated according to the formula:
RoW (m) x 30 m + EAWR
The compensatable riparian disturbance area consists of the construction RoW width (m) multiplied by 30 m (from high high-water mark up to 15 m on each bank, when loss of canopy closure results) plus estimated additional workspace required (“EAWR”), which may include areas for temporary vehicle crossings.
The construction RoW width for the Project is 50 m. The estimated riparian area affected by the RoW for each crossing is 1500 m2. This exercise is intended to scale the HADD. Actual measurements will vary with bank configuration and angle at which the pipeline RoW intersects the watercourse. The EAWR will also be identified during detailed engineering.
Permanently Lost or Altered Habitat
Construction of the Kitimat Terminal and disposal of waste rock next to the terminal will result in substantial modification or infilling of approximately 1,500 m of two fish-bearing tributaries to Renegade Creek (a tributary to Bish Creek). Both streams are small first order watercourses less than 2 m in width. One originates in the southwest corner of the Kitimat Terminal footprint while the other is located within the excess cut disposal area north of the security fence at the Kitimat Terminal. This is the only direct loss of freshwater habitat due to the Project (Table 1).
Table 1 – Estimated HADD for Permanently Altered Streams Watercourse Length Stream HADD Estimate (m2) (m) Width Instream Riparian Total (m) Two Tributaries to 1,500 2 3,500 45,000 48,500 Renegade Creek
Temporary Losses or Alterations of Habitat
The RMF analysis conducted for the watercourse crossings (see Application (Volume 6A, Section 11.5)) identified 96 watercourse crossings that were high or medium risk crossings (Table 2). The remaining watercourses were low risk and no HADD is likely after mitigation measures are applied.
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Northern Gateway Response to Federal Government IR No.1 Page 36 of 246 Table 2 – Summary of Estimated HADD for Temporary Losses or Alterations of Habitat Crossing RMF No. of HADD Method Result Watercourse Instream Riparian Total Crossings Open Cut High 2 8,110 1,800 9,910 Isolate: High 7 2,250 6,300 8,850 Flume Medium 1 250 900 1,150 High Medium 3 350 2,700 3,050 Isolate: High 4 1,710 3,600 5,310 Super Flume Medium 1 160 900 1,060 High Medium 1 350 900 1,250 Isolate: High 14 3,860 12,600 16,460 Dam and Pump Medium 12 1,320 10,800 12,120 High Medium 22 2,910 19,800 22,710 Medium 29 2,070 26,100 28,170 Low Totals 96 23,340 86,400 109,740
Detailed information for each watercourse crossing with a potential HADD is described in Attachment Federal Government IR 19 (Tables 3, 4, 5 and 6).
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Watercourse Crossings
20 Reference: Volume 6A, Section 11, Appendix 11D
Preamble: Consistent with standard operating policies, DFO seeks to avoid impacts with fish and fish habitat consistent with the Risk Management Framework. Additional information on impacts of watercourse crossings on aquatic species of concern would assist DFO in understanding the additional mitigation measures that might be required.
Request: For any fish-bearing streams where a trenchless watercourse crossing method is not proposed, the proponent should provide:
1. All information necessary to fully determine the feasibility of using a trenchless crossing method; 2. Considering the above, the rationale for not selecting a trenchless crossing method; 3. Contingency plans for all watercourse crossings and rationales for selecting them; 4. A habitat assessment (and, if winter construction is proposed, the availability and/or proximity of overwintering habitat); and 5. Vehicle access plans for all proposed watercourse crossing activities.
Regardless of the crossing methods, where species that have had either federal or provincial management concerns identified are present (e.g., species listed under Species at Risk Act):
1. Identify what, if any, additional mitigation measures are proposed; and 2. What, if any, additional contingency plans are proposed in the event of the failure of the mitigation.
Response: Crossing Methods
1. A watercourse crossing technique decision process was developed to provide an overview of the crossing methods at a level suitable for planning purposes (Volume 6A, Section 11, Figure 11-6). The process assigns recommended crossing methods for each watercourse based on flow regime and habitat sensitivity. Biophysical data used for the sensitivity analysis are summarized in Technical Data Report Freshwater Fish and Fish Habitat Appendix B: Freshwater Fish and Fish Habitat Aquatic Catalogue and Watercourse Crossing Data. Biophysical parameters used for sensitivity analysis are described in the Application (Volume 6A, Section 11, Table 11-12).
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Northern Gateway Response to Federal Government IR No.1 Page 38 of 246 Crossings with a high level of complexity, sensitivity or with specific engineering construction or operational concerns were identified for detailed site review where the decision between trenched or trenchless crossing technique was made. Crossing methods selection, including alternative crossing methods for trenchless crossings and the crossing method review process is discussed in the Application (Volume 3, Section 6).
2. Rationale for assigning a watercourse crossing method is shown in the Application (Volume 6A, Section 11, Figure 11-6). Trenchless crossing methods will be used at select watercourse crossings based on fisheries, engineering, construction, cost and other assessments.
3. Once detailed engineering and final route selection have been completed, additional detail will be provided in an updated Construction Environmental Protection and Management Plan (“EPMP”). Detailed contingency plans for watercourse crossings will be outlined in the Construction EPMP and will be included in the construction-related permitting applications.
4. Habitat assessments for all watercourse crossings are presented in Technical Data Report Freshwater Fish and Fish Habitat Appendix B: Freshwater Fish and Fish Habitat Aquatic Catalogue and Watercourse Crossing Data. Overwintering assessments for select sites are provided in the TDR.
5. Vehicle Access Plans will be included in the Construction EPMP. Specific plans will be provided once detailed engineering is complete.
Additional Mitigation and Contingency
1. Primary mitigation measures for sensitive species include the selection of the crossing method and timing of construction works. The Risk Management Framework (see Application (Volume 6A, Section 11.5)) assigns sensitivity based on species presence. The presence of species with federal and provincial management concerns results in a higher sensitivity score. The sensitivity score is carried through the crossing method decision process. Construction activities are also timed to occur in the least risk period so as to lessen the effects on fish species present. Other mitigation measures are described in the EPMP (Volume 7A).
2. In watercourses where there are species that have either federal or provincial management concerns, on-site monitoring effort will be increased. Also, post-construction sampling will occur to ensure that mitigation and protection measures are working as intended. Detailed contingency plans will be provided in the regulatory permitting application.
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Watercourse Crossings
21 Reference: Volume 6A, Section 11
Preamble: DFO needs to be in a position to submit written evidence on currently proposed and any new crossings and HADDs to the Joint Review Panel.
Request: The application is for a 1 km wide corridor, within which the Joint Review Panel will consider the potential environmental impacts to fish and fish habitat. DFO uses a risk-based approach to the management of fish and fish habitat, but this approach requires certainty of knowledge about the type, extent, duration and location of potential HADDs to inform the environmental assessment. The proponent should provide the following in non-proprietary or other use- restricted formats:
1. GIS shapefiles, including GPS referencing, for the pipeline right-of-way (ROW) and all watercourse crossings for the most current routing; and 2. Habitat assessments for all watercourse crossings for the most current routing.
The proponent should also address the following questions or provide the following information or update:
1. Have the pipeline crossing locations within the 1 km corridor been finalized? 2. Will the final centerline of the pipeline route fall outside the proposed 1 km wide corridor? 3. In the event that the final pipeline route falls outside the proposed 1 km corridor or involves one or more new watercourse crossings and associated HADDs, provide a detailed schedule for assessing those watercourse crossings. Assessment of new crossings and HADDs should be completed and information provided to DFO during, not after, the environmental assessment phase so that DFO can offer informed advice to the Joint Review Panel. 4. Update stream crossing catalogues/technical data reports to include contingency crossing methods and risk summaries.
Response: 1. GIS shapefiles, including watercourse crossings, have previously been provided to the Government of Canada and future updates will be provided as route revisions are undertaken.
2. Habitat Assessments for the watercourse crossings are provided in Freshwater Fish and Fish Habitat Technical Data Report – Appendix B: Freshwater Fish and Fish Habitat Aquatic Catalogue and Watercourse Crossing Data. These one page data sheets summarize information collected during the field surveys up to October 2009. Currently 265 sites
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Northern Gateway Response to Federal Government IR No.1 Page 40 of 246 remain to be surveyed due to improvements in Project design and routing, of which 125 are pipeline RoW sites. The remaining 140 sites are located on road, power line or terminal watercourse crossings. All remaining unsurveyed watercourse crossings will be surveyed prior to submission of regulatory permitting applications. The aquatic catalogue will also be updated accordingly as new information becomes available.
1. No. Pipeline crossing locations within the 1 km corridor will be finalized during detailed engineering.
2. The application filing is for a 1 km wide corridor within which the final centerline will be located.
3. If there are deviations outside of the 1 km route corridor, Northern Gateway will seek approval for corridor changes in consultation with regulatory agencies. Supplementary information will be submitted to the NEB in support of the route revision as per the standard approval process. This includes assessments of new watercourse crossings due to the route revision. Consultation with participating Aboriginal groups would also occur. As part of the standard approval process, DFO and other agencies will have an opportunity to assess the additional watercourse crossings and pipeline routing.
4. The proposed crossing locations have been selected so that both the trenchless crossing method and the contingency crossing method are feasible. Future updates to the Aquatic Catalogue, including contingency methods where applicable, will be provided once the detailed route is finalized. In the meantime, risk summaries for each watercourse crossing are available in the Risk Management Framework Analysis in the Application (Volume 6, Appendix 11C).
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Marine Mammals
22 Reference: Volume 8B, Sections 10, 10.7.3, 10.7.4. Pg 10-15, 10-91
Preamble: The additional information is being requested to assist DFO in understanding the impact of marine tanker traffic on fish and fish habitat, including species listed under the Species at Risk Act.
Request: Vessel speed and location has been evaluated and the assessment indicates that lethal or severe strikes are unlikely. However, the proponent indicates limited confidence in such predictions. The proponent should provide:
1. The likelihood (in terms of probability) of a ship strike, given the cumulative number of vessels and the distribution and abundance of marine mammals in the project area and vessel route; 2. Should strike occurs, the likelihood of injury or death of a marine mammal (adult and young and species listed under the Species at Risk Act) struck by ship over a range of likely speeds; and 3. Using a probabilistic description of observed behavioural response of marine mammals, especially those that are listed, an estimate of the likelihood of a strike if a ship is initially on a collision course with one or more mammals.
In addition, the proponent should provide the following information on species listed under the Species at Risk Act:
1. Section 10 refers to using a whale-monitoring vessel during months of peak humpback whale abundance in the core humpback whale area. The proponent should provide information on what those peak periods are.
2. Section 10 states that residual environmental effects of marine-related transportation might lead to changes in the distribution and abundance of some marine mammals within the confined channel assessment area, but are not expected to affect the long-term viability of marine mammals at population level. The Species at Risk Act prohibits impacts to listed species. Using only population level consideration is not appropriate for species listed under this Act. The proponent should provide information that addresses this concern.
3. Section 10 states that the proponent will "take a lead role in researching potential behavioural changes, and associated effects such as increased energy expenditure or reduced foraging efficiency, with other interested parties." The proponent should provide specific details of the activities being proposed and how the research results will be used to support the proponent's adaptive management approach.
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Northern Gateway Response to Federal Government IR No.1 Page 42 of 246 Response: Preamble
In consideration of the Federal Government’s IR No. 1.22, Northern Gateway feels that responses to this IR need to be interpreted within the context of the following 3 points.
1. Although DFO has been very cooperative at providing Northern Gateway with information on certain subjects (e.g., potential concerns surrounding Project effects on marine mammals, the current population size of NR killer whales, an update on known sea otter distribution in proximity to the CCAA, and recorded incidents of all vessel-marine mammal strikes in the CCAA), DFO data on marine mammal distribution in BC has not yet been provided. Multiple requests for access to such records have been made since 2005.
Northern Gateway remains committed to reviewing any and all marine mammal data made available by DFO and to using this data to better inform its assessment of potential Project effects. Northern Gateway would further value the opportunity to improve its baseline understanding and to refine its proposed surveys and monitoring plans through conversation with DFO’s marine mammal experts.
2. As noted in the Project Description, Northern Gateway estimates that approximately 220 vessels will call on the Kitimat Terminal each year (i.e., 440 vessel transits through the Confined Channel Assessment Area; (“CCAA”)). Northern Gateway believes that it is important to view this vessel traffic and its potential associated effects in the context of existing and predicted vessel traffic in the CCAA and North Central Coast region as listed species will not distinguish between vessel traffic related to Northern Gateway and vessels utilized by others.
As discussed in the TERMPOL (Section 3.2, Sub-Section 5: Regional Vessel Traffic Analysis and Sub-Section 6: Variations in Traffic Density), large numbers of commercial and government vessels have been operating within the North Central Coast region for an extensive period of time. Traffic volumes within the CCAA are predicted to increase as a result of Northern Gateway and four other proposed projects in the Kitimat area (e.g., Kitimat LNG Project, Cascadia Materials, Alcan Smelter Expansion, Merrill Lynch/Teekay Shipping Floating LNG Facility). The contribution of Northern Gateway vessels to overall traffic in the CCAA and North Central Coast region are presented in Table 1.
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Northern Gateway Response to Federal Government IR No.1 Page 43 of 246 Table 1 – Contribution of Northern Gateway Vessels to Overall Vessel Traffic within the CCAA and North Central Coast Region (TERMPOL, Section 3.2(5): Regional Vessel Traffic Analysis and (6): Variations in Traffic Density)
Area Current Additional Northern Total Contribution traffic future Gateway future of Northern (transits traffic traffic traffic Gateway (%) / yr)1 (transits / (transits / (transits / yr) yr) yr) Douglas 540 390 440 1,370 32.1 Channel Wright 3,330 390 440 4,160 10.6 Sound Prince Rupert 21,600 390 440 22,430 1.9 Area (MCTS) 1 values do not include non-reporting vessels
Vessels associated with Northern Gateway will account for an estimated 32.1% and 10.6% of total vessel traffic in Douglas Channel and Wright Sound, respectively. For all vessels reporting to the Prince Rupert MCTS, Northern Gateway vessels will account for less than 2% of total traffic. These values are conservative, as non-reporting vessels were not included in the calculations.
Northern Gateway is committed to minimizing and mitigating potential environmental effects of Project-associated vessels within the CCAA. However, it is clear that Northern Gateway is not the sole contributor to vessel traffic in the North Central Coast region. In contrast with existing large vessel traffic in the region or other proposed large vessel traffic, Northern Gateway is the only Project to have undertaken an assessment of the environmental effects of shipping on marine biota, and committed to a suite of mitigation measures for these effects (e.g., vessel speed limitations, use of tethered and other escort vessels, monitoring of whales, and whale spotting vessels). Northern Gateway is also the only proponent to have made a commitment to undertake further research and monitoring, and fund independent third-party research. Northern Gateway would encourage the Government of Canada, other proponents, existing vessel operators, Aboriginal groups and public stakeholders to work cooperatively in undertaking this research and in developing measures to minimize vessel effects on marine biota, including species at risk.
3. Northern Gateway’s proposed mitigations and commitment to a focused marine mammal monitoring and survey program are unprecedented in Canada. None of the shipping agencies in southern BC – where traffic is
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Northern Gateway Response to Federal Government IR No.1 Page 44 of 246 far more frequent – are undertaking any such mitigation measures (e.g., dramatic vessel speed reductions, a marine-mammal monitoring vessel, real-time passive acoustic monitoring (“PAM”)) or monitoring studies (e.g., dedicated multi-year vessel-based surveys, long-term PAM baseline study). Shipping agencies in Atlantic Canada, also are not undertaking these types of monitoring or mitigation measures. Northern Gateway is committed to filling data gaps to help mitigate the effects of vessel traffic on marine mammals and to find a balance between industry and the environment that supports it. Northern Gateway encourages others (DFO, Environment Canada, Aboriginal groups, other major vessel operators, fishing organizations, and universities) to also be involved in the design, conduct and funding of a more broad-scale regional assessment program.
Vessel speed and location
1(a) As discussed in the Application (Volume 8B, Section 13.10, Exhibit B3-36), Northern Gateway has initiated a quantitative marine mammal– vessel strike analysis, which will be completed in advance of Project operations. As noted in this Volume, this analysis will include:
• initiating discussions with participating coastal Aboriginal groups and third-party independent marine mammal experts • requesting marine mammal density and distribution data from DFO • collecting field data for marine mammal density and distribution, if necessary • working with potentially affected stakeholders to evaluate the requirement for additional mitigation measures (e.g., spatial or seasonal routing or vessel-speed changes).
The primary objective of the marine mammal–vessel strike analysis is to determine the likelihood (in terms of probability) of a ship strike. The analysis will be spatial in nature, thereby allowing the model to predict areas along the vessel route that (based on available data) are at highest risk of a strike.
The model will be developed based on two datasets: 1) the cumulative number of vessels (both current and including proposed vessel traffic), and 2) the distribution and abundance of marine mammals in the Project area and along the vessel route. Northern Gateway is currently in possession of a database of current vessel traffic throughout the Project area (CCAA and OWA). However, analysis cannot begin until a more complete baseline of marine mammal densities is available.
As noted in the preamble above, despite multiple requests for access to
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Northern Gateway Response to Federal Government IR No.1 Page 45 of 246 DFO records of marine mammal distribution data (going back to 2005) no data has been provided. Northern Gateway has also begun initiating discussions with third party experts concerning available data. During conversations with Dr. Rob Williams in 2011, Dr. Williams was very helpful in providing input concerning Northern Gateway’s initial ideas for development of a quantitative marine mammal-vessel strike analysis. Dr. Williams did however express concern that current marine mammal information covering the CCAA (including his own) may not be sufficient and/or appropriate for the purpose of this study. As noted above, should it be necessary, Northern Gateway is committed to collecting the necessary field data in the CCAA and in the two approaches to the CCAA (i.e., the approach areas where reduced vessel speeds are proposed), to better inform the strike analysis.
2(a) The probability of a marine mammal sustaining injury or death as a result of a vessel strike depends on three factors: the probability of encounter, the probability of vessel strike, and the probability that the strike is severe/lethal.
The probability of marine mammal encounter is the probability that a marine mammal and vessel occur at the same location, at the same time. This depends therefore on the distribution and density of both marine mammals and ships. The probability of a vessel strike is the probability, given a marine mammal and vessel occur in the same location, that a strike actually occurs (i.e., any potential avoidance response by either the marine mammal or vessel is unsuccessful). The probability of a severe/lethal strike is the probability, given that a strike occurs, that the resulting injuries are severe and/or fatal to the marine mammal. Should a strike occur (i.e., there is an encounter, and avoidance responses are unsuccessful), research suggests that the severity of strike is correlated with vessel speed. Vanderlaan and Taggart (2007) developed a probability relationship between strike lethality and ship speed based on a compilation of worldwide historical records (1960 to 2002) of strikes to large whales (n=275; Laist et al. 2001, Jensen and Silber 2003). As discussed in the Application (Volume 8B, Section 10.7.3.3, Exhibit B3-33), Vanderlaan and Taggart’s (2007) logistical regression indicates that the probability of lethal injury decreases from 79% at 15 knots, to 31% at 10 knots and 21% at 8.6 knots. Laist et al. (2001) similarly concluded that serious injuries to whales are infrequent at vessel speeds of less than 14 knots, and are rare at vessel speeds of less than 10 knots. Comparable results are reported in a vessel strike database maintained by the National Oceanic and Atmospheric Administration in the United States (Jensen and Silber 2003).
In developing their model, Vanderlaan and Taggart considered only those records for which vessel speed and injury were known. With the
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Northern Gateway Response to Federal Government IR No.1 Page 46 of 246 exception of ‘unknown species’ and one record of a killer whale, all records involved large whale species (i.e., North Atlantic right whales, southern right whales, humpback whales, blue whales, fin whales, grey whales, minke whales, sperm whales, sei whales and Bryde’s whales). The vessel speed relationship developed above was based on the combination of these large whale species, and Vanderlaan and Taggart assumed that the different species would serve as suitable proxies (at least from a body-mass perspective) for their specific consideration of North Atlantic right whales. Therefore, the application of Vanderlaan and Taggart’s vessel speed-lethal injury relationship can be reasonably assumed to hold true for all large whales likely to be encountered in the Project area, including those listed on the Species at Risk Act (SARA). Although toothed whales and pinnipeds are occasionally struck by vessels, most of these marine mammals are small, agile, and fast- moving. Therefore, the above speed-risk relationship is likely conservative in its applicability to pinnipeds and toothed whales, including SARA-listed species.
In terms of strike risk to young whales, Laist et al. 2001 suggest that the higher recorded proportion of calves and juveniles among stranded ship- struck right and humpback whales may indicate that young whales are more vulnerable to being hit. They further suggest that this could be a result of calves and juveniles spending relatively large amounts of time in areas where they are more vulnerable to being hit (i.e., at the surface or in shallow coastal areas), or it may indicate that vessel avoidance is a behaviour that is learned as whales mature. No mathematical relationship between strike risk and vessel speed specific to young whales has been developed.
3(a) As discussed in Federal Government IR 1.22 1(a) above, the probability of a vessel strike is the probability, given a marine mammal and vessel occur in the same location, that a strike actually occurs (i.e., any potential avoidance response by either the marine mammal or vessel is unsuccessful).
Species at Risk Act
1(b) The whale-monitoring vessel will operate in the core humpback whale area during periods of peak humpback whale abundance. Humpback whales are found in North Pacific waters during all months of the year, although research suggests that peak abundance occurs between May and October (Clarke and Jamieson 2006, Ford et al. 2009). For the purpose of the assessment, the period of peak abundance was therefore designated as May to October; however, this time period will be further defined through information collected during follow-up studies and the whale monitoring program.
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2(b) In an effort to focus its response, Northern Gateway has selected to respond to this request by focusing on the NR killer whale, one of the Project’s key indicators (“KIs”) and a Threatened species on Schedule 1 of SARA. The response applies equally well to all listed species potentially found in the Project Area.
Underwater noise has been identified as a threat to killer whales in both the “COSEWIC assessment and update status report on the Killer Whale Orcinus orca Southern Resident population, Northern Resident population, West Coast Transient population, Offshore population and Northwest Atlantic / Eastern Arctic population, in Canada” (2008) and in the “Recovery Strategy for the Northern and Southern Resident Killer Whales (Orcinus orca) in Canada” (“Recovery Strategy”; 2008).
However, in its discussion of shipping noise, the Recovery Strategy concludes that “the consequences of these chronic sources of noise [i.e., shipping] on killer whales have not been assessed”. As one of its four recovery objectives to “mitigate and/or eliminate each of the threats facing resident killer whales, and to better address gaps in our knowledge” the Recovery Strategy identifies a need to “ensure that disturbance from human activities does not prevent the recovery of resident killer whales”. However, the proposed strategies for achieving these objectives include only research goals (e.g., determining effects of noise disturbance on physiology, foraging, and social behaviour) and developing policies (e.g., regulations and guidelines to reduce acoustic disturbance). Actual guidelines or suggestions for ways that industry may assist in mitigating the effects of chronic noise are not provided.
In the absence of input from regulatory experts, and in the context of a SARA recovery strategy that provides no actual guidelines but only identifies the need for further research, Northern Gateway has conducted its assessment to the best of its ability given available science and direction from regulatory agencies. Furthermore, Northern Gateway has made commitments to mitigation measures, monitoring programs, and long-term funding of research programs (including some that would assist in attaining the Recovery Strategy objectives), that are unprecedented in Canada.
As noted in the preamble, vessels calling on the Kitimat terminal will represent approximately 1.9% of the future vessel traffic in the Prince Rupert Region. All other vessels operating in this region would have underwater noise effects on Northern Resident Killer whales and other species of whales. Therefore the contribution of this Project to any threshold would have to be weighed in relation to the effects of all other existing and future projects involving large vessel shipping in the North
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Northern Gateway Response to Federal Government IR No.1 Page 48 of 246 Central Coast of British Columbia, as would the feasibility of any mitigation measures.
3(b) Northern Gateway has committed to taking a lead role in researching potential behavioural changes, and associated effects such as increased energy expenditure or reduced foraging efficiency, with other interested parties.
As discussed in the preamble, Northern Gateway encourages others (DFO, Environment Canada, Aboriginal groups, other major vessel operators, fishing organizations, and universities) to also be involved in the design, conduct and funding of a more broad-scale regional assessment program. This may be an appropriate research topic for independent third party research under the proposed Marine Research Chair that Northern Gateway will help sponsor.
In keeping with the above, Northern Gateway has committed to “undertaking a cooperative research initiative with other interested parties including government, industry (shipping, fishing and recreational fishing), participating Aboriginal groups and stakeholders, to determine the effects of underwater noise on NR killer whales, the distribution of their key prey (i.e., salmon) within the CCAA, and to develop industry protocols to limit these effects, as well as generally making a positive contribution toward recovery of this population” (see Application (Volume 8B, Section 10.6.2.3, Exhibit B3-31)).
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Mitigation Measures
23 Reference: Volume 6A, Section 11
Preamble: The additional information is being requested to assist DFO in determining the risk of the proposed pipeline installations.
Request: Mitigation measures to protect fish and fish habitat are not adequately described or linked to activities and/or watercourse crossings. The proponent should provide a mitigation table that clearly identifies appropriate mitigation measures at all watercourse crossing sites - referenced by crossing method and to the impact table for watercourse crossings (referred to in Question 19). The mitigation table should also identify and rationalize the timing of the application of the mitigation measure.
Response: Mitigation measures to protect fish and fish habitat are described in the Application (Volume 6A, Section 11.5.3.3 and Section 11.6.3.3). Summaries of mitigation measures as they relate to construction activity and potential environmental effects are described in Table 11-18 Mitigation for Potential Effects on Freshwater Fish Habitat Productive Capacity and Table 11-28 Mitigation of Fish Health and Mortality Risk.
Additionally, protection and mitigation measures for watercourse crossings are described in the Construction Environmental Protection and Management Plan (“EPMP”) (Application (Volume 7A)). Relevant sections include Section 8.5.6 Watercourse Crossing Protection and Mitigation Measures and Section 8.6.2 Fisheries Protection Measures. Contingency plans and environmental management plans for watercourse crossings are described in detail in Appendix A of the EPMP. Please refer to Table A-1 for a list of plans relevant to watercourse crossing construction.
Attachment Federal Government IR 23 provides a list of mitigation measures that would be applied during design and construction of the watercourse crossings. The Table details general mitigation measures as well as those that would be applicable to a specific watercourse crossing method.
In addition to the mitigation measures described in the Attachment, additional site-specific mitigation measures will be developed for the 96 high, medium- high, medium, and medium-low risk watercourse crossings identified in Northern Gateway’s response to Federal Government IR 19. These site-specific mitigation measures will be developed during detailed engineering as part of the ongoing strategic watercourse assessment team (SWAT) field investigations.
Once detailed engineering and final route selection have been completed, additional detail will be provided in a detailed Construction EPMP. The
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Northern Gateway Response to Federal Government IR No.1 Page 50 of 246 detailed Construction EPMP will describe the requirements to ensure that the pipelines are installed in a manner that protects the environment. It will outline the general and specific methods that will be applied once site-specific crossing designs and construction methods are determined and will be used as a guidance document for construction and other Project personnel. The detailed Construction EPMP will document the requirements to be followed to ensure that the Project is constructed under applicable regulations, internal policies and procedures and will meet Project requirements. The document will be completed at least 60 days prior to the start of construction.
As specified in the Application (Volume 7A, Section 1), the Construction EPMP will be comprised of a number of separate documents, each specific to the construction of unique Project components (e.g., pipelines, tunnels, pump stations, and the Kitimat Terminal).
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Cumulative Effects Assessment
24A Reference: Volume 6A, 6B
Preamble: Canadian Environmental Assessment Act subsection 16(1)(a) requires that the environmental assessment includes a consideration of "…any cumulative environmental effects that are likely to result from the project in combination with other projects or activities that have been or will be carried out."
Request: The proponent should expand the Cumulative Effects Assessment to consider issues such as:
1. Riparian impacts from other existing or reasonably foreseeable ROWs (powerlines, roads, pipelines, etc.) and land use (forestry, agriculture, etc.); 2. Instream fish habitat impacts from existing and planned development (roads, pipelines, etc.); and 3. Increased current and future vessel traffic to and from nearby ports (e.g., Prince Rupert).
Response: 1. As noted in Application (Volume 6B, Section 11.5.3.6), the Project has considered other projects that may develop lands in the Project area and potentially damage riparian habitats. All such developments would be required to meet the requirements of the Fisheries Act and the Fish Habitat Management Policy (including compensation for any likely HADDs). They should have no net residual effects on fish and fish habitat (including riparian zones), and thus no cumulative effects.
In addition to compensation specific to Project impacts, Enbridge has an ongoing commitment to environmental stewardship, and habitat remediation and protection through initiatives such as planting and caring for native trees and plants throughout urban and rural areas along Enbridge RoW (see Application (Volume 6B, Section 1.4)).
2. As noted above, projects compliant with the Federal Fisheries Act cannot contribute to cumulative effects on the productive capacity of fish habitat as they are required to compensate for any potential harmful alteration to fish habitat.
3. As described in Application (Volume 8B, Section 4.2.3.2), an assessment of potential cumulative effects resulting from marine transportation was completed for each of the valued environmental components (“VECs”) selected for the marine environment. “The project inclusion list includes past, present and reasonably foreseeable projects (those that are likely to occur), activities and actions with residual effects that could overlap spatially and temporally with the residual environmental project effect being considered” (Application, (Volume 8B, Section 4.2.3.2)). The project
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Northern Gateway Response to Federal Government IR No.1 Page 52 of 246 inclusion list for marine transportation (Application, (Volume 8B, Section 4.2.3.2, Table 4-2)) includes current destination and transit traffic en route to the Prince Rupert Port area and other ports (bulkers, general cargo, tankers, cruise ships, and ferries), as well as future projects proposed for the Prince Rupert Port area.
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Monitoring Plans: Fish and Fish Habitat
24B Reference: Volume 6A, 6B
Preamble: Construction monitoring is conducted to minimize impacts to fish and fish habitat during construction activities. Construction monitoring typically includes oversight of works conducted in and around water by a trained professional to ensure that identified mitigation measures are being appropriately applied and environmental emergencies are responded to should they arise. Construction monitors also assess the effectiveness of the mitigation measures applied and confirm the project footprint and impact. Compensation monitoring is designed to confirm that habitat compensation measures outlined in a DFO authorization are followed and assesses their effectiveness in achieving "No Net Loss" of fish habitat productive capacity over the long term. For more information see Section 5.2 of DFO's "Practitioners Guide to Habitat Compensation".
Request: Monitoring Plans are typically included as a condition of Fisheries Act authorizations and should be reviewed during the environmental assessment of a proposed project.
Monitoring can be separated into two components: (1) construction monitoring, and (2) overall effectiveness monitoring. For each of these two components, the proponent should provide monitoring plans for mitigation, reclamation/restoration and compensation. Monitoring plans for the project should include the following elements:
1. Objectives of the monitoring program; 2. Metrics for the program; 3. The schedule of activities including long-term monitoring activities; 4. Documentation and reporting procedures; 5. Procedures and commitments to maintenance, repair or replacement of project or compensation structures that fail to work as intended; and 6. The qualifications and experience of the environmental monitor.
Response: Northern Gateway agrees that monitoring is a key part of the construction mitigation and compensation process. Monitoring and the need for monitoring before, during, and after construction are addressed throughout the Application (Volumes 6A and 6B) including many parameters of importance to fish and fish habitat.
Environmental inspection and auditing during construction are addressed in Section 6 of the Environmental Protection and Management Plan (Volume 7B). Post construction monitoring is addressed in the Application (Volume 6B, Section 11.7).
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The Project anticipates that monitoring programs will be a condition of Fisheries Act authorizations. Details of monitoring programs, including all of the items listed above will be provided in the authorization applications.
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Marine Environmental baseline – Reefs
25 Reference: Volume 6B: Environmental and Socio-economic Assessment "Marine Terminal Chapter 9 Marine Invertebrates Section 9.5 Ecology and Habitat Requirements for Marine Invertebrates Subsection 9.5.3 Hexactinellid Sponges, page 9-12
Enbridge states: “While these sponges have the potential to form reefs, their abundance during baseline surveys did not indicate the formation of sponge reefs. Sponge reefs consist of frequently interconnected circular mounds and ridges up to 21 m in height (Conway et al. 2001). The sponges within the PEAA were low-density, loose aggregations."
Preamble: It is important to have a good understanding of the existing environment. No mounds appeared in the video survey. These mounds could still appear in multibeam data.
Request: Confirm if multibeam data are available and explain if any NRCan suggests multibeam data be reviewed to determine if any potential reefs are present.
Response: Hexactinellid sponges were identified within the PDA during subtidal surveys conducted in June 2006 and June 2007. As stated in the Marine Fish and Fish Habitat Technical Data Report (Beckett and Munro 2010; Section 3, Sub- Section 3.22: Subtidal Habitat Characterization Results), “Sponges were particularly abundant at the southern end of the survey areas, just outside the marine PDA. Less than 25% of sponge aggregations in the southern region of the PDA showed evidence of active growth and much of the remaining sponges were completely or partially buried in silt.” Large aggregations, or sponge reefs, were not identified during the subtidal surveys.
In response to a request by DFO for further information on sponge abundance and distribution in Kitimat Arm, Northern Gateway undertook additional subtidal surveys within the PEAA in May 2011. Multibeam bathymetry data were used to identify eight survey sites with suitable sponge habitat. It should be noted that while multibeam data are available for Kitimat Arm, it is not currently possible to detect deep-water sponge grounds using purely acoustic methods, except for the very large sponge reefs off the west coast of Canada (Hogg et al. 2010). Within the PEAA, vertical transects were surveyed using a Remote Operated vehicle (“ROV”) with scaling lasers (to obtain accurate specimen size data) from depths of at least 100 m to the surface. A minimum of 5 transects were completed in each of the 8 survey areas and a total of 44 transects were completed in the PEAA.
Sponges were observed in each of the survey areas and were common throughout the PEAA. Typical preferred habitat appeared to be on vertical rock walls at depths of 30 to 50 m. Approximately five species of sponges were observed, three of which belong to the Class Hexactinellida (glass sponges).
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Northern Gateway Response to Federal Government IR No.1 Page 56 of 246 Glass sponge species observed included the goblet sponge, cloud sponge, and the chimney sponge. While there were areas with several sponges in close proximity, no reefs or aggregations were observed. Sponges were typically less than a meter in diameter.
Based on the results of this detailed sponge survey, it is not expected that sponge reefs are present within the PEAA.
Reference:
Hogg, M.M, Tendal, O.S., Conway, K.W., Pomponi, S.A., van Soest, R.W.M., Gutt, J., Krautter, M. and Roberts, J.M. 2010. Deep-sea sponge grounds: reservoirs of biodiversity. UNEP-WCMC Biodiversity Series No. 32. UNEP- WCMC, Cambridge, UK.
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Surface Water
Water Sources
26 Reference: Volume 6A, Section 11
Preamble: The additional information is being requested to assist DFO in determining the risk to fish and fish habitat of the proposed pipeline installations.
Request: Pipeline construction projects typically require water for project associated activities including road construction and hydrostatic testing of the pipeline. The proponent should provide the following:
1. A list of all project activities or works that will require water; 2. The water source; 3. Amount and timing of water withdrawals; and 4. Fish habitat assessment at the withdrawal sites.
Any anticipated HADDs resulting from these activities should be described along with appropriate mitigation and included in a table format.
Response: The primary Project activities that may require water are described in the Application (Volume 6A, Section 10.4.4.2). These and additional miscellaneous water uses include:
• Potable water supply for construction camps and the Kitimat Terminal • Hydrostatic testing • Ice bridge construction • Dust control • Fire suppression • Fire fighting (Kitimat Terminal) • Drilling mud preparation for drilling investigations and at directionally drilled watercourse crossings • Tunneling operations at the Clore and Hoult Tunnels
Water sources have not yet been identified, as the locations at which water will be required are not all known at this time. For example, some camps may be supplied with water trucked in from an existing potable water source, and the locations and volumes of water required for hydrostatic testing of the pipeline will depend on the hydrostatic test sections, which will not be defined until final design. Similarly, the volumes of water withdrawn from a watercourse and the timing of those withdrawals are not presently defined.
Maximum rates of withdrawal for hydrostatic testing are discussed in the Application (Volume 7A, Section 9.1.3.1). Water withdrawals for construction camps are discussed in the Application (Volume 7A, Section 10.2.2). The
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Northern Gateway Response to Federal Government IR No.1 Page 58 of 246 withdrawal volume and the timing of withdrawals will vary depending on the proposed use and water source. Water withdrawals will follow applicable legislation and guidelines regulating the withdrawal of water from watercourses and aquifers and the above-noted activities, including:
• Alberta Water Act • Alberta Environmental Code of Practice for the Temporary Diversion of Water for Hydrostatic Testing of Pipelines • DFO Ice Bridges and Snow Fills Operational Statement • DFO Freshwater Intake End-of-Pipe Fish Screen Guideline • British Columbia Water Act • British Columbia Water Protection Act • Federal Fisheries Act
The effects of water withdrawals on fish and fish habitat were discussed in the Application (Volume 6A, Sections 11.5.3.5 and 11.6.3.4).
More detailed assessment will be completed once the extraction locations, volumes, and timing are known.
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Marine Terminal Sedimentation baseline
27 Reference: Volume 6B: Environmental and Socio-economic Assessment - Marine Terminal Chapter 3 Setting for the Marine Environment Section 3.1 Physical Marine Environment, page 3-1 "3.1 Harris (1999) estimated a sediment burial rate of 0.61 cm/year for Kitimat Arm, corresponding to a net deposition rate of 1.9 x 10-3 kg/m2/day, 58% of which is generated by resuspension, with the remainder imported from river sediments."
Preamble: In previous text (as noted in IR 6) it was reported that there was no evidence of river sediment in the area- 'except for a few photographs'. Sediment in suspension could provide an important mechanism for oil for oil dispersal.
Request: Explain from where and by what mode this resuspension occurs.
Response: Northern Gateway has reviewed documentation in the ESA and in the Federal Government IR list and cannot find a reference to NRCan’s IR 6 comments about “no evidence of river sediment in the area.” The comments about resuspension of sediment and mechanism of oil dispersal are discussed below.
Harris (1999) referred to oceanographic conditions and processes in Kitimat Arm that could affect observed PAH levels in sediment, related to emissions from the Rio Tinto aluminum smelter. Sediment inputs from the Kitimat River during spring freshet are visible in historic and current aerial photographs.
Oceanographic processes that lead to sediment resuspension include estuarine and fjord circulation patterns and storm-induced waves (ocean wave orbital velocities). For fine sediment particles, the threshold speed for resuspension is typically 25-30 cm/s and for larger particle sizes, resuspension occurs at speeds of 50 cm/s or greater (Grant and Madsen 1979, 1986; Dyer 1986).
References:
Dyer, K. 1986. Coastal and estuarine sediment dynamics. John Wiley and Sons, Chichester, Sussex (UK), 358 pp
Grant, W.D. and O.S. Madsen. 1979. Combined wave and current interaction with a rough bottom. J. Geophys. Res. 84: 1797-1808.
Grant, W.D. and O.S. Madsen, 1986. The continental-shelf bottom boundary layer. Annual Review of Fluid Mechanics, Vol. 18: 265-305 (Volume publication date January 1986)
Kitimat Arm resuspension processes generally occur in water depths less than 25-30 m (most frequent in shallower areas, less than 5 m). Resuspension of
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Northern Gateway Response to Federal Government IR No.1 Page 60 of 246 sediments in water depths greater than 50 m would occur rarely, unless related to biological processes (activity of benthic organisms) and disturbances from anthropegenic activities such as fishing.
Extended ocean current measurements, conducted in the Marine Terminal Area, for Northern Gateway from April 2006 to July 2007 show that near-bottom current speeds were typically 3 -5 cm/s with maximum speeds of less than 25 cm/s (ASL, 2010; Technical Data Report – Marine Environment). The low current speeds combined with the steep shoreline and the absence of any important freshwater sources indicate that bottom resuspension of sediments within the marine terminal area will occur at very low levels.
Sediment, whether from Kitimat River freshet or from resuspension of benthic substrates, could contribute to formation of oil-mineral aggregates (“OMAs”), although the extent is likely to vary considerably over space and time. It is understood that OMA formation can affect the rates of dispersal and biodegradation for spilled hydrocarbons, particularly in surf zones (Khelifa et al. 2005). Oil-sediment interaction processes would speed up natural dispersion and degradation processes in the surf-zone where appropriate concentrations of mineral fines and oil types co-exist.
Reference:
Khelifa, A., P.S. Hill and K. Lee. 2005. The role of oil-sediment aggregation in dispersion and biodegradation of spilled oil. Developments in Earth and Environmental Sciences, 3, 131-145. .
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Marine Terminal Sedimentation significance determination
28 Reference: Volume 6B: Environmental and Socio-economic Assessment - Marine Terminal Chapter 7 Sediment and Water Quality Section 7.2 Scope of Assessment for Sediment and Water Quality Subsection 7.2.7 Determination of Significance for Sediment and Water Quality page 7-7
Enbridge states: "An environmental effect is considered to be significant if the measured parameter (e.g., total suspended solids [TSS]) occurs at increased concentrations that exceed guidelines for longer than one day. In the case where baseline conditions currently exceed guidelines, a predicted effect is considered to be significant if the increase over baseline is more than 10%."
Preamble: It is important to understand how significance criteria are established.
Request: Explain if this is chosen arbitrarily for this EIS, or has a rationale. Provide a reference if used.
Response: Northern Gateway’s approach is to set significance criteria based on regulatory guidelines or policies wherever these are available. The significance criteria for water and sediment quality were based on the British Columbia Approved Water Quality Guidelines (BC MoE 2006), and the Canadian Environmental Quality Guidelines (CCME 2007).
The Project activities being assessed (dredging during construction, stormwater discharge during operations) have the potential to release sediment to the marine environment. For this effect, the provincial and federal guidelines for turbidity and total suspended solids (“TSS”) are used. These guidelines describe a maximum increase over background conditions for “clear” (non-turbid) conditions (<250 mg/L TSS and <80 NTU turbidity) and for “high” flow (turbid) conditions (>250 mg/L TSS and >80 NTU turbidity).
• The reference to exceeding guidelines for longer than one day comes from the CCME guidelines for turbidity and TSS (short term exposure) • The reference to a significant effect when baseline conditions currently exceed guidelines being an increase of 10% or greater over baseline was derived from the CCME guideline for background values >250 mg/L TSS or 80 NTU turbidity.
For turbidity and TSS, the Federal Water Quality Guidelines for the Protection of Aquatic Life (CCME 2007) read as follows:
TSS:
Clear flow: Maximum increase of 25 mg/L from background levels for any short-term
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High flow: Maximum increase of 25 mg/L from background levels at any time when background levels are between 25 and 250 mg/L. Should not increase more than 10% of background levels when background is ≥ 250 mg/L.
Turbidity:
Clear flow: Maximum increase of 8 NTUs from background levels for a short-term exposure (e.g., 24-h period).
High flow or turbid waters: Maximum increase of 8 NTUs from background levels at any one time when background levels are between 8 and 80 NTUs. Should not increase more than 10% of background levels when background is > 80 NTUs.
References:
British Columbia Ministry of Environment (BC MoE). 2006. British Columbia Approved Water Quality Guidelines. Ministry of Environment, Science and Information Branch. Accessed: August 2011.
Canadian Council of Ministers of the Environment (CCME). 2007. Canadian Environmental Quality Guidelines. Canadian Council of Ministers of the Environment. Winnipeg, MB. (updated from 1999 Edition).
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Marine Terminal Sedimentation mitigation
29 Reference: Volume 6B: Environmental and Socio-economic Assessment - Marine Terminal Chapter 7 Sediment and Water Quality Section 7.3 General Mitigation Measures for Sediment and Water Quality page 7-7 Enbridge states: "Surface water runoff from the area outside the tank and manifold areas will be controlled so that this water will be released outside the boomed zone of the berths to the extent practical."
Preamble: It is important to understand mitigation measures in various scenarios.
Request: Provide further information on what is meant by "practical", and what the method would be if this became impractical.
Response: Please refer to the Northern Gateway’s response to Federal Government IR 7.
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Marine Terminal Sedimentation effects prediction
30 Reference: Volume 6B: Environmental and Socio-economic Assessment - Marine Terminal Chapter 7 Sediment and Water Quality Section 7.5 Effects on Suspended Sediment Levels Subsection 7.5.2 Effects on Suspended Sediment Levels 7.5.2.1 Effect Mechanisms, page 7-11
A) Enbridge states: "During dredging, it is estimated that approximately 0.5% of the material from each grab will escape from the clamshell near the bottom and another 0.5% will be lost as the bucket is moved to the surface. This will result in increased TSS levels in water."
B) Enbridge states "Because discharged water will comply with the regulations, it is not expected to exceed guideline levels for turbidity or TSS. There are separate guidelines for turbidity and TSS because they are not necessarily directly related to each other (e.g., a sample with an exceedance for turbidity may meet the TSS guideline if the sample consists mainly of fine silt).The turbidity guideline is maximum induced increase of 8 nephelometric turbidity units (NTU) when background turbidity is up to 80 NTU, The TSS guideline is maximum induced increase of 25 mg/L for ambient TSS levels up to 250 mg/L. These levels are within natural variability observed for Kitimat Arm."
Preamble: A) Methods used to predict effects should be appropriately referenced.
B) It is important to show whether there is a difference between extended periods of high turbidity due to dredging and infrequent periods of natural high turbidity.
Request: A) Provide a source/reference for this quantity of 1%. The following is an appropriate reference to percent loss in clamshell dredging: "Approximately 2% of the dredged material was lost at the dredging site Of this quantity 61% was due to the dredging itself and 38% was due to intentional barge overflow. Approximately 3.7% of the dredged material was lost at the Mud Dump Site during disposal. Total loss of dredged material during these clamshell dredging and ocean disposal operations was calculated to be 5.6% (Tavolaro, 1984)."Tavolaro, J.F., 1984. A sediment budget study of clamshell dredging and ocean disposal activities in the New York Bight. Environmental Geology. Volume 6, Number 3, 133-140.
B) Explain if this implies that because natural turbidity has a certain variability, that a project induced turbidity increase of the same magnitude as this variability, means that the turbidity is still within the same variability and guideline.
Response: A) Request A refers to a construction-related activity. A COCIRM-SED 3-D
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Northern Gateway Response to Federal Government IR No.1 Page 65 of 246 numerical circulation model was used to predict the quantity and dispersion patterns of suspended sediments resulting from dredging to develop the marine terminal (Fissel et al. 2006). The assumed loss rate for this model was 1% of the total volume of dredged material. This value was taken from a historical review of dredging operations (Shroeder and Ziegler 2004), which provided loss rates ranging from 0.2 to 3% for closed mechanical dredges. The use of silt curtains, as described in the Application (Volume 6B, Section 7.5.2) will reduce the amount of sediments released into the marine environment away from the immediate location of the dredging operations.
In the reference provided in the IR request, Tavolaro (1984) estimated that approximately 2% of the dredged material was lost at the dredging site. Of this 2%, 61% was due to dredging itself, i.e., a loss of approximately 1.2%, similar to the value of 1% cited in the assessment. The remaining losses cited by Tavalaro occurred as a result of intentional barge overflow and during disposal at sea. These losses do not pertain to the Northern Gateway dredging program because: i) barges will not be loaded to the point of overflow; and ii) all dredged material will be disposed of on land, not at sea.
B) Although Reference B refers to an activity (release of stormwater from the site to the marine environment) during the operation phase, the Preamble B and Request B appear to be related to dredging during construction. As discussed below these are not the same concepts.
During operations, most stormwater generated on the surface of the terminal will pass through an impoundment reservoir and surface layers of oily water removed (to less than 15 parts per million) prior to release through a perforated pipe to the marine environment. Discharged stormwater will need to meet applicable standards defined in the British Columbia Waste Management Act. Both the Federal (Canadian Council of Ministers of the Environment 2007) and Provincial (BC MOE 2006) water quality guidelines describe total suspended solids and turbidity guidelines based on increase above background levels. Discharges will need to meet the criteria of maximum increased turbidity of 8 NTU above background when background is ≤ 80 NTU and of maximum increased TSS of 25 mg/L above background when background is ≤ 250 mg/L. If background levels are higher (e.g., during freshet), then the guidelines are for an increase equal to 10% of the observed background levels. Compliance would be assessed against the background levels in the marine environment.
During construction (dredging), the background levels used to assess TSS plume generation against guidelines would be determined in areas away from the dredging (to avoid confounding the guideline determination). This takes into account the infrequent periods of high turbidity (e.g., Kitimat River freshet), but would not be confounded by the dredging activity itself
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Northern Gateway Response to Federal Government IR No.1 Page 66 of 246 (i.e., extended periods of high turbidity due to dredging). The sediment plume that would result from dredging during construction was modeled, and results are presented in the ESA as an increase in TSS above background over the period of dredging (see Application (Volume 6B, Section 7.5.2.3)). No values higher than the guidelines are predicted.
References:
British Columbia Ministry of Environment (BC MoE). 2006. British Columbia Approved Water Quality Guidelines. Ministry of Environment, Science and Information Branch. Accessed: August 2011.
Canadian Council of Ministers of the Environment (CCME). 2007. Canadian Environmental Quality Guidelines. Canadian Council of Ministers of the Environment. Winnipeg, MB. (updated from 1999 Edition).
Fissel, D., J. Jiang and K. Borg. 2006. Spatial Distribution of Suspended Sediment Concentrations and Sediment Deposition from Marine Terminal Dredging Operations. Sidney, BC. Unpublished report prepared for Jacques Whitford Ltd. by ASL Environmental Sciences. Burnaby BC.
Schroeder, P. and C.K. Ziegler. 2004. Understanding, predicting and monitoring contaminant releases during dredging. Paper presented at “Addressing Uncertainty and Managing Risk at Contaminated Sediment Sites”, USACE/USEPA/SMWG Joint Sediment Conference, US Army Corps of Engineers, October 2004.
Tavolaro, J.F. 1984. A sediment budget study of clamshell dredging and ocean disposal activities in the New York Bight. Environmental Geology. Volume 6, Number 3, 133-140.
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Marine Environment
31 Reference: Volume 8B, Environmental and Socio-Economic Assessment (ESA) - Marine Transportation Appendix 3B, Tanker Wake Study page
Sediments are resuspended or eroded due to shear stress applied to them by moving water. Waves breaking on a beach impart this stress to the sediment directly. Waves may also undercut unstable cliffs, causing them to fail, and thereby mobilizing large amounts of sediment. Underwater, waves increase the shear stresses at the bed by adding wave orbital currents to the existing tidal or wind generated currents. A rule of thumb is that waves will impact the bottom to a depth of the wavelength. In a sheltered environment the tanker wake may be large relative to the smaller wind-generated waves, which are fetch-limited. Even with relatively low traffic, tanker wakes could mobilize sediment which otherwise has been locked into stable shorelines. Resuspension or erosion of sediment by any of above methods may cause offshore or longshore transport of sediment, and with it the transport of contaminants, nutrients or other natural organic material.
Wake statistics (height, period) should be contrasted alongside the natural wave climate, and should include the frequency of wake-sized waves generated by tankers versus the frequency of the same-sized waves generated by storm events. If tanker wakes are larger than average natural waves, or are more frequent than similar sized storm generated waves, then susceptibility of shoreline erosion to wake energy (down to depths of the wake length) should be assessed.
Enbridge's calculations show that secondary waves of a tanker moving at 16 knots revealed a wave height of 8cm, 500 m from the ship, and 7cm at 1km from the ship.
Preamble: It is important to understand if and how the effects of tanker wakes on the environment were appropriately assessed.
Request: It is NRCan's view that this number is too low, perhaps even by an order of magnitude. Explain and verify calculated results by comparing them to reported empirical data. Once verified, and if found to be larger, explain how these larger waves will affect the shorelines and sediment transport.
Response: Northern Gateway does not believe the calculated wave heights (and corresponding wave energy) presented in the Application (Volume 8B, Appendix 3B) are under-predicted by an order of magnitude and wave that vessel wake would still be small and transient compared to the ambient waves conditions.
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Northern Gateway Response to Federal Government IR No.1 Page 68 of 246 The waters within the Confined Channel Assessment Area ("CCAA") are fetch limited, which restricts the maximum size to which wind-generated waves can grow. Nonetheless, the wave records show that the existing ambient wave conditions in the region are greater than those that Project-related vessels will create, and that the effects of vessel wakes on shorelines will therefore be minimal.
The methodology used to predict tanker and tug wake heights was based on empirical methods published in the literature specifically intended to evaluate the effect of ship wakes on shorelines. (Schiereck, 2001; PIANC 1987; Verhey and Bogaerts (1989) etc. (Refer to Application (Volume 8B, Appendix 3B) for full citations). The methods have been validated with experimental data from a number of sources. Although the methodology was developed for conditions in shallower water and indicates a reduction in wave height for deeper water, the literature does not identify what limits (if any) apply to extending the results into the deeper water. Under certain specific assumptions regarding water depth, channel width and vessel speed the calculated wave heights may be marginally higher (or lower) than presented. Nonetheless, ship wakes will be small relative to ambient wave conditions, for several reasons:
a) Within Hecate Strait recorded wave heights exceed 6 m. Within more sheltered waters (e.g. Nanakwa shoal in Douglas Channel) waves exceeding 2.0 m in height have been recorded. (Ref: Table 2.2 in ASL report "Weather and Oceanographic Conditions at Sites in the CCAA and in Queen Charlotte Sound, Hecate Strait and Dixon Entrance"). These conditions have been recorded over a 20 year data analysis period.
b) Wave heights decrease as vessel speeds decreases, water depth increases, and distance from vessel to shore increases. Due to the wide and deep natural channels (generally more than 1.0 km to shore, and often much more) the energy in the waves spreads out (reducing the wave height) by the time it reaches shore.
c) Vessel wakes are largest when the vessels are travelling close to their full sea speed (in the order of 16 knots for Project tankers). Once the vessels enter the CCAA they would be travelling at a much reduced speed (e.g. in the range of 8 to 12 knots) consistent with the limitations of the escort tugs and the commitment to maintaining a safe speed to reduce the likelihood of marine mammal strikes. At these lower speeds, vessel wakes are forecast to be smaller than those conservatively calculated for a ship transit at 16 knots.
d) Modern vessels have hull designs (e.g., bulbous bows) that are designed to reduce the generated wakes, since the energy radiated in the wakes represents additional fuel consumption. There is an economic incentive to reduce wake heights as much as possible, apart from any environmental effects.
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e) There are no known reports of wake issues with existing vessel traffic in the region. Currently the busiest sections of the route (Wright Sound) experience in the order of 5,500 vessel moves per year (including ferry and cruise ship traffic which will transit at speeds in excess of 16 knots).
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Water Quality Acid rock drainage
32 Reference:
Preamble: With reference to point 7.29 on page 67 of its October 2010 Response, the proponent combined the bulk of its response on Environment Canada acid rock drainage issues into the Natural Resources Canada point 5.1 (starting on page 10), as most of our concerns and comments were similar in nature.
Based on the October 2010 Response, Environment Canada recognizes that the proponent has:
• presented an acceptable identification process to determine acid generating potential prior to construction; • presented a tool box of generally effective mitigation measures, but not the circumstances/evaluative measures to apply them; • indicated that further investigations, testing and design of management measures will be undertaken during detailed engineering and it is expected that the work will include review and input from the appropriate regulatory authorities; and • committed to engaging appropriate regulatory agencies in the development of final acid rock drainage management procedures and mitigative measures.
Environment Canada advises that the department considers itself an 'appropriate regulatory authority', and on this basis would plan to provide additional input to the proponent for the development of acid rock drainage management procedures and mitigative measures at the appropriate time.
Environment Canada advises that stockpiling potentially acid generating material can create its own adverse environmental issues, and agencies should be consulted to ensure that stockpiling and subsequent construction mitigations are in keeping with the overall objectives of any acid rock drainage management plan / Environmental Protection Plan.
Request: Confirmation that Environment Canada is considered by the proponent as being an 'appropriate regulatory authority' that would be engaged in the development of final acid rock management procedures and mitigative measures.
In the event Environment Canada is not considered an "appropriate regulatory authority", Environment Canada recommends that the proponent:
• provide a level of preliminary detail on the likely mitigation plans for the two potential large acid rock drainage disturbances - the two tunnel sites. Such detail should:
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Northern Gateway Response to Federal Government IR No.1 Page 71 of 246 • assume a range of likely waste volumes and likely corresponding mitigation; • identify likely mitigation techniques (hierarchy of elimination, reduction, control) and scale for each site (via sketches/drawings/narrative) • identify the process for how, during trench or tunnel construction, potentially acid generating material will be timely and practically identified, separated and/or managed, or by default stockpiled for later attention. • within the Environmental Protection Plan, arrangements be made to consult with 'appropriate regulatory authorities' for unique acid rock drainage situations not covered in the Environmental Protection Plan strategies, and where volumes are >500 m3.
Response: Northern Gateway confirms that it considers Environment Canada to be one of the appropriate regulatory authorities to be engaged during the development of final acid rock management procedures and mitigative measures for the Project.
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Disposal at Sea
33 Reference: Preamble: In its October 2010 Response to Environment Canada questions, the proponent offered several points of clarification helpful to determining the potential requirement for a disposal at sea permit under the Canadian Environmental Protection Act, 1999. Specifically, the proponent indicated that disposal at sea is not planned for either acid generating rock (point 7.30(i) on page 67) or terrestrial overburden (point 7.30(iii) on page 68).
In point 7.31(i) on page 68 of the proponent's October 2010 Response, it is stated that "the disposal at sea material will be limited to excess soil and rock from marine dredging and blasting that cannot be practically salvaged for on- land disposal". Reference is also made in point 7.31(ii) on page 68 to "ongoing design for the marine terminal will consider additional measures to minimize the footprint of the marine terminal and the amount of dredging and blasting required". The connection being made between dredging and blasting in these quoted passages creates some uncertainty. Dredging and blasting should each be described as distinct activities and the fate of the material resulting from either activity should be detailed accordingly. Presenting information in this manner will facilitate an understanding of the potential need for a disposal at sea permit.
Request: Re-affirm that in the case of any blasted rock which is recovered, disposal at sea as defined under the Canadian Environmental Protection Act, 1999 is not planned.
Clarify what is specifically envisioned by marine dredging that may be conducted in relation to the project (as distinct from blasting) and the fate of the material resulting from any marine dredging (as distinct from blasting).
Response: Please refer to the Application, (Volume 6B, Section 2.2.2.1). Dredged material will be disposed of on land at the excess cut disposal area. The location of the excess cut disposal area is shown on Figure 2-2. The Application (Volume 6B, Section 2.2.2.1) also provides a description of marine dredging, (as distinct from blasting). Marine dredging will likely be completed using a derrick barge with a clamshell bucket. Total overburden dredging quantities will be approximately 30,000 m3. The estimated volume of rock blasting is approximately 25,000 m3, of which about 60% or 15,000 m3 of that material would be recoverable by dredging.
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Hydrology
Hydrologic parameters
34 Reference:
Preamble: Using the coefficient values shown in Table 3-14 (on page 3-22) for the Central Interior hydrologic zone in the peak discharge equation in Section 3.1.1.2 of the Technical Data Report - Hydrology (2010) appears to lead to erroneous estimates for the 10-year and/or 100-year discharges for basins with a catchment smaller than approximately 50 km2. Based on Figure 3-5 (Peak Discharge) and the parameters shown in Table 3-14, the extrapolation of the 100-year regressed line intersects with the extrapolated 10-year regressed line near the 50 km2 mark, which results in having 100-year estimates smaller than the 10-year estimates.
Given that Environment Canada understands that peak discharges for smaller catchment basins have been estimated by using the foregoing extrapolations, the equation coefficients and graph should be corrected. Any flow estimates obtained from these equations and used subsequently in the environmental assessment should also be corrected.
Request: Correct the regression equations for peak discharges for Central Interior hydrologic zone.
Response: The revised equations are provided in Table 34-1 below. The updated regional peak discharge correlation is shown in Figure 34-1.
Table 34-1 Coefficients for Regional Peak Discharge Correlation – Central Interior Flood Return Period Coefficient Correlation (years) C B Coefficient R2 10 0.871 0.622 0.74 100 1.41 0.628 ---
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Figure 34-1 Revised Regional Peak Discharge Relationship for the Central Interior Hydrologic Zone
The above adjustment increases the estimated peak discharges within smaller watersheds for the 1:100 year average recurrence interval and is therefore a more conservative basis for pipeline burial design. Design flows for pipeline burial designs will be finalized during detailed engineering. The effects of the Project on peak discharges are quantified in the Application (Volume 6A, Appendix 10B). With the corrected regression, the increases in 1:100 year flood discharge due to the Project (e.g., from clearing) are proportionally less than the effects computed with the original 1:100 year flood discharge regression. The effects presented in the Application (Volume 6A, Appendix 10B) are therefore conservatively high.
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Effects of the environment on the project
35 Reference: With reference to point 7.26(ii) on page 60 of the proponent's October 2010 Response (first bullet of this Information Request), the proponent indicated that the 100-year design flood was obtained on the basis of drainage area upstream of the crossing and the regional drainage area discharge correlations presented in Section 10.4.2.1 and Figure 10-4 of Volume 6B of the Environmental and Socio-economic Assessment (Assessment Report).
Based on our review, the peak discharges used in developing the regional correlations appear to be the maximum mean daily discharges from Environment Canada's Water Survey of Canada records and not the instantaneous peak discharges. The proponent should confirm which of the two values were used for the regional analyses. We note that design floods for infrastructure design are to be based on estimates of peak instantaneous discharges. For smaller catchments, instantaneous peak discharges may be considerably higher than the mean daily discharge for the same day.
It is still unclear what method was used to estimate design flood values for watercourse crossings located on streams that are gauged by Water Survey of Canada, i.e. those presented in Table 1 on page 61 of the proponent's October 2010 Response. We ask the proponent to describe the method used for these.
Table 1 provided by the proponent is useful but incomplete. The proponent is asked to complete the table by including the 100-year design flood estimates used for the environmental assessment, the frequency distribution used in obtaining the 100-year estimates, along with the goodness of fit between the data and the assumed distribution. It is assumed in the above that for crossings located on streams that are gauged by Water Survey of Canada, that the actual Water Survey of Canada records were used to estimate the design flood.
The proponent indicated that the estimated 100-year peak discharges are provided in Appendix B, Freshwater Fish and Fish Habitat, Aquatic Catalogue and Watercourse Crossing Data; however, extracting the data from the Appendix is time consuming as values are scattered amongst different pages. The information should be provided in a concise manner in Table 1 to facilitate further review.
Preamble: The first column in Table 1 that indicates the location of the watercourse crossing is unclear. A reference based on the kilometre post (KP) should be used to be consistent with the reference system used in the Assessment Report.
With reference to point 7.26(iii) on page 62 of the proponent's October 2010 Response (second bullet of this Information Request), although Environment Canada acknowledges that there is considerable uncertainty associated with predicting the effects of climate change on peak flow hydrology, there is also an
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Northern Gateway Response to Federal Government IR No.1 Page 76 of 246 increasing recognition that engineers need to account for possible climate change effects in the design of infrastructure. The Canadian Standards Association for instance recently published a Guideline for Canadian water resources practitioners (2010, CSA, Technical Guide - Development, interpretation and use of rainfall intensity-duration-frequency (IDF) information), which states that under possible climate change, scientists project that a warming climate will bring increases in the intensity and frequency of extreme precipitation. "As a result, infrastructure designed under historical IDF values may be at greater risk of damage or failure." The CSA document recommends, amongst other things, that water resources practitioners consider an adaptation design increment (i.e. a more conservative design) when investing in larger, long-lived infrastructure. Of course, knowledge of the sensitivity of the infrastructure to possible climate change is key to this recommendation.
Kharin and Zwiers (Environment Canada) have authored several influential papers on the anticipated changes in climate extremes under climate change including: Changes in Temperature and Precipitation Extremes in the IPCC Ensemble of Global Coupled Model Simulations (2007). The key findings for extreme precipitation may be found in Figure 13 and Table 6 on pages 1438 & 1439, which indicates that a present-day 20-year return period 24-hour rainfall event will become much more frequent (a 13-year return period) by 2055 on average for North America. These papers are available at:
http://journals.ametsoc.org/doi/pdf/10.1175/JCLI3320.1 http://journals.ametsoc.org/doi/abs/10.1175/JCLI4066.1
The proponent has also indicated in point 7.26(iii) on page 62 of its October 2010 Response that " … the magnitude of the design flood event is not critical to the development of a safe burial depth for a spilling channel. For incised or confined channels where the depth of scour is related to the flood magnitude, a potential allowance for changes to the design peak flow due to climate change will be considered during detailed engineering." Environment Canada requests that the crossings of incised or confined channels be identified during the environmental assessment stage. Furthermore, we reiterate our original request for a written discussion of the appropriateness of design flood selection, with an emphasis on those crossings located on incised or confined channels. Potential allowance for changes to the design peak flow due to possible climate change for these crossings should occur at this time because the design flood is a parameter that may affect the feasibility of the selected crossing type. Discussion should include consideration of acceptable risk in view of possible liabilities associated with failure and, most importantly, the safety of the public and the environment.
With respect to the last bullet of this Information Request, the proponent proposes four aerial watercourse crossings. The proponent should explain
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Northern Gateway Response to Federal Government IR No.1 Page 77 of 246 whether the potential for ice jam formations has been examined in selecting an appropriate aerial crossing.
Request: • Include the following elements in the assessment of changes to the project that may be caused by the environment: • an accounting of values and the method used in obtaining the estimated design flood values for watercourse crossings • discussion of design criteria for extreme flood events in view of potential climate change • consideration of ice jams at aerial watercourse crossings
Response: Flood values for watercourse crossings were determined on the basis of regional flood discharge-drainage area relationships developed from regional flow data. Within each hydrologic region, streamflow monitoring stations were assessed against selection criteria for inclusion in the hydrological database (proximity to study area, period of record, continuity of record, etc.). For stations accepted into the database, frequency analyses were performed on annual maximum daily discharges recorded at each station. The frequency distribution selected for each station varied according to which distribution provided the best fit to the recorded data. The Log-Pearson Type III and 3-Parameter Lognormal distributions were most commonly used. For many stations, both distributions were deemed acceptable for the dataset being analyzed. In those cases, goodness of fit was visually assessed. The data presented in the environmental impact assessment and the accompanying Technical Data Report for Hydrology were derived from the maximum daily discharge data.
Maximum instantaneous discharges are used for watercourse crossing designs. For crossings on watercourses with streamflow monitoring stations, recorded flood data are used to generate the estimated design flood at the crossing. For all other watercourses, the design flood is determined from the estimated maximum daily flood discharge derived from the regional drainage area – discharge relationships and a regionally based multiplier that is inversely proportional to drainage area; i.e., greater ratio of instantaneous to daily mean discharge for smaller drainage areas.
Climate change might increase the intensity and frequency of storm events. Precipitation for the 1:20 year storm event is predicted to increase by 12.3% by the year 2100 (Kharin et al. 2007). Correspondingly, the average recurrence interval of the present 1:20 year event is expected to decrease by half, or to approximately 10 years. These results, however, cannot be directly related to effects on the design flood hydrology for watercourse crossings because of the effects of antecedent soil moisture and ground cover on runoff coefficients (the proportion of precipitation that runs off as streamflow) and effects of climate change on snowfall.
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Northern Gateway Response to Federal Government IR No.1 Page 78 of 246 Nevertheless, some increase in the magnitude and frequency of peak flow events is expected to occur with climate change. The effects of higher flood discharges on watercourse crossings will vary between confined and spilling channels. The banks of spilling channels are overtopped during flood events, and the bankfull capacity of spilling channels is generally far less than the design flow. For spilling channels, small increases in the depth of flow correspond to large increases in wetted width and conveyance capacity. Unit discharge (discharge divided by wetted width) and average channel velocity are greatest just as the flow reaches bankfull stage. For spilling channels, the effects of climate change on design floods will be limited as changes in discharge have only a nominal effect on water levels. For confined channels, an increase in flood discharge will have a greater effect on depths of flow. However, the increased depth of scour that would result from a relatively nominal increase in water depth is small relative to the effects of other factors that affect scour depth, such as channel curvature, debris jamming, channel confluences or instream obstructions. Required burial depths at larger watercourses will be assessed during the detailed design phase of the Project. At that time, a potential allowance for changes to the design peak flow due to climate change will be considered.
Aerial crossings will be designed to be above both open water flood levels and potential ice jam levels, as required by federal and provincial agencies.
Reference:
Kharin, V.V., F.W. Zwiers, X. Zhang and G.C. Hegerl (2007). Changes in Temperature and Precipitation Extremes in the IPCC Ensemble of Global Coupled Model Simulations. Journal of Climte, Volume 20, pp. 1419-1444. 15 April 2007.
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TERRESTRIAL - Vegetation
Vegetation diversity
36 Reference: Vol. 6A, Section 8.5 (Follow-up and Monitoring for Vegetation Diversity), p. 8-152 to 8-153.
Preamble: Further detail on Enbridge's proposed monitoring program for vegetation diversity is required in order to assess its effectiveness. Long-term monitoring of vegetation is required to ascertain success of reclamation/restoration.
Request: Further detail on Enbridge's proposed monitoring program for vegetation diversity is required.
Enbridge states (Vol. 6A, p.8-152):
Vegetation follow-up and monitoring programs will be developed to determine:
• the accuracy of the prediction of effects • the effectiveness of mitigation measures
NRCan requests that Enbridge provide details on proposed monitoring program, including:
• What is the proposed schedule for monitoring? • What variables will be measured/observed? • Will there be any monitoring after the proposed 5-year period? • What is Enbridge's plan for long-term monitoring? Will it include assessment of cumulative environmental effects? • How/when will overall vegetation diversity be assessed? What standards and criteria will be used?
Response: The 1 km wide pipeline corridor described in the ESA is intended only to aid in the planning of the pipeline and the completion of the environmental assessment. The centerline shown within the 1 km corridor is for illustrative purposes only. The final locations of the two pipelines could occur anywhere within the 1 km corridor.
Following approval of the Project, the exact location of the two pipelines will be finalized within the 1 km wide corridor during detailed engineering. The final pipeline route will be selected based upon the route selection criteria described in the Application (Volume 3, Section 2) and will incorporate:
• detailed engineering • construction, and operational considerations
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Northern Gateway Response to Federal Government IR No.1 Page 80 of 246 • further site-specific constraint mapping • results of Aboriginal Traditional Knowledge studies • further biophysical investigations (e.g., identification of site-specific habitat features such as wildlife trees, wetlands, rare plants), archaeological surveys; and • input from participating Aboriginal groups and communities, landowners, the public, other interested parties and government agencies.
The intent of these various surveys and undertakings will be to obtain finer- scale information to aid in the final routing for the two pipelines.
As part of detailed routing, the centreline will be surveyed and marked. Centreline surveys will then be conducted by teams typically consisting of an engineer, a botanist, a wildlife ecologist and an archaeologist. A fisheries biologist will be included to assist in finalizing water crossing locations. Participating Aboriginal groups will also be invited to the team.
Each biophysical specialist, the archaeologist and the Aboriginal representative will be responsible for identifying important design constraints, possible alternatives to avoid or minimize effects on sensitive features and requirements for specialized construction methods during pipeline installation. Where a feature cannot be avoided, mitigation measures will be identified including details on seasonal restrictions for certain activities, habitat compensation, reclamation methods, etc. If there are conflicts among engineering, biophysical, archeological, fisheries or Aboriginal representatives, the team will work to select the route that best meets the route selection criteria, including pipeline safety and avoiding or minimizing effects on sensitive features.
Once the pipeline route is finalized, detailed environmental alignment sheets will be developed. These sheets identify the Project location with respect to the environmental or cultural characteristics located on the ground and detail the mitigation measures to be employed during construction in order to minimize Project effects.
Vegetation follow-up and monitoring programs will be finalized once detailed routing is complete. The programs will be finalized prior to the commencement of construction. The programs will contain details on the scope, schedule, variables to be measured, timeframe and standards and criteria.
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Vegetation diversity
37 Reference: Vol. 6 A, Section 8.2.7 (Scope of Assessment for Vegetation: Determination of Significance for Vegetation), p. 8-15 to 8-16 and Section 8.4.3.4 (Residual Effects), p. 8-103- to 8-112.
Enbridge states that the effects of surface disturbance on vegetation diversity are, for all key indicators, reversible and not significant.
An effect is considered reversible if the key indicator is predicted to recover to baseline condition from an environmental effect (Vol. 6A, Section 8.2.6, Table 8-5, p. 8-15).
The reversibility of key vegetation indicators depends on many things, including the adjacent forest stands, the edge effects created by the disturbance, etc. To state that the effects of a disturbance are reversible implies that it is known that the key indicator will return to its former state. Such knowledge would require extensive research.
Enbridge states that after decommissioning of the pipeline, the effects of surface disturbance on vegetation diversity will be reversed or restored (p. 8- 21): The loss of vegetation diversity by surface disturbance will be reversed
Preamble: Reversibility is difficult to assess, and cannot be accurately assessed without consideration of many variables.
Request: NRCan requests that Enbridge:
• Explain the basis upon which the effects were determined to be reversible - did Enbridge conduct or reference specific studies? If so, please provide them. • Explain what constitutes the baseline upon which reversibility will be assessed. • Describe the time frame over which vegetation diversity will be reversed.
Response: The assessment of vegetation reversibility is based on extensive research and monitoring information conducted in Alberta and British Columbia since the 1990’s. The results of these studies shows recovery of vegetation diversity in areas of surface disturbance including pipeline RoWs was successful, particularly in programs that included topsoil salvage and replacement, erosion control, maintenance of soil moisture regime, use and/or encouragement of native species and post construction monitoring and maintenance to treat problem areas. These measures and associated supporting literature are summarized in several guidelines and standard industry operating procedures including:
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• 2010 reclamation criteria for wellsites and associated facilities (AENV 2010) • Guidelines for reclamation of forest vegetation in the Athabasca oil sands region (CEMA 2010) • Revegetation using native plant materials (AENV 2003) • Environmental protection guidelines for pipelines (AEP 1994) • Reclamation of Disturbed Alpine Lands (Hardy BBT 1990) • Natural Vegetation Succession and Sustainable Reclamation (Polster 1991)
Using industry standard practices, the reclamation goals of the EPMP (Volume 7A, Section 8.5.8) were developed. The goals are to promote soil stability, encourage the re-establishment of natural plant communities and re-establish drainage patterns, watercourses and wetland communities. These goals will be met by contouring surfaces, installing drainage and erosion control structures, replacing topsoil and re-vegetating and managing disturbed sites. The re- vegetation program includes a natural recovery plan, a watercourse reclamation plan and an enhanced reclamation and post construction monitoring plan. Re- establishing stable soil, water resources and natural plant communities along the RoW will support on-going land uses, such as forestry, traditional use of vegetation by Aboriginal groups and other land use and management plans.
The baseline on which vegetation reversibility will be assessed is described in the Application (Volume 6A, Section 8.4.3).
The timeframe (duration) over which vegetation reversibility will be assessed is described in the Application (Volume 6A, Table 8-5).
References:
AENV (Alberta Environment) 2010. 2010 Reclamation Criteria for Wellsites and Associated Facilities. Albert Environment, Edmonton, AB
AENV. 2003. Revegetation Using Native Plant Materials. Guidelines for Industrial Development Sites. R&R/03-03. Edmonton, AB
AEP (Alberta Environmental Protection). 1994. Environmental Protection Guidelines for Pipelines. C&R/IL/95-2. Edmonton, AB
Hardy BBT. 1990. Reclamation of Disturbed Alpine Lands: A Literature Review. Alberta Land Conservation and Reclamation Council Report No. RRTAC 90-7. Edmonton, AB
Polster, D.F. 1991. Natural Vegetation Succession and Sustainable Reclamation. Paper presented at the Canadian Land Reclamation Association /
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Assessment Methods for Vegetation diversity and Regional Effects
38 Reference: Volume 6A, Section 8.4.2 (Assessment Methods for Vegetation Diversity) pages p. 8-22 to 8-27; vegetation pre-classification page 8-29 There is a wide variation in level of vegetation detail from different scale photos and use of Alberta Vegetation Inventory (AVI)
Preamble: Ecosite determination needs field observation of local site moisture and ground vegetation conditions. Level of vegetation detail that can be discerned is widely variable over range of data described in the report. Landsat data alone, for example, cannot reliably map and separate individual species.
Request: NRCan requests that Enbridge clarify which combination of resources /data/field study will be done where, and how assessment was/could be validated. How will ecosite phases be determined?
Clarify how the satellite unsupervised classification of pre-vegetation diversity was undertaken and how results were validated.
Response: The Technical Data Report, Vegetation (TDR) expands on the information in the ESA and includes a more detailed description of the methods including protocols, existing data sources, and vegetation classification. The latter includes preliminary ecosystem mapping, field surveys, map revision and finalization. The combination of resources/data and field surveys are discussed Section 2.3.2 Field Surveys. The combination of resources is reviewed in the TDR section 2.1.1, 2.2.1 and 2.3.1.2.
The assessment (field surveys) was validated by qualified plant ecologists, as described in section 2.3.2 in the TDR.
The ecosite phases were determined during field surveys (TDR section 2.3.2) using the reference field guides (TDR section 2.1.1). All field surveys were conducted by experienced plant ecologists. The mapping was conducted by an experienced plant ecologist who used the field survey plots as reference locations. Detailed information on the mapping process is included in the TDR section 2.3, 2.3.1.2 and 2.3.3.
The methods for satellite image classification are presented in the Application (Volume 6A Section 8.4.2.2) and follow standard approaches. Initially field surveys were conducted at specific locations called reference points in the REAA to determine a number of broad vegetation classes. In total 242 reference locations in the REAA, along with 2,474 plots in PEAA, were used to “instruct” the software to associate spectral signatures with a specific broad community type. The results of the computer model were verified following standard practices used for interpretation of satellite imagery.
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Forestry
Mountain Pine Beetle (MPB)
39 Reference: Volume 6C, Section 5.4.7: Effects on the spread of mountain pine beetle, pages 5-42 to 5-45
Data regarding the MPB in Alberta are not presented.
Preamble: The MPB has spread into Alberta, and in areas that appear to overlap the proposed pipeline RoW. MPB data can be obtained from the Province of Alberta.
Request: NRCan requests that Enbridge provide a summary of MPB infestation along the RoW in Alberta.
Response: In 2009, when information presented in the ESA (Volume 6C, Section 5.4.7) was being compiled, significant beetle overflights (of the Rockies) had just been reported and infestations had not yet become established. Since that time, significant infestations have been reported over extensive portions of the Alberta corridor to the point where the current spatial extent of infestation in Alberta is now mapped. Using the most current information will be critical in the identification of the detailed route and for timber salvage planning. Efforts will be made to obtain the then current spatial extent of infestation information during detailed engineering.
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Mountain Pine Beetle (MPB)
40 Reference: Volume 6C, Section 5.4.7: Effects on the spread of mountain pine beetle, pages 5-42 to 5-45
Enbridge states (Section 5.4.7.3, p. 5-43) that it will: "Coordinate timber hauling with pipeline construction so that wood (except wood that will be used for access control) is removed from the RoW."
Preamble: Within the context of MPB disturbances and infestation spread, it is important to understand the larger spatial context of the MPB outbreaks with respect to the proposed pipeline RoW.
The "leading edge" of beetle outbreaks is an especially important area upon which to focus mitigation techniques.
Request: The mitigation strategies proposed by the Proponent are unclear.
In Table 5-9 Enbridge presents data on MPB "stages of infestation". NRCan recommends that Enbridge confirm whether they will propose the same mitigation efforts for all areas of construction regardless of the MPB outbreak status.
NRCan recommends clarification on whether ALL harvested trees (infested and non-infested pine, and other tree species) be hauled to mills for processing soon after they are cut. Also, confirm whether the wood left behind for access control be non-infested pines.
NRCan requests that Enbridge:
• Clarify precisely what mitigation efforts will consist of with respect to different stages of infestation, and timber hauling and processing for infested and noninfested trees. • Provide a map of the RoW that overlays a map of current infestations, the extent of pine, and the extent of already killed pine (in AB and BC). • Indicate regions (in AB and BC) that are the most critical areas for mitigation strategies.
Response: Northern Gateway will undertake development of a comprehensive Timber Salvage Plan as described in the Construction EPMP (Volume 7A, Section A.3.25). This plan will specify the internal and external use of all timber, in particular, pine that is salvaged or otherwise used or disposed of by the Project. The Timber Salvage Plan will cover the entire Footprint approved for construction, including the RoW itself and all temporary and extra work space, utility corridors, access roads, camps, etc. This plan will be inclusive of
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Northern Gateway Response to Federal Government IR No.1 Page 87 of 246 applicable private, industry and regulatory stakeholders that have been identified, and will include spatial tracking of log decks. It will include provisions for the storage, transportation and disposal of all pine trees, as this is highly regulated in both Provinces. This plan is comprehensive and can only be prepared closer to construction.
For the purpose of reference, maps have been provided with the location of the proposed pipeline RoW corridor overlain with data indicating the current severity and location of Mountain Pine Beetle infestation in British Columbia (Attachment 1 FedGov IR 40) and in Alberta (Attachment 2 FedGov IR 40). This information will be incorporated into the Timber Salvage Plan when developed closer to construction. At that time, if more recent Mountain Pine Beetle spatial data is available, this information will be utilized to achieve a more accurate and effective Timber Management Plan.
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Bark Beetles
41 Reference: Volume 6C, Section 5.4.7: Effects on the spread of mountain pine beetle, pages 5-42 to 5-45
Preamble: In addition to facilitating the spread of MPB, Project construction could facilitate the spread of other bark beetle outbreaks, such as spruce bark beetle and Douglas-fir bark beetle outbreaks. It is important to indicate what will be done with all trees species, not just MPB hosts (i.e., pines).
Request: Enbridge discusses the effects of logging and hauling operations resulting from the construction of the RoW on the spread of mountain pine beetle (MPB); other bark beetles are not discussed.
NRCan requests that Enbridge:
• Discuss the potential effects of Project construction on non-MPB bark beetle (i.e., spruce bark beetle and Douglas-fir bark beetle) populations and spread. • Identify mitigation techniques for non-MPB bark beetles, including the treatment of non-pine tree species.
Response: With regard to the first request, the influence of other forest pests was not considered significant for the Project, at the landscape level, which is the methodology used for cumulative effects analysis (see Application (Volume 6C Section 5.4.7)).
It is known that other forest pests have had dramatic influence in the past, with one case in point being the spruce beetle epidemic in the Bowron Valley of BC. However the cumulative effect analysis cannot be accomplished on a predictive basis, when there is no supporting attribute or geomatic data available.
With a comprehensive Timber Salvage Plan (see Northern Gateway’s response to Federal Government IR 40), log decks and debris piles will be geomatically tracked and managed across the entire Project footprint. This means that the wood movement and sanitation practices used as mitigation techniques for pine are also available for other species.
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Forest Pests and Pathogens
42 Reference: Volume 6C, Section 5.4.7.1, Page 5-42
Preamble: Many pathogens are present in soil. Soil disturbance and the movement of equipment to and from the site risks transporting and introducing new pathogens. Shipping terminals frequented by foreign tankers can also be a risk for the introduction of new exotic forest pathogens.
The pipeline corridor could create an uninterrupted pathway for the movement of air, potentially facilitating the long distance dispersal of airborne pathogens (particularly fungal propagules).
Request: Enbridge assesses the effects of the pipeline on the spread of mountain pine beetle (MPB) but no other biotic forest disturbance agents, such as forest pathogens, were identified. In addition to other forest insects, there are forest pathogens in the PEAA which may be affected by or interact with the project activities. For example, construction activities may lead to wounding of roots and stems of trees left in place. Such trees are at increased risk of colonization by forest pathogens and pests, which may result in tree mortality and greater windfall. Furthermore, the project could serve as a pathway for the dispersal of exotic invasive pathogens and insects.
NRCan requests that Enbridge:
• survey for the occurrence and incidence of forest pathogens and insects (other than MPB) along the proposed RoW so that changes in forest health can be determined. • describe what strategies Enbridge will use to reduce the risk of forest pathogen impacts and to monitor pathogen activities.
Response: Northern Gateway will discuss this suggestion with Provincial forestry resource managers in British Columbia and Alberta to seek direction regarding inclusion of these types of surveys and strategies in pre-construction timber salvage planning.
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Wildfire
43 Reference: Volume 7A, Appendix A, Section A.2.2.9, Page A-36
Preamble: Reducing the risk of a fire ignition is the best way to prevent wildfires. Great caution should be exercised when pile burning and carrying out ignition-prone operations within the proximity of certain vegetation types. Some types are much more susceptible to fire ignition and spread depending on the seasonal weather conditions.
Request: Enbridge indicates that burning slash will not be permitted if the fire hazard is high or extreme. However, the plan does not provide specific weather conditions under which burning (or certain operations, such as blasting) would occur.
• Explain how Enbridge's plan will use the Canadian Forest Fire Weather Index System fuel moisture codes and fire weather indexes which are used by fire management agencies throughout Canada.
Response: During the fire season, the Wildfire Management Branch (British Columbia) and Sustainable Resource Development (Alberta) have weather forecasters that collect and evaluate weather station data to determine Fire Danger Ratings. The resultant maps are updated daily and posted Wildfire Management Branch (British Columbia) and Sustainable Resource Development (Alberta) websites.
These maps provide a uniform, numeric method of rating regional fire danger. However, they are dependent on weather only and do not consider localized differences in ignition risk, fire fuel sources, or topography. To incorporate both the Canadian Forest Fire Weather Index System, fuel moisture codes and the fire weather indexes, as well as site specific fire spread protection measures all along the route, the detailed Construction EPMP will incorporate the following:
“In consultation with the local Forestry officer, and unless otherwise permitted, controlled burning of organic debris will only be conducted when the following site specific Canadian Forest Fire Weather Index System fuel moisture codes and fire weather indexes are met.” (NRC, 2009; Malagaweather, 2011):
• Fine Fuel Moisture Code (FFMC), a numerical rating of the moisture content of litter and other cured fine fuels is less than 70. • Duff Moisture Code (DMC), a numerical rating of the average moisture content of loosely compacted organic layers of moderate depth, is less than 30. • Drought Code (DC), a numerical rating of the average moisture content of deep, compact, organic layers, is less than 200.
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Northern Gateway Response to Federal Government IR No.1 Page 91 of 246 • Initial Spread Index (ISI), a numerical rating of the expected rate of fire spread, combines the effects of wind and FFMC on rate of spread without the influence of variable quantities of fuel, is less than 10. • Build Up Index (BUI), a numerical rating of the total amount of fuel available for combustion, is less than 40. • Fire Weather Index (FWI), a numerical rating of fire intensity that combines ISI and BUI, is suitable as a general index of fire danger throughout forested and rural areas, is less than 17 (low to moderate). “
As outlined in the Application (Volume 7A, Section 1), a detailed Construction EPMP will be developed during detailed engineering. It is expected that the detailed Construction EPMP will be comprised of a number of separate documents, each specific to the construction of unique Project components (i.e., pipelines, tunnels, pump stations, and the Kitimat Terminal). The documents will include general and specific protection measures and will be integrated into the environmental management approach for each Project component. The detailed Construction EPMP will include an expanded fire spread protection measures section and will be filed at least 60 days prior to the start of construction.
References:
Natural Resources Canada, 2009. Background Information. Canadian Forest Fire Weather Index (FWI) System.
Malagaweather, 2011. Fire Weather.
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Wildfire
44 Reference: Volume 7A, Appendix A, Section A.2.2, Pages A-30 to A-37
Preamble: Best practices in contemporary wildfire management require a consultative approach which utilizes relevant provincial fire management staff.
Request: The Fire Response Contingency Plan does not follow the Canadian Incident Command System (ICS) used by all fire agencies in Canada.
NRCan requests that Enbridge: • Provide a Fire Response Contingency Plan that is consistent with ICS and outline how construction crews (spreads) will support each other in the event of a fire, and how activities will be coordinated with provincial fire management staff.
Response: The Project’s Fire Response Contingency Plan will be updated to be consistent with the Canadian Incident Command System (“ICS”) prior to construction.
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Wildfire
45 Reference: Volume 7A, Appendix A, Section A.2.2.2, Page A-31
Preamble: The fire management strategy should be consistent with current provincial legislation.
Request: Enbridge references the Forest Practices Code of British Columbia Act as the relevant fire management legislation in British Columbia; this reference is out of date.
NRCan requests that Enbridge: 1. Amend this section to reflect the current legislation. It is NRCan's understanding that this is the Wildfire Act S.B.C. and Wildfire Regulation. Furthermore, Enbridge should then clarify that its Fire Response Contingency Plan is in accordance with this legislation.
Response: A detailed Construction EPMP will be developed during detailed engineering. The detailed Construction EPMP will be filed at least 60 days prior to the start of construction. The reference to the Forest Practices Code of British Columbia Act will be changed to the Wildfire Act (S.B.C.) and Wildfire Regulation at that time assuming that the name of the legislation is not changed in the meantime.
The Wildfire Regulation addresses the need for fire suppression equipment and fuel breaks that are adequate for fighting wildfires. Northern Gateway’s Fire Response Contingency Plan will be updated to address the revised legislation.
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Forestry - Sustainable timber supply
46 Reference: Vol. 6C, Section 5.4 (Forestry) and Section 5.12.1 (Summary of Effects on Non-traditional Land Use: Forestry)
Preamble: Precise values for areas and timber volumes are required to understand the potential implications to long-run sustained yields by tenure holders, compensation for timber removal, and carbon sequestration potential.
Request: With respect to permanent removal of forested land, on page 5-147, Enbridge states: "Project activities will affect 7,253.3 ha of forestry land base and will cause an estimated 1.11 million m3 of total timber loss".
Enbridge does not distinguish between the "forest land base" and the timber harvesting landbase, and does not report areas and volumes by tenure holder.
The total volume reported does not appear to include clearing required for access to, and construction of, tunnels.
In Vol. 6A, Section 2.7.1.1, p. 2-21 Enbridge states the following regarding the clearing for the construction of the Kitimat terminal:
"Within the 220 ha area, clearing of 110 ha of forest cover will be required, in addition to approximately 40 ha of existing cutblocks."
It is unclear what the fate of these existing cutblocks is, and if this area is included in the area of mature forest that will be permanently removed from production.
NRCan requests that Enbridge: 1. Specify those portions of total forest land base and timber volume affected according to on and off the commercial (timber harvesting) land base, and by tenure holder (could add to Table 2-9 in the Vegetation TDR); 2. Distinguish between new and upgraded roading and powerline requirements (e.g., Vol. 6A, Table 2-2), and include the clearing needed for access to and construction of tunnels (not just pump stations) 3. Specify fate of 40 ha of existing cutblocks at proposed Kitimat Terminal site (Vol. 6A, Section 2.7.1.1), and clarify whether 110 ha of mature forest or 150 ha of total forest area will be permanently removed from production.
Response: 1. This information cannot be determined at this stage of Project planning.
2. Northern Gateway is not able to distinguish between new and upgraded roading and powerline requirements at this time. The clearing needed
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3. Confirmed that the 110 ha is incremental to the 40 ha of existing cutblocks.
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Forestry - permanent sample plots
47 Reference: Vol. 6C, Sections 5.11.1 (Follow-up and Monitoring for Non-traditional Land Use: Forestry) and 5.12.1 (Summary of Effects on Non-traditional Land Use: Forestry)
Preamble: Permanent sample plots (PSPs), forest research plots, and forestry demonstration installations represent a significant investment and are valuable to long-term research and monitoring.
Request: Criteria for designation and protection of "high priority forestry plots" or "plots prioritized for research or protection" (Vol. 6C, footnote 13 of Table 5-39) are not specified.
Enbridge states (Vol. 6C, line 2 of page 5-146):
"Northern Gateway will employ forestry monitors that plan and consult with relevant forestry stakeholders to avoid potential disturbance of high-priority forestry plots when clearing forestry during construction." Table 5-39 of Vol. 6C (footnote 13, page 5-149) describes the following mitigation:
"Route the pipelines to avoid plots prioritized for research or protection. Route- marking surveyors will notify project management of any flags tied to trees making up essential plots. Northern Gateway will coordinate with the requisite forestry stakeholder to make a minor route adjustment to avoid the essential plot."
NRCan requests that Enbridge: 4. avoid, with at least a 25-m (1 tree height) buffer, any permanent sample plots (PSPs), forest research plots, or forestry demonstration installations registered with Federal or Provincial agencies and designated to have ongoing value; 5. add "forest research plots" to the list of features to be searched for, flagged and avoided as per Vol. 7A, Section 8.5.1, "Environmental Flagging." • In addition, NRCan requests that Enbridge also: • Specify criteria for designation and protection of permanent sample plots (PSPs), forest research plots, and forestry demonstration installations • Specifically describe mitigation measures that will be taken to avoid disturbing such sites (e.g., how great a buffer will be left?).
Response: As stated in the Application (Volume 7A, Section 1) a detailed Construction EPMP will be developed during detailed engineering and will be filed at least
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Northern Gateway Response to Federal Government IR No.1 Page 97 of 246 60 days prior to the start of construction. This Construction EPMP will expand the Environmental Flagging Section (Volume 7A, Section 8.5.1) to ensure that “priority” forest research plots are added to the list for environmental flagging. In addition Northern Gateway will work with those having an interest in forest research plots, as described in the Application (Volume 7A, Section 7.3), to ascertain the significance of specific plots to minimize or eliminate damage during detailed routing. Northern Gateway will track the plots in accordance with the Application (Volume 7A, Section 6.6), so that wherever possible these installations can be protected with a buffer.
Criteria for designation as a priority “forest research plot” are as follows:
• Forest Inventory Plots, specifically Permanent Sample Plots (“PSPs”) which occur at known, geospatially referenced locations throughout both provinces. • Forest Insect and Disease plots that continue to have residual significance with respect to population dynamics, pest control, etc. • Silviculture installations, where stakeholder dialogue has identified significant long term value.
Any plot that meets the significance test will be identified, wherein each plot is assessed for potential avoidance during detailed routing, protected with a 25 m buffer where feasible, or identified for compensation when entitled by regulation.
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Forestry - reclamation through reforestation
48 Reference: Vol. 7A, Section 8.5.2 Clearing, Section 8.5.8 Reclamation: Project Revegetation Program
Preamble: Previously forested sites that are cleared temporarily should be reforested. It is NRCan's understanding that the B.C. Ministry of Forests, Lands, and Natural Resource Operations has a "Zero Net Deforestation" policy. Grubbing process, if not absolutely necessary, will cause undue disturbances and complicate the reclamation process.
Request: There is uncertainty regarding "temporary" clearings (extra 25 m of RoW, temporary access roads) being grubbed (in the case of the RoW), and whether they will be reforested or not.
Enbridge describes temporary workspace included as part of the Project (Vol. 6A, Section 1.2, page 1-1, 2nd and 5th bullets):
• …a 25-m wide temporary workspace will be cleared of vegetation, where needed. Extra temporary workspace, totalling approximately 10% of the construction RoW, will be needed at specific locations for highway, road, watercourse and utility crossings, grading along sloping terrain, timber salvage and other special circumstances. • temporary access roads, construction camps, and other support infrastructure (e.g., borrow pits and stockpile sites) required for construction • In reference to its proposed Revegetation Program (Vol. 7, Section 8.5.8, page 8-20), Enbridge states:
Trees may also be planted to assist reforestation of infrastructure sites.
NRCan recommends that all previously forested sites subject to temporary clearing will be reforested with mixed tree species suitable for the site in accordance with provincial standards and regulations, and suggests adding this commitment to Vol. 7A., Section 8.5.8 and Table 8-1 (p. 8-21).
NRCan recommends that no grubbing or disruption/removal of forest floor and stumps will be conducted unless absolutely necessary.
NRCan requests that Enbridge: • Confirm/clarify that temporary clearings and workspaces will be reclaimed by planting trees. Specify what areas will be reforested, and how/when.
Response: In response to the preamble discussion of pipeline terminology, specifically
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Northern Gateway Response to Federal Government IR No.1 Page 99 of 246 Temporary Work Space (“TWS”) and the Extra Temporary Work Space (“EWS”) described in the Application (Volume 6A, Section 1.2), as it relates to work on forested land, it should be noted that the Project routinely requests additional working space for its construction crews and although some of this additional workspace may eventually be built upon, the vast majority of the TWS and EWS is merely salvage logged and never grubbed nor graded. Present day logging technology routinely reduces stumps to 20 cm in height or less, which is sufficient to allow pipeline construction equipment to pass over the ground to complete their work.
The Grubbing sub-section of the Application (Volume 7A, Section 8.5.2) specifies that grubbing is only conducted where soil removal is necessary and only immediately prior to soil work, thereby reducing soil productivity impacts and erosion. This means that any TWS or EWS that does not become part of the permanent Project footprint, remains in its “cleared” condition and can readily be returned to forest (timber) production once construction is complete.
A reforestation program will be conducted on the temporary (forested land) withdrawals that are not used for Project infrastructure. A detailed reforestation plan for the Project will be completed in consultation with provincial resource agencies and disposition holders. The Project revegetation program in the Application (Volume 7A, Section 8.5.8) specifies that self sustaining native plant communities will be promoted, rather than trees, because it is referring to the permanent RoW where the soils have been modified and reclaimed.
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Vegetation reclamation
49 Reference: Volume 7A, Section 8.5.8 (Reclamation) and Appendix A, Section A.3.24 (Vegetation Reclamation and Protection)
Preamble: All disturbed forested areas outside of 25m RoW should be regenerated to forest species Ability to acquire suitable seed stock will require advanced planning to contract seed selection and production
Request: It is NRCan's view that locally common, native forest plant species should be used in all forested areas, not just where suitable seed stock is available (Vol. 7A, App. A, p. A-123)
Enbridge states that procuring suitable seed depends on its "commercially available" and "if there are seed shortages" (Vol. 7A, p. 8-20, 5th bullet); Seed from a wide selection of native grass and legume species can be made available by contract growing via commercial seed brokers (if ordered in advance).
NRCan requests that Enbridge:
• Map present plant communities; perform pre-harvest assessments • Specify arrangements for ordering and procuring suitable seed to avoid seed shortages.
Response: Northern Gateway will consult with Provincial resource managers, landowners and participating Aboriginal groups to determine appropriate reclamation practices and specific seed requirements. These could include the measures suggested by NRCan. Please see the Application (Volume 7A, Appendix A.3.24).
The following measures pertaining to ordering and procuring suitable seed should be inserted immediately following Table A-11 in the Application (Volume 7A , Appendix A):
• Contact commercial seed producers well in advance (two to three years) prior to the anticipated need of seed to determine availability and production schedule of each of the required species. (Lead times can change considerably from one year to the next, depending on weather and demands arising from other development projects.) • Identify preferred species and acceptable alternatives where possible. • Secure seed supply of each individual species - from existing stock and/or contracting the production of additional quantities. • Consider utilizing several seed producers to reduce the risk of lack of seed due to a crop failure, especially of those species required in large
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Vegetation reclamation
50 Reference: Vol. 7A, Section 8.5.8 (Reclamation) and 8.5.9 (Enhanced Reclamation and Post-Construction Monitoring)
Preamble: Vegetation reclamation methods should reflect the different land use types of the forested areas through which the RoW would pass.
Request: The criteria for alternative reclamation options (e.g., "enhanced reclamation", Vol. 6A, section 2.2.11; Vol. 7A, Section 8.5.8, Table 8-1, Section 8.5.9, top of page A-124) are not clear.
NRCan recommends that enhanced restoration approaches should be applied to protected areas, habitat of listed wildlife species, and areas zoned for high biodiversity emphasis in regional land use plans and landscape-level forest stewardship or management plans; this expectation can be added to the last line of Table 8-1 in Vol. 7A, and in the bullet list in Section 8.5.9.
NRCan requests that Enbridge: • Specify the criteria invoking enhanced reclamation and the major reclamation options, including tree planting (Vol. 7A, Sections 8.5.8 and 8.5.9), and choice of regeneration method (Vol. 7A, page A-124)
Response: All provisions of the Application (Volume 7A, Section 8.5.8 and 8.5.9) apply to the “residual” footprint of the Project. That is, all of the land that remains occupied by Northern Gateway (under crown disposition), after construction. It does not apply to lands that will be temporarily used during construction, Temporary Work Space (“TWS”) and the Extra Temporary Work Space (“EWS”) that will be used temporarily for construction of the Project, and turned back to the crown.
Construction reclamation and re-vegetation of pipelines is normally directed to the stabilization of soils and the re-establishment of vegetation that will assist pipeline maintenance over the operational life of the Project. Agricultural uses such as hay production and improved pasture are normally compatible with the operations phase of the Project. However Northern Gateway has 2 pipelines within the RoW, and the width of the residual land disposition (the PLA) is proposed to be approximately 50 m on average. Approximately 25 m of the RoW over centerline will be revegetated to grass for monitoring and access purposes. The remainder of the RoW would be allowed to revegetate with woody vegetation. The reforestation plan would consider species and management regimes matching the stated land use objectives of applicable land use plans. In instances where forest management is compatible, the option would be available for the Project to re-vegetate with tree species and manage the stands accordingly, over time.
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Mitigation measures for rare plants and old-growth forests
51 Reference: Vol. 6A, Section 8.4.3.3 (Mitigation and Effects Management), p. 8-101 to 8- 103, Vol. 7A, App. A, Section A.3.24 (Vegetation Protection and Management Plan)
Preamble: A clear management plan for rare plants and ecosystems is required to ensure that loss and/or degradation of species does not threaten the viability of the rare plant or ecosystem.
Knowing the criteria for rerouting decisions is necessary to assess the proposed mitigation measures for old-growth forests and rare plants.
Request: The protection/management plan for rare plants and ecosystems is ambiguous.
Enbridge proposes rerouting and micro-rerouting as measures to mitigate the effects on old-growth forests and rare plants, but does not state under what circumstances such measures will be taken.
Regarding mitigation efforts for old-growth forests, Enbridge states (Vol. 6A, p. 8-102):
Pipelines should be rerouted around old growth forests because these forests are unique and protective legislation exists. However, if this is not possible then no extra temporary workspace will be included, and grubbing will be limited to the ditch line and any areas requiring grading.
Regarding mitigation efforts for rare plants, Enbridge states (Vol. 6A, p. 8- 102):
As a general rule, red- or blue-listed species in British Columbia, species that are At Risk or May Be at Risk in Alberta, or a species ranked S1 or S2 by either the BC CDC or ANHIC should be avoided by micro-rerouting of the pipelines. If that cannot be accomplished, the next acceptable option is transplanting the rare plant specimen or seed collection.
In the Vegetation Protection and Management Plan, Enbridge states (Vol. 7A, App. A, page A-121):
Where rare plants or sensitive ecosystems are identified before construction, various techniques could be used to limit any adverse effects on the population or community.
These techniques might include:
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Northern Gateway Response to Federal Government IR No.1 Page 104 of 246 • avoiding the population or ecosystem • replacing stripped topsoil containing native vegetation seed bank (rollback) • transplanting the population to another site for post construction reclamation
NRCan requests that Enbridge: • State criteria for rerouting to avoid old-growth forests and rare plants. • Specify thresholds of "acceptable loss" (e.g., < 12% at landscape, district and provincial levels) for the avoidance or acceptance of ecosystem and rare plant/vegetation loss to be incurred by the project. • Under what circumstances (e.g., economic, legislative, environmental) does Enbridge anticipate rerouting to be "not possible"? • Considering that preliminary surveys have already been conducted, are there specific areas where Enbridge anticipates (or has already decided) that rerouting "cannot be accomplished"? If yes, where and why?
Response: Please see Northern Gateway’s response to Federal Government IR 36.
A balance between preservation of the old growth forests and rare plants, and other route selection criteria will be maintained. Thresholds for acceptable loss are defined in Application (Volume 6A, Section 8.2.6, Table 8-5), see magnitude. These criteria apply to the local, regional and provincial levels.
The application filing is for a 1 km wide corridor in which the final centerline will be located. In addition, along the current pipeline route there are ‘control points’ where there is little flexibility to alter the current alignment. These locations include approach slopes to watercourse crossings, which have been selected to traverse stable valley side slopes or to avoid sensitive fisheries habitat. Additional areas where route alteration is limited include the approaches to Hoult and Clore tunnels and in areas where the pipeline routing has been based on avoiding unstable terrain.
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Land Use
Reserve Lands
52 Reference: Volume 3, Appendix C, Pipeline Route Atlas
Preamble: Aboriginal Affairs and Northern Development Canada is contemplating Crown conduct in relation to the project. The department will require more information on the use of reserve lands and potential future reserve lands.
Request: Enbridge has indicates that there will still be a series of minor adjustments to the proposed corridor.
Provide more specific information on each of the following areas:
- Will the revised corridor still require the use of reserve lands and potential future reserve lands (i.e., the federal Crown lands which may be added to Woyenne IR # 27 (Lake Babine First Nation))? - Is the Applicant considering any other uses of reserve lands or potential future reserve lands (i.e., the federal Crown lands which may be added to Woyenne IR # 27 (Lake Babine First Nation)) which may require departmental approvals (e.g. permits or leases associated with utilities, roadway use, work camps, timber harvesting, solid waste, pump stations, etc.)
Response: Below is a summary of the proposed use of reserve lands for the pipelines and pump stations.
In each of the following cases we acknowledge that grant of a RoW over reserve lands would need to be made with consent of the First Nation pursuant to the provisions of the Indian Act. It is anticipated that this would be done well in advance of commencement of construction, failing which alternative routing and pump station locations would be utilized.
Alexander (Alexander First Nation) In respect of the Alexander (Alexander First Nation), Northern Gateway will not require the use of Alexander No. 134A Indian Reserve for the purposes of placing a portion of the proposed pipeline on the said lands. The pipeline route is currently located on the Alexander No. 134A Indian Reserve between KP 249.1 and KP 251.1. As stated in the Application Update (Volume 5A, Section 4.3.1), Northern Gateway will relocate the pipeline route off of the reserve to address concerns raised by the Alexander (Alexander First Nation). This route refinement will appear in a future pipeline route revision. The pipeline route is currently located on one quarter section of land, NE 20-56-27 W4M, from KP 65.5 to KP 66.4 that is owned by AFN TLE Land Corp.
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Northern Gateway Response to Federal Government IR No.1 Page 106 of 246 Alexis Nakota Sioux Nation Northern Gateway anticipates that the revised corridor will still require the use of Alexis Whitecourt No. 232 Indian Reserve lands, near Whitecourt, Alberta, for the purposes of placing a portion of the proposed pipeline and a pump station on the said lands. The pipeline route is currently located on the Alexis Whitecourt No. 232 Indian Reserve from KP 203.8 to KP 208.3. As stated in the Application Update (Volume 5A, Section 4.3.2), Northern Gateway is also prepared to relocate the Whitecourt pump station (KP 203.3) onto the reserve, as requested by the Alexis Nakota Sioux Nation. Subject to confirmed Alexis Nakota Sioux Nation interest and with their support for the Project, this refinement will appear in a future pipeline route revision. A location on the reserve has been determined by both Northern Gateway and the Alexis Nakota Sioux Nation to be the preferred site. Technical confirmation of the pump station relocation to this site will be undertaken during detailed engineering.
The relocation of the Whitecourt pump station onto the identified site on the Alexis Whitecourt No. 232 Indian Reserve would require the construction of a permanent access road and a permanent power line on the reserve to service the pump station. The exact location of these facilities will be determined during detailed engineering.
West Moberly First Nations Northern Gateway and West Moberly First Nations are currently discussing the potential West Moberly First Nations selection of TLE lands coincident with the location of the Tumbler Ridge pump station (KP 600.9).
The potential establishment of a new West Moberly First Nations reserve coincident with the location of the Tumbler Ridge pump station (KP 600.9) would also require the construction of a permanent access road and a permanent power line on the reserve to service the pump station. The exact location of these facilities will be determined during detailed engineering.
McLeod Lake (McLeod Lake Indian Band) As stated in the Application Update (Volume 5A, Section 4.3.2), Northern Gateway has relocated the Bear Lake pump station and the pipelines (KP 719.6 to KP 719.9) onto the Sas Mighe No. 32 Indian Reserve, as requested by McLeod Lake (McLeod Lake Indian Band). Subject to technical feasibility and continued support from McLeod Lake (McLeod Lake Indian Band), a site on the reserve has been determined by both parties to be the preferred site. Technical confirmation of the pump station relocation to this site will be undertaken during detailed engineering.
The location of the Bear Lake pump station on the Sas Mighe No. 32 Indian Reserve will require the construction of a very short permanent access road and a permanent power line on the reserve to service the pump station. The exact location of these facilities will be determined during detailed engineering.
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Lake Babine First Nation Northern Gateway understands that the pipeline route (KP 932.0 to KP 932.4) is located on potential future reserve lands that may be added to Woyenne No. 27 Indian Reserve. Due to existing land development in this area, Northern Gateway proposes to keep the pipeline corridor in its current location, and further discussions to that end will take place.
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Landscape Ecology
53 Reference: Vol 6A, Appendix 3A: Project Inclusion List within the REAA in Alberta and British Columbia (p. 3A1 to 3A-15); Vol. 6A, Section 6.2.5 (Administrative boundaries), Table 6-1, p. 6-8
Preamble: Land use plans and ecosystem management plans may contain thresholds and guidelines for total disturbance within a land management area; a discussion of the Project and other developments within the context of these guidelines is required in order to assess/analyse cumulative effects.
Request: The discussion of potential cumulative effects within the context of existing land use plans or ecosystem management plans offered is not found in the Application.
NRCan acknowledges that the Proponent has listed the Land Use Planning Areas crossed by the proposed pipeline (Vol. 6A, Section 6.2.5, Table 6-1, p. 6- 8.) and other projects within the proposed Regional Effects Assessment Area (REAA) (Vol. 6A, App. 3A, p. 3A1 to 3A-15).
There is no discussion or indication of how the proposed Project, in conjunction with other proposed and existing developments, fits into existing land use plans or ecosystem management plans for the area; such plans may have guidelines for total disturbances within an ecological region.
NRCan requests that Enbridge: • List and reference all existing land use plans or ecosystem management plans that apply to the REAA. • Identify any guidelines within existing land use plans, ecosystem management plans that would apply to this Project, and discuss how the cumulative effects of other developments within the REAA may exceed (or fall within) thresholds or guidelines in these plans.
Response: A listing of land use and ecosystem management plans that would apply to the Project is provided (Attachment Federal Government IR 53).
Guidelines that are listed for all land use plans (i.e., land and resource management plans, forestry management plans, official community plans, etc.) in Alberta and British Columbia, with respect to resource development do not specify thresholds for cumulative effects management. Therefore, the scope of the assessment does not include an analysis of whether cumulative effects of other developments within the REAA may exceed (or fall within) thresholds or guidelines in these plans.
The plans, however, do provide guidance for land use planning areas, where
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Northern Gateway Response to Federal Government IR No.1 Page 109 of 246 lands are zoned for specific uses and values and provide direction for land use, and specify resource management objectives and provide general mitigation strategies (e.g. for parks and protected areas). These objectives, directions and mitigation strategies have been used in the effects assessment, including cumulative effects assessment, in the selection of valued ecosystem components (“VECs”) and in establishing related specific parameters and thresholds, where applicable.
Therefore, despite the lack of thresholds in the land use plans, the cumulative assessment approach (spatial analysis including map overlays, area statistics) addresses all land use VECs (see Application (Volume 6A, Section 3.0)).
References for the Listing of Land Use Plans:
District of Kitimat. 2008. District of Kitimat Official Community Plan. December 2008
Government of Alberta. 2010. Land Use Framework.
Government of Alberta. 1999. Whitecourt and Anselmo Public Land Use Strategy
Government of Alberta. 1984. A Policy for Resource Management on the Eastern Slopes
Government of Alberta, Sustainable Resource Development. 2011. Forest Management Agreements.
Peace River Regional District. 2009. North Peace Fringe Area Official Community Plan.
Province of British Columbia, Ministry of Agriculture and Lands, Integrated Land Management Bureau. 2007. Morice Land and Resource Management Plan. February 2007.
Province of British Columbia. 2004. Prince George Land and Resource Management Plan.
Province of Birtish Columbia. 2002. Kalum Land and Resource Management Plan. May 2022.
Province of British Columbia. 2000. Lakes District Land and Resource Management Plan. January 2000.
Province of British Columbia. 1999. Fort St James Land and Resource Management Plan. 30 March 1999.
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Province of British Columbia. 1999. Dawson Creek Land and Resource Management Plan. March 1999.
Province of British Columbia. No date. Vanderhoof Land and Resource Management Plan.
Regional District of Bulkley-Nechako. 2010. Fort St James Rural Official Community Plan.
Regional District of Bulkley-Nechako. 2009. Burns Lake Rural and Francois Lake (North Shore) Official Community Plan.
Regional District of Bulkley-Nechako. 2009. Vanderhoof Rural Official Community Plan.
Regional District of Bulkley-Nechako. 2004. Houston Topley Granisle Rural Official Community Plan.
Regional District of Bulkley-Nechako. 2003. Omineca Settlement Corridor Official Community Plan.
Regional District of Fraser-Fort George. 2007. Crooked River-Parsnip Official Community Plan.
Regional District of Bulkley-Nechako. 2009. Vanderhoof Rural Official Community Plan.
Regional District of Bulkley-Nechako. 2004. Houston Topley Granisle Rural Official Community Plan.
Regional District of Bulkley-Nechako. 2003. Omineca Settlement Corridor Official Community Plan.
Regional District of Fraser-Fort George. 2007. Crooked River-Parsnip Official Community Plan.
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Pipeline Crossings
54 Reference: Volume 3: Engineering, Construction and Operations Section 5.9 Pipeline Crossings (Page 5-6)
Preamble: Such a table would facilitate the review of risks associated with the proposed pipelines.
Request: Provide a table with all locations where the proposed pipelines are crossing existing pipelines.
Response: The number of pipelines listed in the Application (Volume 3, Section 5.9, Table 5-6) was derived from data provided by IHS Inc., an external oil and gas data provider. This information provides an order of magnitude for the number of pipeline crossings. Provision of the requested level of detail at this time would yield considerable unverified information because the pipeline route is not yet finalized. During detailed engineering all pipeline crossings will be identified and required crossing approvals obtained from existing pipeline operators.
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Soil
Soils Impact Assessment
55 Reference: TDR Soils, Section 2.3.6, p. 2-12
Preamble: Some specialized analyses are needed for trace elements
Request: Details are missing from the description of lab analysis of trace elements in surface organic horizons
Enbridge states (p. 2-12):
Surface organic samples (i.e., LFH or O horizon) from several sites were analyzed for calcium, magnesium, phosphorus, potassium, sodium and 16 trace elements (aluminum, arsenic, barium, cadmium, chromium, cobalt, copper, lead, manganese, mercury, molybdenum, nickel, selenium, thallium, vanadium and zinc). The analyses were for total elemental content, which involves acid digestion of samples and elemental measurement by ICP-AES.
Several elements (such as Hg and Se) often require separate specialized analyses. It is difficult to make a complete assessment of the trace element analysis because details are missing from the laboratory analysis. Without knowing the details of the analyses that were applied to these elements, these results should be treated with caution.
NRCan requests that Enbridge:
Provide complete details of laboratory analysis methods for elements, e.g. Hg and Se.
Response: The method reference for trace metal analysis is indicated in the laboratory Analytical Reports, which are located in the Application, (Volume 6A, Section 6A, Appendix E).
All trace elements (including mercury and selenium) were determined by the same method, namely the EPA 3050/6010 method as described in U.S. Environmental Protection Agency (1997).
Reference:
U.S. Environmental Protection Agency. 1997. Test Methods of Evaluation of Solid Waste, 3rd Ed, through Update III. Office Solid Waste Emergency Response, U.S. Environmental Protection Agency, Washington, D.C.
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Acid Deposition
56 Reference: TDR Soils, Section 2.10, p. 2-37 to 2-39
Preamble: The requested method of extraction is more accurate for forest soils
Request: RADEAA zone and acid deposition
NRCan requests that Enbridge:
Utilize a more appropriate method such as NH4CL to provide estimate of cation exchange capacity (CEC)
Response: The referenced section refers to determination of the sensitivity of soils in the RADEAA to acid deposition, and includes a rating system as well as a soil chemistry modelling approach to assess possible extent of acidification of soils in relation to atmospheric inputs of acidity. The rating system is described in the referenced section above, whereas details of the modelling approach are presented in the Application (Volume 6A, Section 6A, Appendix G).
A number of methods are available for the determination of cation exchange capacity (“CEC”) of soils, each having their advantages and disadvantages for different types of soils. The ammonium acetate method has been the most commonly used method historically for both agricultural and forest soils. The ammonium chloride (“NH4Cl”) method has some advantages for forest soils, but both methods have been applied in acidification sensitivity analysis.
CEC data were not obtained for the RADEAA by the NH4Cl method because both the soil sensitivity rating system and the modelling approach applied in the acidification assessment require data measured by the ammonium acetate method. These methods were originally developed using the large amount of ammonium acetate data available in numerous soil survey reports. There was considerably less NH4Cl data available for development of these assessment methods. The acidification sensitivity rating system was developed in the late 1980s using data from soil surveys in western Canada (Wiens, 1987; Holowaychuk and Fessenden, 1987). Hence, data by this method are also required for assessments of acidification sensitivity using this approach.
References:
Holowaychuk, N. and R.J. Fessenden. 1987. Soil Sensitivity to Acid Deposition and the Potential of Soil and Geology to Reduce the Acidity of Acidic Inputs. Alberta Research Council. Earth Sciences Report 87-1. Edmonton, AB.
Wiens, J. H. 1987. Sensitivity of Western and Northern Canada Soils and Geology to Acidic Input. Prepared for British Columbia Ministry of
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Northern Gateway Response to Federal Government IR No.1 Page 114 of 246 Environment and Parks, Technical Committee for the Long-Range Transport of Atmospheric Pollutants in Western and Northern Canada., Coordinating Committee on Soil and Geology Sensitivity Mapping (Canada). British Columbia Ministry of Environment and Parks, Victoria, BC.
As with the sensitivity rating system, the soil modelling approach uses CEC data acquired by the ammonium acetate method. The calculation of exchangeable base saturation percentage in the model is based on calculated loss of base cations due to incoming acidity. The reduced base saturation percentage is then calculated as the reduced exchangeable base cation content of the soil divided by the CEC measured by the ammonium acetate method. The soil pH is subsequently determined by an empirical correlation of pH with base saturation percentage. Similar to the situation with the soil sensitivity rating system, the data for developing this correlation were obtained from numerous soil survey reports that historically used the ammonium acetate method for CEC determination.
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Acid Deposition
57 Reference: Volume 6A, Section 6.5.2 (Assessment Methods for Nonagricultural Soils), p. 6-43 to 6-45.
Preamble: Atmospheric pollution includes S, NOX and particulate material and will be potentially of cumulative effect concern near the Kitimat terminal
Request: Discussion of potential of atmospheric emissions from marine traffic mentions only S - sulphur
NRCan requests that Enbridge:
Provide similar information and discussion for N - nitrogen deposition on vegetation of forested ecosystems in the terminal area
Response: Under current conditions (Base Case), the maximum annual deposition level of N is just over 1 kg/ha/a (see Application (Volume 6A, Appendix 8A, Table 8A-1)). This level is below the recommended critical load ranging from 5 to 30 kg/ha/a depending on the vegetation type (Volume 6A, Section 8.4.2.2, Table 8-10).
This maximum deposition occurs in an area covering approximately 1 km2 in the immediate vicinity of the marine loading facility. The maximum annual deposition level of N for the Application Case is 7 kg/ha/a, which is below the recommended critical load for salt marshes (20 kg/ha/a), temperate forests (10 kg/ha/a) and coastal habitats (10 kg/ha/a). There are no alpine/subalpine shrub habitats in the vicinity of the terminal.
The maximum annual deposition level of N for the Future Case (which includes the Kitimat LNG terminal) is 13.4 kg/ha/a, which is above the recommended critical load for coastal habitats (10 kg/ha/a) and temperate forests (10 kg/ha/a). This maximum deposition occurs in an area of less than 0.5 km2 in the immediate vicinity of the marine loading facility (i.e., within the Project development area). Depending on atmospheric conditions, surrounding vegetation of lodgepole pine, hemlock- fir and western hemlock vegetation types may be affected. The percentage of each vegetation class as well as total vegetation affected by N deposition in the REAA remains below 1%.
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Soil Mitigation Strategies
58 Reference: Vol. 6A, Section 6, Appendix 6A (Mitigation Strategies for Soil), p. 6-A1 to 6- A21
Preamble: Additional detail would provide more clarity whether mitigation strategies for the effects of soil disturbance for specific areas. Additional detail would also provide clarity on the assessment of potential risks for areas over time.
Request: A number of mitigative strategies are discussed, e.g. soil penetration tests, but details on techniques and subsequent monitoring are not detailed.
NRCan requests that Enbridge:
Provide a description of the tests including sampling and quantitative monitoring, tools utilized.
Response: Following approval of the Project, the exact location of the two pipelines will be finalized within the 1-km wide corridor during detailed engineering. Once the detailed pipeline route is finalized, detailed environmental alignment sheets will be developed. A separate set of alignment sheets will be developed for preparation of the pipeline RoW (i.e., clearing, grubbing) and another set for the trenching and construction of the pipeline. Within each set, the alignment sheets will identify the specific location (i.e., kilometer post start and finish) of environmental-sensitive or cultural-sensitive features and characteristics and detail the mitigation measures to be employed during construction in order to minimize Project effects. The requested details will be provided at that time. The construction alignment sheets will also be completed and provided to the NEB at least 60 days prior to the start of construction.
Once detailed engineering and final route selection have been completed, additional detail will be provided in the detailed Construction Environmental Protection and Management Plan (“EPMP”). The Construction EPMP will describe the approach and commitment by construction and Project personnel so that the Project is carried out in a manner that protects the environment during construction. It will outline the general and specific methods that will be applied for the Project and will be used as a guidance document for construction and Project personnel. The detailed Construction EPMP will document the requirements to be followed to ensure that the Project is constructed under applicable regulations, internal policies and procedures and will meet Project requirements. The detailed Construction EPMP will be completed and provided to the NEB at least 60 days prior to the start of clearing.
Qualified personnel will inspect the pipeline, pump station and Kitimat Terminal construction activities based on a documented inspection program to
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Northern Gateway Response to Federal Government IR No.1 Page 117 of 246 confirm that contractor operations comply with all the alignment sheets, environmental protection plans, other applicable specifications and government regulations. An inspection team will monitor contractor activities for conformance with the construction, safety and environmental contract specifications. Quality audits will be undertaken for work in accordance with the Project specifications.
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Terrain and Geological Hazards
Earthquake Hazards
59 Reference: Volume 7A Appendix A Contingency Plans and Environmental
Management Plans, Section A.3.23 Geology and Terrain Protection and Management Plan A. Subsection 3.23.2 Summary of Geohazards by Physiographic Region, page A116
Preamble: The statement: "The Coast Mountains Region is the only part of the RoW where appreciable seismic motion may occur" is not accurate. The Coast Mountains region is the area where appreciable seismic motions are most likely to occur. The Rocky Mountain region (including the fold and thrust belt) is another region (albeit less likely) where appreciable motions may occur. Note (as described in Volume 3, p. 27) the magnitude 5.5 earthquake that occurred near Prince George in 1986 and the magnitude 6 earthquake that occurred near Valemount in 1918.
Request: Enbridge states: "The Coast Mountains Region is the only part of the RoW where appreciable seismic motion may occur" Change the above statement to: The Coast Mountains Region is the part of the RoW where appreciable seismic motions are most likely to occur.
Response: As discussed in Northern Gateway’s response to Eco Justice IR 1.23B, Northern Gateway confirms that the Coast Mountain Region is the only region on the Project where “appreciable” seismic motions are most likely to occur. Although seismic motions may occur outside the Coast Mountain Region, Northern Gateway does not consider them to be “appreciable”.
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Earthquake Hazards
60 Reference: Geology and Terrain Technical Data Report, chapter 3 Results of Baseline Investigations, section 3.6 Coast Mountains, subsection 3.6.4 Geohazards PDA, 3.6.4.10 Seismicity, page 3-55
Preamble: The existing sentence is true but it should be mentioned that seismic hazards exists in other physiographic regions crossed by the proposed pipelines - notably in the fold and thrust belt of the eastern Cordillera.
Request: Enbridge states: "Seismic motion (shaking) is a potential geohazard in the Coast Mountains physiographic region between KP 1060.1 and KP 1172.2." Change the above statement to: "Seismic motion (shaking) is a potential geohazard along segments of the route, particularly in the Coast Mountains physiographic region between KP 1060.1 and KP 1172.2."
Response: As discussed in Northern Gateway’s response to Eco Justice IR 1.23B, Northern Gateway confirms that the Coast Mountain Region is the only region on the Project where potential geohazards due to seismic motions exist.
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Marine Environment Effects of Landslide-induced Tsunamis on Marine Transport
61 Reference: Volume 8B Environmental and Socio-Economic Assessment (ESA) - Marine Transportation Chapter 14 Effects of the Environment on Marine Transportation Section 14.3 Effects of Slope Stability on Marine Transportation page 14-2 and Section 14.5 Effects of Tsunamis on Marine Transportation Subsection 14.5.2 Landslide-Induced Tsunamis page 14-5
Multibeam sonar and bottom samples must be used to determine areas which indicate possibility of slope failure, particularly areas of cohesive sediment which have caused the previously reported tsunamis.
Preamble: It is important to understand where these landslide induced tsunamis could occur.
The work on landslide or submarine slide induced tsunami appears to be a desktop study reviewing slides that have happened. It will be important for the Proponent to identify areas of incipient instability using Multibeam sonar and bottom samples.
Request: Provide annotated multibeam maps of potential submarine instabilities.
Response: Please refer to Northern Gateway’s response to JRP IR 4.1.
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North Saskatchewan River Crossing
62 Reference: Update to Volume 3, Appendix G.2 Preliminary HDD Feasibility Assessments Enbridge Northern Gateway Project
Preamble: It is NRCan's understanding that HDD is feasible at that location.
Enbridge is proposing an open cut crossing. No rationale has been given as to why an HDD is not possible.
Request: Explain why no Stream Crossings Report was done for the North Saskatchewan River and explain why no (Horizontal Directional Drilling) HDD crossing under the North Saskatchewan River has been proposed, while such crossing is possible.
Response: Although horizontal directional drill (“HDD”) crossings have been completed on the North Saskatchewan River with smaller diameter pipelines, there have been HDD failures with large diameter pipeline crossings in the recent past. Conversely, the North Saskatchewan River was recently crossed near this location using open cut techniques with no significant adverse effects documented. Therefore, based on known risks and prior crossing experience, an open cut crossing method is proposed and an HDD feasibility assessment was not completed.
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Stream Crossings without Geohazards Assessment
63 Reference: Volume 3: Engineering, Construction and Operations Appendix E Supporting Geotechnical Reports Appendix C; Table B-1 Preliminary Summary of Geotechnical Conditions-Rev R; Geology and Terrain Technical Data Report - Terrain Atlas Surficial Geology Mapping
Preamble: For some stream crossings where geohazards may affect the proposed pipeline infrastructure, no hazard assessment was provided.
Request: Explain why no terrain hazards and risks were assessed for: KP 41.6 Stream Crossing of Little Egg Creek (Table C-1 Page 3) KP 64 Stream Crossing of Riviere Qui Barre (Table C-1 Page 3) KP 137.9-138.9 Stream Crossing of Paddle River (Table C-1 Page 3) KP 181.5 Stream Crossing of Mink Creek (Table C-1 Page 3) KP 272-275 Stream Crossings of Tributaries to Iosegun Lake (Table C-1 Page 4) KP 377 Stream Crossing of Karr Creek (Table C-1 Page 6) KP 385 Stream Crossing (Table C-1 Page 6) KP 400.3 Stream Crossing of tributary to Smoky River (Table C-1 Page 6) KP 517.9 Stream Crossing of Hiding Creek (Table C-1 Page 7) KP 530-535 Stream Crossing of South Redwillow River (Table C-1 Page 7) KP 561-566 Stream Crossings of Kinuseo Creek and Honeymoon Creek (Table C-1 Page 7) KP 702-704 Stream Crossing of Chuchinka River/Creek (Table C-1 Page 9) KP 751.1 Stream Crossing of Mossvale Creek (Table C-1 Page 10) KP 780 Stream Crossing of Tributary to Great Beaver Lake (Table C-1 Page 10) KP 816-819 Stream Crossing of Necoslie River (Table C-1 Page 10) KP 856.2 Stream Crossing of Sutherland River (Table C-1 Page 10) KP 863.9 Stream Crossing of Tributary to Duncan Creek (Table C-1 Page 10) KP 864.6 Stream Crossing of Tributary to Duncan Creek (Table C-1 Page 10) KP 919 Stearns Creek (Table C-1 Page 10) KP 941.45 Stream Crossing of Gerow Creek (Table C-1 Page 10) KP 948-949 Stream Crossing of Maxan Creek (Table C-1 Page 10) KP 960-967 Stream Crossing of Foxy Creek (Table C-1 Page 10) KP 986.7 Stream Crossing of Buck Creek (Table C-1 Page 10) KP 993.1 Stream Crossing of Parrott Creek (Table C-1 Page 10) KP 1002.5 Stream Crossing of Owen Creek (Table C-1 Page 10) KP 1007.3-1007.6 Tributary to Fenton Creek (Table C-1 Page 10) KP 1007.7-1008.1 Fenton Creek (Table C-1 Page 10) KP 1010.1 Tributary to Morice River (Table C-1 Page 10) KP 1013.2-1014.1 24.5 Mile Creek (Table C-1 Page 10) KP 1037.4-1038.6 Morice River (Table C-1 Page 11) KP 1066.1-1067.3 Tributary to Burnie River (Table C-1 Page 11) KP 1140 Deception Creek (Table C-1 Page 11)
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Response: The following discussion summarizes terrain conditions at the various locations requested. In most cases no terrain geohazards were identified, as described in the Application (Volume 3, Appendix E-1, Appendix B, Table B-1and Appendix C, Table C-1). In general, the stream crossings will be designed during detailed engineering. The design will include consideration of scour and lateral erosion. In a few cases lateral erosion was included as a geohazard in Table C-1 where unusually large amounts of lateral erosion could occur. In most cases; however, lateral erosion is a typical design condition and was not included as a geohazard.
KP 41.6 Stream Crossing of Little Egg Creek (Table C-1) From Table B-1: “KP 41.6: Little Egg Creek. Narrow irrigation canal or canalized stream acting as a drainage ditch. Covered with weeds, bottom not visible from air. Other apparently similar canalized streams/drainage ditches exist in the area.” No geohazards were identified.
KP 64 Stream Crossing of Riviere Qui Barre (Table C-1) From Table B-1: “Meandering stream with several cut-off and oxbow channels.” “Sagbend locations will need to consider meandering channel, oxbows and the potential for future lateral erosion.” No geohazards were identified.
KP 137.9-138.9 Stream Crossing of Paddle River (Table C-1) From Table B-1: “There was a beaver pond in the river upstream of the existing crossing. Very low approach slope on east. West slope is approx. 20 m high and steep. No problems with stability identified from air; however, extremely high plastic clays occur in the valley which may be prone to slides.” “Extensive high plastic glaciolacustrine clay deposits underlying approach slopes. Some of these deposits are jointed and slickensided, perhaps as a result of melting of ice blocks soon after deposition. Geotechnical field review of stability of approach slopes recommended. Lateral erosion considerations with respect to approach slope stability and sagbend locations should also be considered. Ground and surface water control will be required. Potential for long term meander cut-offs upstream and downstream. Lateral erosion needs to be considered. Bank may be locally armoured at Alliance.” No geohazards were identified. If further work identifies geohazards, the crossing will be included in Table C-1.
KP 181.5 Stream Crossing of Mink Creek (Table C-1) Small incised stream. No geohazards were identified.
KP 272-275 Stream Crossings of Tributaries to Iosegun Lake (Table C-1) From Table B-1: “KP 274.4 and KP 275.0: Tributaries to Iosegun Lake. Small streams, near flat ground. Preliminary indication from drilling investigations is that local deposits consist of glaciolacustrine clay over clay till. There was a harder zone that may be ice rafted bedrock.” No geohazards were identified.
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KP 377 Stream Crossing of Karr Creek (Table C-1) Small creek in gently sloping valley. No geohazards were identified.
KP 385 Stream Crossing (Table C-1) Small slightly incised stream. No geohazards were identified. Local crossing location may need to be adjusted slightly within Project Development Area due to slightly meandering creek.
KP 400.3 Stream Crossing of tributary to Smoky River (Table C-1) Level ground. No stream found at this location.
KP 517.9 Stream Crossing of Hiding Creek (Table C-1) From Table B-1: “Hiding Creek (KP 517.9) has an extensive area of muskeg in the valley estimated visually to be at least 1.5 m deep.” No geohazards were identified. The muskeg depths will be further investigated and the stream crossing designed during detailed engineering.
KP 530-535 Stream Crossing of South Redwillow River (Table C-1) From Table B-1: “Confined and straight channel upstream, meander downstream. Crossing in tight area. Rock on east side. [Rock] Might also occur on west side but not seen. Narrow valley with limited work room. The river is misfit in an old glaciofluvial meltwater channel.” “Open Cut Crossing: Appears feasible from a geotechnical point-of-view. Lateral erosion conditions also need to be considered. Isolation appears possible under winter conditions.” To the west of the crossing at KP 531.9, there is an area of muskeg. No geohazards were identified.
KP 561-566 Stream Crossings of Kinuseo Creek and Honeymoon Creek (Table C-1) From Table B-1: “Gently sloping to the north and west with several creek crossings including: KP 561.5: Kinuseo Creek; KP 564.9: Honeymoon Creek; KP 566.0: Kinuseo Creek; Wet soil conditions may occur at some of the creek crossings.”
“Some of the creek crossings will require grading of the banks and/or riprap or other measures for bank restoration. There may be some areas of wet soil or muskeg.” Some of the streams are meandering and will require appropriate setback of the sagbends during detailed design but this is considered a standard part of stream crossing design during detailed engineering. No geohazards were identified.
KP 702-704 Stream Crossing of Chuchinka River/Creek (Table C-1) Chuchinka Creek is a small creek within a larger valley. Tributary creeks are slightly incised.
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Northern Gateway Response to Federal Government IR No.1 Page 125 of 246 From Table B-1: “Route runs across hummocky to knobby terrain with intervening valleys. Frequent rock drumlins and drumlins. Grain of land runs across route indicating that appreciable grading will be required. Local observation suggests wet surficial deposits in low areas consisting of glaciolacustrine silt and clay with sand interbeds.” “Difficult terrain conditions in low lying areas. Shallow groundwater and ponded surface water. Muskeg and glaciolacustrine silts and clays with sand seams. There have been cut stability concerns along the local logging roads. Trench and cut stability may be a problem. Geotechnical ground review recommended. Ground and surface water control required. Cross berms and possibly erosion matting, mulching or other measures may be required.
KP 703.05: Chuchinka Creek crossing. No geohazards were identified that would be of concern with respect to the pipeline system. The erosion and sedimentation conditions may require mitigation measures as noted.
KP 751.1 Stream Crossing of Mossvale Creek (Table C-1) Very small creek slightly incised. No geohazards were identified.
KP 780 Stream Crossing of Tributary to Great Beaver Lake (Table C-1) From Table B-1: “KP 780.3 Tributary to Great Beaver Creek: Grading of steep approach slopes will be required. Surface and ground water control required.” No geohazards were identified.
KP 816-819 Stream Crossing of Necoslie River (Table C-1) From Table B-1: “Meandering river incised relative to terrain on both sides. Forested areas on both sides of crossing. River occupies the eastern part of a very wide glaciofluvial channel. Local observation suggests a possibility of high plasticity glaciolacustrine deposits (correlated with the Stuart Lake deposits) overlying sand and gravel at depth. Aerial review suggests local sliding as a result of banks and slopes being undercut by meandering stream. Significant grading would likely be required for a trenched crossing in order to put the pipeline in stable soil under the slides. Further field examination required.” “Ground and surface water control. Trench blocks may be required in some areas to prevent migration of shallow groundwater along trench.”
No geohazards were identified during the preliminary work. This will be reviewed during further detailed work.
KP 856.2 Stream Crossing of Sutherland River (Table C-1) Slightly meandering slightly incised stream. No geohazards were identified.
KP 863.9 Stream Crossing of Tributary to Duncan Creek (Table C-1) There is no identifiable stream at KP 863.9. There is a small slightly incised stream at KP 863.4. No geohazards were identified.
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KP 864.6 Stream Crossing of Tributary to Duncan Creek (Table C-1) The only feature identified at the specified location is an extremely small stream barely visible on available imagery. From Table 11C-1 in the Application (Volume 6A, the stream is classified as having no visible channel. No geohazards were identified.
KP 919 Stearns Creek (Table C-1) Small slightly incised creek. No geohazards were identified.
KP 941.45 Stream Crossing of Gerow Creek (Table C-1) From Table B-1: “KP 941.45: Gerow Creek: Probable glaciofluvial channel with sediments, although not mapped as such [on published mapping].” Wide gently sloped valley. No geohazards were identified.
KP 948-949 Stream Crossing of Maxan Creek (Table C-1) From Table B-1: “Long gentle to moderate approach slope on east side. The stream valley bottom is about 250 m wide. East of the creek, conditions in the spruce cover appeared to be wet. The conditions at the creek channel itself may be a bit drier and the terrain on the west side is also drier. Creek channel appeared to be deep, about 5 to 10 m wide with a few beaver dams. Flowing very slowly. Gravel bars on the west side, meandering. Very gentle approach slope on west side with heavy forest cover.” “There are some areas of rilling on the east approach slope that should be avoided or mitigated. No stability problems identified from aerial reconnaissance on either approach slope. Sagbend locations will need to consider the width of the meander band (perhaps 150 to 175 m) and the potential for lateral erosion (appeared to be low). Ground and surface water control on long east approach slope.” No significant geohazards were identified.
KP 960-967 Stream Crossing of Foxy Creek (Table C-1) From Table B-1: “Foxy Creek – KP 960.4 Creek flows toward the east in a valley with approach slopes sloping approximately 15°. The slope on the south side is part of a rounded ridge. The slope on the north side is approximately 40 m high.” “An area of known ARD issues exists at Equity Silver Mine. No rock formations similar to those that are acid generating at Equity have been identified along the route during ground reconnaissance work to date.
Ground and surface water control on slopes.”
KP 960.75 to KP 964.35: “Upland area north of Foxy Creek, rolling to gently sloped terrain with occasional steep areas on upper parts of ridges. Local pockets of muskeg.” “Local pockets of muskeg. Areas of rock outcrop on ridges and possibly a few creek crossings. Ground and surface water control on
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KP 964.35 to KP 975.65: “Upland terrain with two crossings of Foxy Creek.
KP 964.55 Crossing of Foxy Creek
KP 966.95 Crossing of Foxy Creek” The area has been examined on the ground and from the air. Slide areas at other locations along Foxy Creek have been avoided. No geohazards were identified at the crossing.
KP 986.7 Stream Crossing of Buck Creek (Table C-1) From Table B-1: “Buck Creek – KP 986.7 East approach slope is gentle, with moderate slopes farther east. No stability problems noted. There is a road partway up the west slope which is terraced with variable slopes that are locally moderate to steep. The stream is meandering with lateral erosion of the meanders evident. There were several oxbows along the valley bottom near and west of the crossing. The valley bottom is wet with muskeg. The wet ground with numerous oxbow ponds extends up to a logging road on the toe of the west valley slope. There is dead standing timber either from a fire (most likely) or from an increase in water elevation. There were a few beaver dams, but no appreciable ponds. The bottom is cobbles with a few boulders. There was a lot of flaggy rock along the bottom and the bottom of the stream channel may be close to bedrock. The west approach slope is gentle to moderate.” “Locations of sagbends should consider ongoing lateral erosion of stream. A long crossing over most of the width of the valley bottom may be required.
Geotechnical ground reconnaissance recommended.
Ground and surface water control required on slopes. Trench blocks will likely need drains.” No significant geohazards were identified.
KP 993.1 Stream Crossing of Parrott Creek (Table C-1) From Table B-1: “KP 993.2: Parrott Creek crossing. Meandering creek with gentle to moderate sideslopes. Ground and surface water control required on slopes.”
Spreading failures have been identified elsewhere along Parrott Creek but these areas were avoided during routing. No significant geohazards were identified at the crossing.
KP 1002.5 Stream Crossing of Owen Creek (Table C-1) From Table B-1: “Owen Creek – KP 1002.5 Slightly meandering creek slightly misfit on a flat valley bottom with moderately steep approach slopes to east and west. Spawning channels
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Northern Gateway Response to Federal Government IR No.1 Page 128 of 246 downstream near Morice River.” “Detailed ground reconnaissance work may suggest minor changes in alignment. Approach slopes may require local pull back. Ground and surface water control including trench blocks and likely drains will be required.”
No geohazards were identified.
KP 1007.3-1007.6 Tributary to Fenton Creek (Table C-1) From Table B-1: “Tributary to Fenton Creek and Fenton Creek KP 1007.5 and KP 1007.9 Steep slopes on both streams.” “Ground reconnaissance recommended. Slopes may need to be pulled back to shallower angles. Shoofly around area including existing forestry roads will be required for access. Ground and surface water control including trench blocks and drains.” Further work will be carried out during detailed engineering. No significant geohazards were identified.
KP 1007.7-1008.1 Fenton Creek (Table C-1) See above. No significant geohazards were identified.
KP 1010.1 Tributary to Morice River (Table C-1)
KP 1010.1 Tributary to Morice River. From Table B-1: “Slopes will likely need to be pulled back to shallower angles. Ground and surface water control including trench blocks and drains.” No geohazards were identified.
KP 1013.2-1014.1 24.5 Mile Creek (Table C-1) From Table B-1: “24.5 Mile Creek KP 1013.5 Crossing of creek and tributary to west.”
“Minor adjustment of route may be required, in particular on east side where route at present appears to sidehill into the creek. Ground reconnaissance recommended. Slopes will likely need to be pulled back. Shoofly around area including existing forestry roads will be required for access. Ground and surface water control including trench blocks and drains.” No significant geohazards were identified.
KP 1037.4-1038.6 Morice River (Table C-1) From Table B-1: “Morice River KP 1038.0 Moderate slope on south side of river has variable slopes and a terrace near the toe. Areas of rock outcrop high on the slope but no outcrop found lower on slope. River is relatively stable and does not appear subject to appreciable lateral erosion. Route is parallel to existing logging road bridge.”
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No geohazards were identified.
KP 1066.1-1067.3 Tributary to Burnie River (Table C-1) Terrain geohazards and risks were assessed in the cited reference.
KP 1140 Deception Creek (Table C-1) From Table B-1: “KP 1140.0 Deception Creek: Area is wet on north side of crossing. Consider diverting a short distance to the east to improve conditions. A hole drilled by AMEC at about KP 1140.0 on the east side of Iron Mountain near Deception Creek (R02) did not encounter sensitive glaciomarine clay, although stiff to hard high plastic clay was encountered below sand deposits from 44 m to the bottom of the hole at 66.5 m.”
No significant geohazards were identified. Further work during detailed engineering is anticipated including further work on the glaciomarine clays in the area.
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Geohazards – gullies
64 Reference: Volume 3: Engineering, Construction and Operations Appendix E Supporting Geotechnical Reports E-1 Overall Geotechnical Report on the Pipeline Route Rev. R for the Enbridge Northern Gateway Project, Bruderheim, Alberta to Kitimat, BC Appendix C
Preamble: If deep incised gullies are crossed, there may be a potential for erosion and landslides that could affect the proposed pipelines.
Request: Explain the absence of a risk assessment for the deep incised gullies crossed at KP 408, KP 408.2, KP 409, KP 411.5, KP 412.3, KP 414.9, and KP 417.7.
Response: The noted features are stream channels that range from slightly incised to somewhat more incised. The kilometre points listed are Rev R. The channels are tributaries to the Smoky River that is located to the west in a deep valley. At the location under discussion, the Northern Gateway pipelines will parallel other pipeline RoW and a road to the west. All of the features noted above have been assessed on the ground and from the air. No geohazards with significant potential impacts were identified at the channels listed above.
During detailed engineering, the potential for downcutting erosion will be considered through this area in view of the steeper gradients to the west in the tributaries where they flow into the Smoky River valley. Detailed routing will also consider local topography and the proximity of nearby pipeline RoW with respect to the potential for erosion.
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Geohazards - Smoky River
65 Reference: Volume 3: Engineering, Construction and Operations Appendix E Supporting Geotechnical Reports E-1 Overall Geotechnical Report on the Pipeline Route Rev. R for the Enbridge Northern Gateway Project, Bruderheim, Alberta to Kitimat, BC Appendix C
Preamble: NRCan did not find the proposed mitigation measures in preliminary design for geohazards at this location.
Request: Enbridge Northern Gateway Project, Bruderheim, Alberta to Kitimat, BC Appendix C Explain what some of the preliminary design measures will be to minimize the effects of geohazards on the pipelines in the Smoky River area between KP 419 and KP 424.
Response: Information on the Smoky River crossing and nearby area including preliminary mitigation measures is contained in the following items filed as part of the Application:
1) Detailed discussion of geotechnical aspects of the area is contained in the Application (Volume 3, Appendix E-1, Appendix B, Table B-1). This includes stability, routing considerations, and preliminary mitigative measures.
2) Assessment of Hazards, Consequences and Risks with respect to the pipeline are shown in the Application (Volume 3, Appendix E-1, Appendix C Table C-1). Mitigative measures are indicated.
For both of the above references, the discussion includes the east approach slope, the floodplain and terrace areas and the west approach slope.
3) General discussion of the various mitigative measures appears in the Application, (Volume 3, Section 5, Appendix E-1).
4) Additional information including preliminary assessment of a directionally drilled crossing, photos of the approach slopes showing routing considerations to avoid slides and other aspects are contained in Preliminary Geotechnical HDD Feasibility Assessment Smoky River (Crossing #3174), Report 03, (see Application, (Volume 3, Appendix G.2).
The following points briefly summarize preliminary mitigative measures across the river valley:
1. General: The Smoky River valley has widespread deep-seated sliding on one or both sides over long distances. Considerable effort has been expended locating a crossing where it was possible to avoid most of the
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Northern Gateway Response to Federal Government IR No.1 Page 132 of 246 deep-seated slide problems. As a result, various potential routes were investigated over a long portion of river valley. The Application, (Volume 3, Section 2.4.7 and Appendix D, Figure D-7) indicates some of the routes that were considered across the Smoky River; however, considerably more locations were evaluated from a geotechnical point of view with the aim of avoiding major slide areas as much as possible.
2. East approach slope: The route parallels existing pipelines located to the north. No major stability concerns were identified along the proposed route although there are slides farther north and south along the valley. Preliminary mitigative measures include:
• Local grading of terrace fronts to lower angles will likely be necessary to facilitate construction. • Further investigation of slopes by drilling and possibly including monitoring. • Ground and surface water control including trench blocks, drains (particularly near crest of slope) and cross berms. Surface water drainage will need to be coordinated with existing RoW.
3. Floodplain, terraces and river crossing: The Smoky River is eroding to both the east and west at and near the crossing. Erosion is constrained to some degree by the road bridge approach fills approximately 1.2 km upstream of the crossing. Failure of these fills would allow much greater lateral erosion than at present. In the past, the river has eroded laterally over relatively large distances both to the east and west.
The preferred crossing method is a directional drill. The crossing (whether by directional drilling or other means) would need to be relatively long to avoid the substantial lateral erosion that has occurred in the past and which will likely continue to occur in the future. Detailed investigation of the subsurface geology in connection with the directional drill assessment and design will be required. Investigative drilling and geophysics are anticipated.
4. West approach slope: The route approximately parallels the north side of an existing pipeline RoW. The slope is about 70 m high at an overall angle of 9.5o. The route is just beyond the apparent north edge of a large deep-seated slide to the south. One very small crack 10 mm wide was found on the south side of the adjacent RoW. At the toe of the slope there is abundant seepage, but no sign of a toe thrust. Trees along the existing RoW are straight. There is another small slide north of the route on the side of a ridge. Preliminary mitigative measures include the following:
• Deviation from the centerline of the Project Development Area (PDA) to the south at the edge of the floodplain and to the north on the main
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Geohazards - Missinka River
66 Reference: Volume 3: Engineering, Construction and Operations Appendix E Supporting Geotechnical Reports E-1 Overall Geotechnical Report on the Pipeline Route Rev. R for the Enbridge Northern Gateway Project, Bruderheim, Alberta to Kitimat, BC Appendix C
Preamble: Error correction required.
Request: In Enbridge's Table C-1 (pg 8) in the row reported, "Tributaries to Missinka River KP 632.0 - 636.8 69DF Mitigated Risk" Enbridge states, "Hazard Likelihood 2 Consequence Rating 1 Risk 4". NRCan notes the calculation is in error, please correct the numbers.
Response: The correct values in the table should be Likelihood 2 Consequence Rating 1 Risk 2.
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Wetlands
Baseline information regarding the extent and conservation status of wetlands
67 Reference:
Preamble: Environment Canada has requested the above mentioned information as part of the environmental assessment stage to ensure that wetlands of higher conservation priority and areas of higher wetland concentration are identified and that impacts to these areas are sufficiently addressed.
Avoidance of these key areas is Environment Canada's first best recommended approach to mitigation, both with respect to potential impacts from construction and routine operations, as well as ecological consequences from accidental spills. We recommend that this requested information be presented as part of the environmental assessment stage rather than after (as proposed by the proponent), and prior to determination of the final pipeline route.
Environment Canada notes that in point 7.3(i) of the October 2010 Response, the proponent indicated "once the centerline is finalized, the ecological community types will be identified according to the Conservation Data Centre and priority ranking according to British Columbia Conservation Framework for each affected wetland". Furthermore, the proponent indicated that maps showing affected wetlands and associated riparian habitats would also be provided once the centerline is finalized.
From the perspective of assuring that impacts to high priority wetlands are avoided, Environment Canada advises that it is not useful to address the aforementioned information requests subsequent to finalization of the pipeline route, as rerouting opportunities at that point are likely to be minimal. For clarity, Environment Canada does not anticipate that these revision requests would require additional field data collection; information in the second bullet could be provided based on terrestrial ecosystem mapping.
Request: Provide the following:
A table that lists the identifier, location, size, class, site association and the corresponding ecological community types (tracked by Conservation Data Centre). For each wetland in British Columbia, include the British Columbia Conservation Framework priority ranking. A map of the location of all identified wetlands, with a reasonable representation of the size of each wetland overlaid with the current pipelines and route and expected placement of auxiliary facilities.
Response: The requested map atlas, showing the location of all identified wetlands with a reasonable representation of the size of each wetland overlaid with the current
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Quality of baseline information related to the extent and conservation status of wetlands
68 Reference:
Preamble: Environment Canada is not able to assess the quality of the wetland baseline information for British Columbia (based on terrestrial ecosystem mapping) provided in the Assessment Report. While the Assessment Report indicates that, "A Survey Intensity Level 5 was chosen, which prescribes that 5% to 14% of polygons should be sampled to verify the map accuracy" (Assessment Report, Volume 6A, Section 8, page 8-25), the Assessment Report does not indicate the percentage of polygons that were actually sampled, nor does it provide an indication of the extent of wetland community polygons that were sampled. Furthermore, in respect to all vegetation community types, there is no indication in the Assessment Report of whether polygons sampled demonstrated robustness or deficiencies in the terrestrial ecosystem mapping results, and/or how the terrestrial ecosystem mapping was refined to account for any identified deficiencies. As such, Environment Canada is unable to assess the quality of the mapping upon which wetland and vegetation significance determinations have been made. It should be noted that the quality of the terrestrial ecosystem mapping is of particular importance as it forms the basis for many of the habitat models used for Key Indicator species (including SARA-listed species) in Section 9 of Volume 6A of the Assessment Report. Environment Canada continues to recommend that this information be provided for review as part of the Assessment Report. Request: Provide the following:
A map of the location of each wetland for which polygons were sampled. An indication of how many wetlands were sampled versus the total number of wetlands in both the Project Development Area and the Project Environmental Assessment Area. Details regarding the methods used to classify, map and ground- truth ecosystem units (a sufficient level of detail regarding methodologies is currently lacking from Volume 6A, Section 8.4.2).
Response: The requested map will be included in the map atlas, which is being prepared in response to Federal Government IR 67. The number of plots sampled in wetlands versus the total number of wetlands in the Project Development Area (“PDA”) and the Project Effects Assessment Area (“PEAA”) will also be provided at that time.
The Technical Data Report, Vegetation (“TDR”) (Section 2) expands on the information in the ESA and includes a more detailed description of the methods including protocols, existing data sources, and vegetation classification. Section 2.3 covers vegetation classification; Sections 2.3.1 and 2.3.3 discuss mapping; and Section 2.3.2 is field surveys.
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Baseline information regarding wetland functions
69 Reference:
Preamble: The October 2010 Response regarding wetland functions indicates that, "an assessment of wetland functions likely to be adversely affected by the Project has been provided in Volume 6A Part 1: Table 8-6 and 8-7". The tables referenced are labelled 8-6 Project Design Measures to Reduce Potential Effects on Vegetation and Table 8-7 Best Management Practices to Reduce Potential Effects on Vegetation; these tables provide a summary of mitigation measures and best management practices, not an assessment of wetland functions. Wetland functions are infrequently referenced within Volume 6A, Section 8 of the Assessment Report and the Vegetation Technical Data Report3.
For clarity, wetland ecological functions refer to the natural processes (physical, chemical, biological) that are associated with wetlands.
Broadly, these fall into four categories:
• Hydrology, e.g. o Aquifer recharge and discharge o Surface water storage and release o Flow moderation • Biochemical cycling, e.g. o Nutrient transformations o Biomass production o Soil production • Habitat, e.g. o Biological productivity and diversity • Climate, e.g. o Carbon fixation and CO2 o Methane equilibrium o Rainfall and humidity increases o Micro-climatic influences
To help ensure that an adequate wetland function assessment is completed using appropriate techniques, Environment Canada recommends that the proponent consult the following document accessible at: http://wetkit.net/docs/WA_TechReport497_en.pdf :
Hanson, A., L. Swanson, D., Ewing, G, Grabas, S., Meyer, L, Ross, M., Watmough, and J. Kirkby. 2008. Wetlands Ecological Functions Assessment: An Overview of Approaches. Canadian Wildlife Service Technical report Series No. 497. Atlantic Region.
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Northern Gateway Response to Federal Government IR No.1 Page 139 of 246 Environment Canada continues to recommend that a detailed assessment of wetland functions likely to be adversely impacted by the project be completed as part of the environmental assessment. Alternatively, and with the support of appropriate rationale, Environment Canada recommends that a framework for the wetland functions assessment be developed and submitted for review as part of the environmental assessment. At a minimum, such a framework should include a description of the functions assessment methodology to be used; a concise justification of its applicability to the project; data reporting; and, an example baseline data collection form.
______3 References to wetland functions in Volume 6A, Section 8 (Vegetation) of the Assessment Report and the Vegetation Technical Data Report are made in the following statements: o on pages 8-107, 8-108, and 8-125: “Following application of the mitigation measures, the wetland functions will be restored” and, o on page 8-9 (in a bullet on ‘potential effects to vegetation diversity’): “changes in ecosystem functions (e.g., changes to water flow in wetlands)”.
Request: Provide the following:
A detailed assessment of wetland functions likely to be adversely impacted by the project.
Response: Based on a meeting with Environment Canada on August 9, 2011, Northern Gateway committed to provide a draft Framework document that will describe wetlands in greater detail including: wetland function, assessment, mitigation, monitoring and compensation. The draft Framework is under preparation and will be reviewed with Environment Canada. Following input from Environment Canada, the document will be finalized and made available to the Joint Review Panel.
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Assessment of impacts from construction and routine operations and associated mitigation
70 Reference: According to Volume 6A, Section 8 of the Assessment Report, in total, there are approximately 482 ha of wetlands along the extent of Project Development Area. The primary mitigation measure identified within the Assessment Report is avoidance; however every avoidance statement is coupled with caveat statement such as 'where feasible' or 'where possible'. Section 8 of Volume 7A of the Assessment Report identifies general mitigation measures for use where avoidance cannot be achieved; these mitigation measures are again coupled with the caveat statement 'where practical' (page 8-29). The caveat statements within the Assessment Report and point 7.3(vi) on page 23 of the proponent's October 2010 Response do not provide confidence regarding the level of mitigation that is expected to be achieved. We continue to stand by our original information request; however, if it is determined that providing specific impact and mitigation information pertaining to areas where the 25 m right of way, permanent and temporary access roads and other elements of the Project Development Area would interact with wetlands subsequent to the environmental assessment stage is not appropriate to the project, Environment Canada has identified an alternative approach for addressing this concern below.
Should it be determined that providing detailed information regarding site- specific impacts and mitigation measures is not appropriate for most (i.e. perhaps there may be information available for some important wetland areas) or all sites at the environmental assessment stage, an alternative approach would be to, as part of the Assessment Report, provide a mitigation framework, coupled with examples of worst case scenarios where access roads and the pipelines would cross wetland features; and, either a firm commitment that pump stations, construction camps, laydown areas and other project components will not be situated within 100m of wetlands, or additional examples of worst case scenarios of these components being established within wetland areas. The framework and scenarios would act to build an agreed upon wetland functions and mitigation approach from which detailed, site-specific, project mitigation would be expected to follow as a minimum, once the detailed route has been established. The framework and scenarios would provide assurance that impacts to wetlands would be appropriately addressed should the project proceed.
Preamble: As part of this alternative approach, Environment Canada recommends that:
• A mitigation framework be developed regarding impacts to wetlands and associated riparian areas. This framework would expand upon the current list of mitigation measures outlined in Volume 6A, Section 8 and the Construction and Environmental Management Plan and outline what further steps would be taken to minimize impacts where it is
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Northern Gateway Response to Federal Government IR No.1 Page 141 of 246 deemed not possible or feasible to apply identified mitigation measures.
• At least five different site-specific example 'worst-case' scenarios of construction and operations of the pipeline and temporary access roads within ecologically important wetlands along the right of way (i.e. wetlands to which the Wetland Policy goal of no net loss applies). Examples should speak to the breadth of construction techniques that would potentially be used to cross wetlands, the different types of wetlands (fen, bog, treed swamp, marsh, open water, etc.) that could be impacted, as well as the variety of conditions that would be encountered during different times of the year (e.g. wet versus dry versus frozen ground).
• A firm commitment that pump stations, construction camps, laydown areas and other project components will not be situated within 100m of wetlands, or additional examples of worst case scenarios of each of these components being established within wetland areas.
• For each example, a list of construction and ongoing maintenance activities, as well as timing. Diagrams would be useful for descriptive purposes.
• A summary of the potential worst case effects on hydrological, biochemical cycling, habitat and climate functions of the wetland; this should include examples of where SARA-listed amphibians as well as migratory birds (wintering, foraging, nesting) are present within the wetland and associated riparian area.
• A detailed list of mitigation measures that would be used during construction and operation to minimize impacts to the wetlands and how and where they would be applied. Diagrams would be useful for descriptive purposes.
Request: Provide the following:
• Identification of specific wetlands and associated riparian areas that would be directly impacted by the project and the location and type of mitigation to be applied. • Right of way information, including any regular or ongoing scheduled clearing of vegetation, and the effect this may have on wetland function. Special reference should be given to the White Area.
Response: Please see Northern Gateway’s response to Federal Government IR 1.67.
Once the pipeline centerline is finalized, detailed environmental alignment sheets will be developed. These detailed alignment sheets will show the
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Northern Gateway Response to Federal Government IR No.1 Page 142 of 246 location of all wetlands crossed and site specific mitigative measures to be employed during construction in order to minimize Project effects.
Construction of a pipeline in a wetland bog or fen involves the following general steps (Attachment 1 Federal Government IR 70):
• the vegetation will be cleared over the ditch line and the organic layer will be excavated and placed within the spoil side of the RoW, • the pipelines will be lowered into the ground with swamp weights or other buoyancy control methods utilized where required, • the organic layer will be back filled • natural recovery will be the reclamation plan
Construction of a pipeline in swamp, marsh or riparian areas involves the following steps (Attachment 2 Federal Government IR 1.70):
• the vegetation will be cleared over working and spoil sides • the topsoil will be excavated from the working lane and placed on the spoil side, • the deeper mineral soil will be excavated and placed in a separate pile on the spoil side • the pipelines will be lowered into the ground with swamp weights or other buoyancy control methods utilized where required, • the soil layer will be back filled with the mineral soil, followed by the top soil. • reclamation will be by natural recovery with planting of native species in riparian areas.
The mitigation measures for wetlands and riparian areas are discussed in the Application (Volume 6A, Section 8.3 and Section 8.4.3.3). In addition, the Application (Volume 7A) discussed mitigative measures for wetlands in Section 8.6.3 (Vegetation Protective Measures), 9.1 (Protective Measures for Pipeline Construction – Trenching), 9.1.1 (Trench Water Management), A. 3.5.7 (Subsurface Drainage Control) and A.3.2.4.1 (Regulatory Requirements Specific to Resource).
Riparian areas mitigative measures are discussed in the Application (Volume 7A, Section 8.5.6, 10.5 and A.3.15).
The mitigative measures in the Application (Volume 6A and 7A) were reviewed and found to be similar to the suggested mitigation (Appendix E) in Hanson et al. (2008) (see Northern Gateway’s response to Federal Government IR 1.69).
Clearing of the pipeline RoW and preparation for pipeline construction will not begin until the alignment sheets have been completed. Clearing will proceed in
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Northern Gateway Response to Federal Government IR No.1 Page 143 of 246 spreads during the approved timing windows determined by government agencies such as Canadian Wildlife Service (to minimize effects on migratory birds) and Fisheries and Oceans Canada. Within the RoW of bogs and fens, the area cleared will be limited to the ditch line. Additional information is available in the Application (Volume 6A Section 8.4.3.2 and Section 2.2.3.
Generally, the wetland functions, hydrology, biochemical cycling, habitat and climate will not be affected because of the mitigation measures which are found in the Application (Volume 7A), as mentioned above. Wetlands will be accessed during frozen conditions for winter construction spreads; hence disturbance to habitat will be limited. The soil containing a resource of seeds and root crowns will be salvaged and then rolled back onto the pipeline RoW. Over time, the wetland habitat will return by vegetation succession. Similarly, carbon sequestration will continue with natural regeneration.
There are a minor number of wetlands in the white area of Alberta made up of shallow open water surrounded by cultivated fields that will be crossed by the Project. The alignment sheets will provide detailed location and site specific mitigative measures for these wetlands. Within the white area of Alberta, the Alberta Wetland Policy will be met.
During operations, any ongoing clearing of vegetation would be limited to ensuring pipeline integrity.
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Monitoring and follow-up
71 Reference:
Preamble: Environment Canada notes that in point 7.5 of their October 2010 Response, the proponent committed to finalizing a wetland and riparian follow-up and monitoring plan once the detailed pipeline design is complete and the centerline is known. Furthermore, the proponent indicated that a habitat compensation plan could be developed once post disturbance surveys have been completed, if it is deemed necessary. While Environment Canada appreciates that it may be more appropriate to finalize the details of a wetland and riparian monitoring plan postenvironmental assessment (but pre-construction), we recommend that, as part of the environmental assessment stage, an agreed upon framework be developed. Additionally, we recommend that an agreed upon framework for a habitat compensation plan be developed as part of the environmental assessment stage. This would provide a reasonable level of certainty that residual impacts would be addressed and appropriate compensation would be realized. To assist the proponent in the development of these frameworks, Environment Canada has outlined below a set of components which such frameworks should include, but not be limited to:
Wetland and Riparian Monitoring Framework:
An outline of goals and purpose of the plan. The Wetland and Riparian Monitoring Plan should be designed to assess functional recovery (vegetation complement, internal water movement, surface water movement, wildlife presence, distribution and abundance) of these systems.
A summary of baseline information (e.g. example monitoring data collection form), that would be collected prior to any project activities within the vicinity of the wetland. This would include information from the wetland function assessment framework and include photographs.
Details of monitoring and mitigation plans including, duration, timing, specific recovery targets (vegetation diversity, % cover, etc.), and reporting out schedule. Environment Canada recommends a minimum five year post- construction wetland monitoring, as many wetlands along the pipeline route occur in a harsh environment where the growing season is limited and that shrubs, trees and some forbs will take many years to recover.
Commitment to adaptive management in areas where ongoing monitoring demonstrates that recovery has not been effective.
A minimum five year post-construction wetland monitoring program to ensure that no net loss predictions (where applicable) are validated. Environment Canada notes that: mitigation is presented generally in
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Northern Gateway Response to Federal Government IR No.1 Page 145 of 246 Volume 6A, Section 8, page 8-102 of the Assessment Report and that page 8-107 indicates that, following application of the mitigation measures the wetland functions will be restored and therefore effects of surface disturbance on the wetlands will be not significant; the proponent does not cite specific wetlands that may be more sensitive and that may require special considerations; many of the wetlands along the pipeline route occur in a harsh environment (specifically in Northern Alberta and British Columbia) where the growing season is limited; and shrubs, trees, and some forbs will take many years to recover.
For areas of wetland and associated riparian areas where: the Wetland Policy no net loss goal applies; wetland-associated SARA-listed species are present, including (amongst possibly others): . Western Toad, Species of Special Concern, . Schedule 1, SARA; and, . Olive-sided Flycatcher, Threatened, Schedule 1, . SARA; . Rusty Blackbird, Special Concern, Schedule 1, . SARA; . Yellow Rail, Special Concern, Schedule 1, SARA; or important breeding populations of migratory birds are present,
a habitat compensation framework that would form the foundation for a future, detailed plan and be included as part of the environmental assessment stage. The compensation plan would address impacts to wetland and riparian habitats that are unavoidable and cannot be mitigated. To aid the proponent in developing the framework for this plan, Environment Canada has included a list of key components below.
Habitat compensation framework components should include, but not necessarily be limited to:
1. The purpose and goals of the compensation plan.
o Environment Canada recommends that the following goals be included: maintaining or enhancing regional and local wildlife populations (migratory birds/species at risk); ensuring long-term protection of wildlife habitats, functions, and populations; and, any other goals consistent with any regulations, policies plans and programs of the environmental agencies.
2. An outline of the main parties involved in creating the plan, and
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Northern Gateway Response to Federal Government IR No.1 Page 146 of 246 their respective roles (e.g. provide advice, approvals, etc.).
3. Timelines associated with the creation and implementation of the plan.
o Environment Canada recommends that compensation begin before the project is initiated, or as early as possible after, to minimize delay between functional loss and replacement.
4. An appropriate compensation ratio.
o Environment Canada generally recommends a ratio of 2:1 of area of wetland restored/created to original wetland area impacted. In areas where there has been extensive loss of wetlands and wetland function (e.g., the White Area of Alberta), a 3:1 ratio is recommended.
5. An indication of compensation type (restoration, enhancement, creation) and locations (on-site, within same watershed, within same ecosystem) that would be pursued.
o Environment Canada advises that the preferred method of compensation is restoration of drained or altered naturally occurring wetlands. Restored wetlands are preferred over enhanced wetlands, both of which are preferred over newly created wetlands. Furthermore, preference is for restoration of the same wetland types as those impacted.
o Lost wetland functions should be compensated on-site if site conditions are suitable for wetland functions. Second preference is in the same watershed from which they were lost. Third preference is in the same ecosystem from which they were lost.
o We recommend consultation with non-government conservation partners in order to identify potential compensation sites and opportunities.
6. An outline of the main components of the plan. Environment Canada recommends that the outline include, but not be limited to, the following:
(a) Mitigation Goals and Objectives o Describe functions lost at impact site o Describe functions to be gained at mitigation site o Describe overall watershed improvements to be gained
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Northern Gateway Response to Federal Government IR No.1 Page 147 of 246 (b) Baseline Information for Impact and Proposed Mitigation Sites o Provide data on physical attributes of sites (soils, vegetation, hydrology) o Describe historic and existing land uses and resources impacted
(c) Mitigation Site Selection and Justification o Identify any inventories of wetland restoration sites for the region o Likelihood of success, future land use compatibility, etc.
(d) Mitigation Site Work Plan o Location o Construction plan o Describe planned hydrology, vegetation, soils, buffers, etc.
(e) Ecological Performance Standards o Identify success criteria o Compare functions lost and gained at impact and mitigation sites o Describe soils, vegetation and hydrology parameter changes
(f) Site Protection and Maintenance o List parties and responsibilities o Evidence of legal protective measures if relevant o Maintenance plan and schedule
(g) Monitoring Plan o Provide monitoring schedule and identify party(ies) and responsibilities o Specify data to be collected, including assessment tools and methodologies
(h) Adaptive Management Plan o Identify party(ies) and responsibilities o Remedial measures (financial assurances, management plan, etc.)
(i) Financial Assurances o Identify party(ies) responsible for assurances
7. An indication of consideration of compensation in the event of a hydrocarbon spill in a wetland.
Request: Provide the following:
• A Wetland and Riparian Monitoring Plan and Habitat Compensation Plan that includes the elements below. Develop an agreed upon
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Northern Gateway Response to Federal Government IR No.1 Page 148 of 246 framework for these plans as part of the environmental assessment stage.
Response: See Northern Gateway’s response to Federal Government IR 69.
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Species at Risk and Migratory Birds
Key indicators - pipeline and Kitimat terminal
72 Reference:
Preamble: Environment Canada has reviewed information provided by the proponent in the Assessment Report and under point 7.6 on page 24 of the October 2010 Response. We note that impacts to several SARA-listed species (identified below) have not been addressed in the Assessment Report or the October 2011 Response. These species are not evaluated as Key Indicators in the Assessment Report, nor is justification provided for their exclusion. Environment Canada is of the opinion that these species should be included as Key Indicators in the Assessment Report and that potential adverse effects, and appropriate mitigation and monitoring measures be identified.
Cryptic Paw (Nephroma occultum) COSEWIC, Special Concern SARA Schedule 1, Special Concern
Environment Canada advises that based on distribution information, Cryptic Paw lichen has the potential to be adversely impacted by the project.
The Committee on the Status of Endangered Wildlife in Canada (COSEWIC) assessment (2006) for Nephroma occultum indicates that this species "…is confined to moist forested regions at elevations below 1200 m (most populations occur between about 400 and 800 m). In Canada, all populations occur in the Coastal Western Hemlock Zone and the Interior Cedar-Hemlock Zone of the British Columbia Biogeoclimatic Ecosystem Classification system. In Canada, Nephroma occultum usually occurs in old growth forests characterized by high humidity, stable environmental conditions and nutrient- rich soils. These forests provide stable conditions for slow dispersing lichens such as N. occultum and also provide protection from summer drought, one of the key distribution constraints of this species.'
Environment Canada recommends that the proponent engage the Province of British Columbia as the lead jurisdiction for advice on surveys and mitigation measures for this species. Environment Canada will provide further advice, recommendations and guidance as and where appropriate.
Horned Grebe, western population (Podiceps auritus) COSEWIC, Special Concern SARA - No Schedule to date
The western population of Horned Grebe has been assessed as Special Concern by COSEWIC. Consultations on amendments to Schedule 1 of SARA,
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Northern Gateway Response to Federal Government IR No.1 Page 150 of 246 including the addition of Horned Grebe, were scheduled for completion in March 2011. A decision about whether to add the species to Schedule 1 of the SARA could be made within timelines relevant to the project. In order to minimize the risk of future delays, Environment Canada recommends that impacts to this species be considered during the environmental assessment.
Please refer to the information available on this species in an Environment Canada document entitled "Consultation on Amending the List of Species under the Species at Risk Act: Terrestrial Species, December 2009" available at: www.sararegistry.gc.ca.
Request: Provide additional information on how potential impacts on species assessed by the Committee on the Status of Endangered Wildlife in Canada (COSEWIC) or listed on the List of Wildlife Species set out in Schedule 1 of SARA with the potential to be found in the Project Effects Assessment Area, but not included as Key Indicators were considered. For example, Cryptic Paw and Horned Grebe (Western Population) are of particular concern and these species should be assessed as Key Indicators.
Response: In general, the effects of the Project on species not selected as key indicators can be inferred from the assessment of Project effects on key indicators that are representative of those species by, for example, similar habitat or biophysical requirements (e.g., species associated with wetlands) or being likely to respond similarly to certain effects (e.g., species that are negatively affected by increased access). Further, the mitigation measures presented in the ESA (see Application (Volume 6A, Section 8.3, Section 9.3 and Volume 7A) are typically applicable to a broad range of vegetation and plant communities, wildlife habitats, and wildlife species rather than being species-specific. Subsequently, all species are encompassed, not just key indicators. Northern Gateway has also committed to implementing multiple undertakings to minimize Project effects on wildlife and vegetation in general that would also be applicable to species of conservation concern whenever applicable (regardless of their conservation status at the time the ESA was prepared), including:
• Northern Gateway Access Management Plan. Northern Gateway is committed to ‘no net gain in linear feature density’ in sensitive areas as the underlying objective of the Northern Gateway Access Management Plan, particularly within caribou herd ranges and Grizzly Bear Population Units that are affected by the Project. Northern Gateway has initiated discussions with Alberta Sustainable Resource Development and the BC provincial government to develop a comprehensive and detailed Access Management Plan. Participating Aboriginal groups and stakeholders will also be engaged.
• Wetlands Framework. During a meeting with Environment Canada on
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Northern Gateway Response to Federal Government IR No.1 Page 151 of 246 August 9, 2011, Northern Gateway made a commitment to develop a draft Wetlands Framework that will address wetlands in more detail including: function, assessment, mitigation, monitoring and compensation. The draft Framework will be prepared and will be reviewed with Environment Canada. Following input from Environment Canada, the draft framework will be made available to the Joint Review Panel. The Framework will be finalized following Project approval, when the centreline is defined and in advance of Project construction.
• Centreline Surveys. During detailed pipeline routing, the location of the centreline will be surveyed and marked. Centreline surveys will then be conducted by teams typically consisting of an engineer, a botanist, a wildlife ecologist and an archaeologist. A fisheries biologist will be included to assist in finalizing water crossing locations. Representatives of participating Aboriginal groups will also be invited to the team. Each biophysical specialist, the archaeologist and the Aboriginal representative will be responsible for identifying important design constraints, possible alternatives to avoid or minimize effects on sensitive features and requirements for specialized construction methods during pipeline installation. Where a feature cannot be avoided, mitigation measures will be identified including details on seasonal restrictions for certain activities, habitat compensation, and reclamation methods. If there are conflicts, the team will work to select the detailed pipeline route based on the route selection criteria and pipeline safety while also avoiding or minimizing effects on as many sensitive features as possible.
With respect to the two species named as examples in the request:
• Cryptic paw was not found during the Northern Gateway field surveys of the PEAA. However, this species will be included as one of the target species in the rare plant centreline surveys. • Horned Grebe was not recorded during the Northern Gateway field surveys of the PEAA. However, if observed during the centreline surveys its presence will be recorded and it will also be included as part of the waterfowl group under the Wetlands Framework.
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Baseline information for species at risk and migratory birds - pipeline and Kitimat terminal
73 Reference:
Preamble: Environment Canada recommends that, prior to finalization of the project corridor, surveys be completed for Cryptic Paw to identify occurrences within the project area and key areas for avoidance. Environment Canada also recommends that impacts to Horned Grebe be assessed and mitigation measures identified. This would be important for ensuring that impacts to these SARA- listed species are avoided or minimized, and would help ensure that obligations under subsection 79(2) of the SARA are met.
Based on point 7.7 on page 25 of the proponent's October 2010 Response, it appears that surveys for the Yellow Rail have not been undertaken, and that the proponent's assessment of impacts to this species stems solely from a paper exercise. Environment Canada requests that the proponent undertake nocturnal call-playback surveys for the Yellow Rail (in suitable Yellow Rail habitat), adhering to widely acceptable protocols. Results from these surveys, including mitigation measures, should be presented for review.
Additionally, dedicated surveys do not appear to have been undertaken for certain groups of birds. As Environment Canada indicated in item (g) on page 24 of the September 2010 Government of Canada Response, surveys targeting: riverine birds (Harlequin Duck, American Dipper); marsh birds (bittern, rails, Sora); common nighthawk; and raptors (other than Goshawk) have not been undertaken. This suggests that potential impacts for some species would not be known until pre-construction and, thus, raises concerns of the extent to which the project could be adapted to new issues related to these species.
Request: Pursuant to Information Request 72 above, assessment of impacts to SARA- listed species that have not been considered to date and identification of measures to avoid or reduce potential effects on them. Provide the following:
• Identification of observed concentrations of SARA-listed species and any site-specific mitigation needs. • A clear rationale on how impacts can be assessed meaningfully for bird groups or species for which dedicated surveys do not appear to have been completed.
Response: a) The following is a summary of SARA-listed bird species included in the assessment and reported on in the Technical Data Report: Wildlife Data and Field Surveys, and the Application (Volume 6A, Section 9.5). Specifically, the summary refers to observed concentrations, which for this response we consider to be five or more birds within a given land use planning area
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Northern Gateway Response to Federal Government IR No.1 Page 153 of 246 (“LUPA”).
• Great Blue Heron (fannini subspecies) – no known concentrations • Northern Goshawk (laingii subspecies) – no known concentrations • Western Screech-Owl (kennicotti subspecies) – no known concentrations • Short-eared Owl – no known concentrations • Olive-sided Flycatcher – 12 in Morice LUPA, 11 in Lakes LUPA, 9 in Green Area LUPA • Sprague’s Pipit – no known concentrations • Canada Warbler – 7 in Green Area LUPA • Rusty Blackbird – no known concentrations • Yellow Rail – no known concentrations
Presently, no site-specific mitigation measures are required beyond those already committed to in the Application (Volume 6A, Section 9.3 and Volume 7A). However, pursuant to the August 9, 2011, meeting with Environment Canada, Northern Gateway will conduct a centre line and wetlands survey for wildlife as per the Environmental Effects Monitoring Program. If, at the time of those surveys concentrations of SARA-listed bird species are observed and site-specific mitigation is necessary, Northern Gateway will consult with the appropriate regulatory authorities.
b) Not all species necessarily require dedicated surveys to assess potential project impacts with confidence. For example, many key indicators are representative of other species on the basis of similar habitat and biophysical requirements (e.g., species associated with wetlands) or being likely to respond similarly to certain effects (e.g., species that are negatively affected by increased access). Furthermore, mitigation measures presented in the ESA (see Application (Volume 6A, Section 8.3 and Section 9.3 and Volume 7A) are typically applicable to a broad range of vegetation and plant communities, wildlife habitats, and wildlife species rather than being species-specific. Thus, all bird groups or species are encompassed by the mitigation measures.
As per the August 9, 2011, meeting with Environment Canada, Northern Gateway recognizes that for certain species where little is known about their distribution and occurrence in relation to the PEAA, such as for Yellow Rail, dedicated species-specific surveys may be required. Thus, following Project approval, Northern Gateway will to review potential gaps in survey data with provincial and federal regulatory agencies. In addition, following the finalization of the centre line (during detailed engineering and detailed routing), a centre line and wetlands survey will be conducted for wildlife as per the Environmental Effects Monitoring Program.
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Habitat suitability rating and impact analysis for migratory birds and species at risk - pipeline and Kitimat terminal
74 Reference:
Preamble: The information is requested in support of the habitat suitability rating analyses and impact assessments.
Point 7.8(i) on page 26 of the proponent's October 2010 Response indicated that digital maps illustrating the results of the suitability modelling are available in the Wildlife Field Data and Field Surveys Technical Data Report. While maps indicating survey locations and wildlife observations for field surveys are included in the Technical Data Report, mapping related to the habitat suitability rating analysis is not provided. This information is requested in order for Environment Canada to adequately evaluate impacts to key indicator species.
The proponent has highlighted some limitations of the Habitat Suitability Ratings analyses under point 7.8(iii) on page 28 of their October 2010 Response. Environment Canada recommends that an approach be developed to address some of these limitations. The Habitat Suitability mapping for birds is not well supported by the baseline data (i.e. there is no replicated, inter-annual baseline data set) and as such is not, in Environment Canada's estimation, sufficient for identifying key habitat areas. While Environment Canada recognizes that planning begins at coarse scales and proceeds to finer scales as decisions about routing are made (as indicated under point 7.8(iv) page 29 of the October 2010 Response), there needs to be an appropriate balance between information provided in the Assessment Report and further stages in the project process. It is important that measures be taken to identify key areas of habitat for SARA-listed species and migratory birds early in the project planning process so that potential impacts can be assessed and mitigation, including avoidance, can be meaningfully considered.
Request: Provide mapping associated with the Habitat Suitability Rating Analysis. Provide clarification on how avoidance of important habitats will be achieved (proposed as primary mitigation measure) in the absence of robust baseline information for certain SARA-listed species and migratory birds.
Response: a) The output of the habitat suitability models described in the Wildlife Habitat Modelling: Approach, Methods and Species Accounts Technical Data Report and referenced throughout the Application (Volume 6A, Section 9) will be provided to Environment Canada as digital atlases on a DVD.
b) Avoidance of important habitats and wildlife habitat features will be achieved as part of the determination of detailed routing and during the subsequent centreline surveys as follows:
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Following approval of the Project, the exact location of the two pipelines will be finalized within the PEAA. The determination of the final route will incorporate:
• detailed engineering; • construction, and operational considerations; • further site-specific constraint mapping; • results of Aboriginal Traditional Knowledge studies; • further biophysical investigations (e.g., identification of site-specific habitat features such as wildlife trees, wetlands, rare plants); • archaeological surveys; and • input from participating Aboriginal groups and communities, landowners, the public, other interested parties and government agencies.
As identified above, a survey will be conducted of the proposed centerline. Environmental alignment sheets will also be developed. Within each set, the alignment sheets will identify the specific location (i.e., kilometre post start and finish) of environmentally-sensitive or culturally-sensitive features and detail the mitigation measures to be employed during construction in order to minimize Project effects.
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Mitigation for species at risk and migratory birds - pipeline and Kitimat terminal
75 Reference: Subsection 9.6.1.2, page 9-121 of Volume 6A of the Assessment Report states that "clearing will occur primarily during the winter (January, February and March) and fall (September, October and November) when many birds are absent from the [Project Environmental Assessment Area]". Environment Canada recommends that vegetation clearing avoid at minimum the period between March 15 to August 15 in areas where migratory birds may be nesting. Depending on the specific location along the pipeline corridor, a narrower window may be applicable (e.g., May 1 to July 31 is acceptable in Alberta); upon request, Environment Canada will provide advice in this regard. Environment Canada recommends that any filling, draining or other destruction of wetlands with wetland dependent species not take place until August 31 at the earliest to ensure that migratory birds have had sufficient time to fledge and disperse. If an individual has a priori knowledge of an active nest, it must be protected with a suitable buffer until the young have fledged. Provincially sensitive species and SARA-listed species may require species-specific timing restrictions which additionally need to be observed. For further information regarding species-specific timing restrictions for SARA-listed species, the proponent is directed to the Petroleum Industry Activity Guidelines for Wildlife Species at Risk in the Prairie and Northern Region (2009) document (see attached). Please note the following changes to the setback distances outlined in the aforementioned attached document:
Species & Timing Activity Setback Canada Warbler High 300m Minimum May 01 Medium 150m to July 31 Low 0 – 50m Olive-sided High 300m Flycatcher Minimum May 01 Medium 150m to August 31 Low 0 – 50m Rusty Blackbird High 300m Minimum May 01 Medium 150m to July 31 Low 0 – 50m Common High 200m Nighthawk Medium 100m Minimum May 01 Low 0 – 50m to August 31
Preamble: In areas where very limited construction activities must proceed during the nesting season, Environment Canada recommends that a qualified avian biologist survey the habitat within 7 days of the activity to ensure that no nests or indicated nests (i.e. identified by the carrying of faecal sacs, nesting material or food) will be impacted. Any likely nests must be protected with a suitable
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Northern Gateway Response to Federal Government IR No.1 Page 157 of 246 species-specific buffer until the young have fledged. Suitable species-specific buffers include 30m for songbirds, 100m for waterfowl and water birds, and up to 500m for SARA-listed species (see above referenced document for specific setbacks).
Environment Canada is unable to assess whether mitigation is likely to be effective as commitments regarding mitigation measures are coupled with the caveat statements "where possible" or "where applicable"; this does not provide certainty regarding where and how mitigation would be applied. Environment Canada continues to recommend that site-specific mitigation be developed as part of the Assessment Report. Should it otherwise be determined that developing site-specific mitigation after the environmental assessment stage is appropriate to the project, Environment Canada would recommend that a mitigation framework coupled with worst case scenarios be developed and submitted for review and comment during the environmental assessment stage.
By way of example, Environment Canada notes that the presence of Western Toad and Coast Tailed Frog has been confirmed in the project area. Environment Canada recommends that the proponent take further steps to identify key habitat areas within the project corridor for this species that include consulting with regional provincial biologists. Consistent with environmental assessment best management practices, including Environment Canada guidance, avoidance is the preferred approach in the impact mitigation hierarchy. For areas where key habitats cannot be avoided, Environment Canada recommends that a herptile management plan be developed. It is recommended that a framework for the plan, as well as worst case scenarios which demonstrate application of the framework, be included for review during the environmental assessment stage4.
4 If the combined mitigation framework and worst case scenario approach is taken for wetlands associated species, there may be some level of overlap. In these cases it is recommended that redundancy be minimized and species-specific worst case scenarios be focused on impacts aside from impacts on wetlands. For example, for western toad, one such worst case scenario could be locating an access road through a toad migration corridor.
Request: Provide the following:
• Commitment to avoid clearing during nesting season. • Further information regarding the mitigation measures mentioned in Volume 6A, Subsection 9.6.2.1 - Mitigation and Effects Management on page 9-124 of the Assessment Report, and specifically, locations along the right of way where mitigation (including mitigation type) would be implemented • For SARA-listed species, examples of locations on the right of way (on airphoto alignment sheets), where the cited mitigation measures would be implemented and how this would be achieved (for instance, beyond
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Northern Gateway Response to Federal Government IR No.1 Page 158 of 246 the general presentation in Table 9-52 Characterization of the Residual Effects of Change in Habitat Availability on Birds on page 9-135 of Volume 6A of the Assessment Report).
Response: a) The Application (Volume 7, Section A.3.26 and Volume 6A, Section 9.3), describes commitments to avoid vegetation clearing during critical nesting periods for birds. Vegetation clearing is planned to occur in the fall and winter for most construction spreads, thus avoiding the spring and summer breeding period for birds. Where avoidance of the critical nesting period for birds is unavoidable, Northern Gateway will commit to developing with provincial and federal regulatory authorities a protocol for minimizing risk to SARA-listed and migratory nesting birds. As indicated by Environment Canada in the preamble, and discussed at a meeting on August 9, 2011, Northern Gateway anticipates that this protocol will include:
• Pre-clearing nest searches and monitoring • Adherence to setback distances
b) Please see Northern Gateway’s responses to Federal Government IR 1.72 and 1.73.
c) Please see Northern Gateway’s response for Federal Government IR 1.75b).
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Caribou assessment and mitigation
76 Reference:
Preamble: The potential impact of placing the pipeline corridor through core caribou habitat, including provincially designated and proposed ungulate winter ranges is a concern. In point 7.10(i) and 7.10(ii) on page 30 of the October 2010 Response, the proponent indicated that they have been in consultations with provincial wildlife agencies to adequately understand, avoid, mitigate and/or compensate the effects of the proposed project on woodland caribou. Environment Canada supports the engagement of provincial experts on this issue, and recommends a meeting between the proponent, Environment Canada and regional provincial biologists to identify a path forward for addressing outstanding concerns in the Assessment Report.
Request: Provide the following:
• The risks associated with placing the pipeline right of way through key Caribou habitat. • Alternative routing options that avoid or minimize interference with ungulate winter range and other key habitat. • Site-specific locations on the right of way where the proponent will implement the various mitigation measures identified in Table 9-58 Characterization of the Residual Effects of Change in Habitat Availability on Caribou (page 9-152) in Section 9 of Volume 6A the Assessment Report. • Maps overlaying the proposed pipeline route and associated infrastructure overlaid with core caribou habitat, including Ungulate Winter Ranges (proposed and finalized) and Wildlife Habitat Areas. • A justification or reference for the 1.8 km/km2 linear density threshold used to assess effects of habitat fragmentation.
Response: a) Please refer to the Application (Volume 6A, Sections 9.6, 9.7.3.2, 9.8.3.2, 9.8.4.2, and 9.10.4) for a full discussion of the risks for caribou. These sections include discussions on:
• change in habitat availability (which includes fragmentation) caused by clearing vegetation during site preparation sensory disturbance because of human activities. • change in mortality risk, caused by an increase in hunting by humans and/or predation by wolves. • change in movement patterns.
Northern Gateway recognizes the importance of any effects on woodland caribou. To that end, the Project has been in consultation with provincial
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Northern Gateway Response to Federal Government IR No.1 Page 160 of 246 wildlife agencies in British Columbia and Alberta to adequately understand, avoid, mitigate and/or compensate for effects of the proposed Project on woodland caribou. In addition, Northern Gateway has also joined a public- private alliance to monitor woodland caribou and wolves. This partnership includes the British Columbia Ministry of Forests and Range, the Canadian Association of Petroleum Producers, Peace River Coal, West Fraser Timber, the West Moberly First Nation, and the University of Northern British Columbia. Given that the challenges facing caribou are broader than any one institution, Northern Gateway believes that this public-private alliance can be an effective means to pool resources, facilitate dialog, and seek solutions.
It is well documented that woodland caribou avoid a variety of human disturbances including roads, seismic lines, timber harvesting activities, and noise associated with seismic explorations and industrial development around well sites (e.g., Bradshaw et al. 1997; Dyer 1999; Dyer et al. 2001; Oberg 2001; Dyer et al. 2002; Smith 2004). Displacement distances reported in the literature are highly variable, but range from under 1 km to well over 10 km. Studies in west-central Alberta have indicated that caribou were observed further from timber harvesting activity, on average 1,200 m, than would be expected by chance (Smith et al. 2000). Industrial activity around well sites was also found to elicit a maximum avoidance of up to 1,000 m (Dyer et al. 2001, 2002). Notable avoidance of roads has been documented at 100 m (Oberg 2001) and 250 m (Dyer et al. 2001) distances and conservatively up to 500 m (Oberg 2001). Roads were also found to act as semi-permanent barriers to movement (Dyer et al. 2001; Serrouya et al. 2007a, 2007b). Avoidance of seismic lines was observed throughout all seasons (Dyer et al. 2001); however, seismic lines were not found to act as barriers to movement (Dyer et al. 2001). Weir et al. (2007) found that caribou in southwestern Newfoundland avoided areas within 4 km of an active mine site in most seasons and within 6 km of the mine centre. However, in the mountainous terrain of northeastern BC, the displacement effect of mining on caribou appears to be less (i.e. 1 km or less) (C. Bryden, pers. comm., September 2010).
In terms of this analysis, the indirect effects of the pipeline on caribou habitat (e.g., displacement as a result of sensory disturbance) were modeled using disturbance buffers that ranged from 50 m (for trails and cutlines) to 2500 m (for settled areas and active airstrips). The disturbance buffers associated with specific Project features ranged from 50 m (for tunnel waste) to 1000 m (for camps). The pipeline RoW itself was assigned a disturbance buffer of 500 m during construction and 100 m during operations. These disturbance buffers were developed based on a review of the literature and an understanding of the disturbance features characteristics and other related factors (e.g., local topography and vegetation conditions).
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It is important to recognize that the degree to which sensory disturbance associated with human activities may affect wildlife is influenced by a variety of factors (e.g., species, time of day, age and sex class, habitat type, topography, degree of habituation). Consequently, sensory disturbance effects are difficult to predict, but most likely to be manifested either as avoidance or underutilization of habitats within a certain distance of a disturbance. Given this variability, the assessment of indirect effects on woodland caribou are considered conservative, meaning that individual animals may use habitat within these buffers more or less than predicted, and any given effect is unlikely to be uniform throughout the buffer.
References:
Bradshaw, C.A., S. Boutin and D.M. Hebert. 1997. Effects of petroleum exploration on woodland caribou in northeastern Alberta. Journal of Wildlife Management 61: 1127-1133.
Dyer, S.J. 1999. Movement and distribution of woodland caribou (Rangifer tarandus caribou) in response to industrial development in northeastern Alberta. M.Sc. thesis, University of Alberta, Edmonton, AB.
Dyer, S.J., J.P. O’Neill, S.M. Wasel and S. Boutin. 2001. Avoidance of industrial development by woodland caribou. Journal of Wildlife Management 65: 531-542.
Dyer, S.J., J.P. O’Neill, S.M. Wasel and S. Boutin. 2002. Quantifying barrier effects of roads and seismic lines on movements of female woodland caribou in northeastern Alberta. Canadian Journal of Zoology 80: 839-845.
Oberg, P. 2001. Responses of mountain caribou to linear features in a west- central Alberta landscape. M.Sc. thesis. University of Alberta. Edmonton, AB.
Serrouya, R., B.N. McLellan and J.P. Flaa. 2007a. Scale-dependent microhabitat selection by threatened mountain caribou (Rangifer tarandus caribou) in cedar hemlock forests during winter. Canadian Journal of Forest Research 37: 1082-1092.
Serrouya, R., D. Lewis, B. McLellan and G. Pavan. 2007b. The selection of movement paths by mountain caribou during winter within managed landscapes: 4-year results of snow trailing. British Columbia Ministry of Forests. Forest Investment Account – Forest Science Program, Final Technical Report FSP Project #Y071312. Victoria, BC.
Smith, K.G., E.J. Ficht, D. Hobson, T.C. Sorenson, and D. Hervieux. 2000.
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Northern Gateway Response to Federal Government IR No.1 Page 162 of 246 Winter distribution of woodland caribou in relate to clear-cut logging in west-central Alberta. Can. J. Zool. 78:1433-1440.
Smith, K.G. 2004. Woodland caribou demography and persistence relative to landscape change in west central Alberta. M.Sc. thesis. University of Alberta. Edmonton, AB.
Weir, J.N., S.P. Mahoney, B. McLaren, and S.H. Ferguson. 2007. Effects of mine development on woodland caribou Rangifer tarandus distribution. Wildl. Biol. 13:66-74.
b) Northern Gateway and both Provincial and Federal wildlife regulators have met on several occasions to discuss Project interactions with wildlife, access management and refinements to the pipeline route to minimize potential Project effects on caribou and other wildlife. Meeting details are summarized in Tables 1, 2, 3 and 4 of Attachment Federal Government IR 1.76b).
An example outcome of a meeting held with ASRD is related to the proposed routing of the Project through the Little Smoky caribou herd. ASRD concluded that they preferred the currently proposed route, as opposed to an alternative that would have routed around the herd range, because the currently proposed route would have less new linear disturbance.
Northern Gateway is committed to managing Project access with the range of these five herds, and plans to continue working with regulators to minimize effects on wildlife in general. Opportunities to achieve a no-net increase in access density will also be explored as part of the Access Management Plan.
c) Following approval of the Project, the exact location of the two pipelines will be finalized within the 1-km wide corridor during detailed engineering. The determination of the final route will incorporate:
• detailed engineering • construction, and operational considerations • further site-specific constraint mapping • results of Aboriginal Traditional Knowledge studies • further biophysical investigations (e.g., identification of site-specific habitat features such as wildlife trees, mineral licks, wetlands, rare plants), archaeological surveys; and • input from participating Aboriginal groups and communities, landowners, the public, other interested parties and government agencies.
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Northern Gateway Response to Federal Government IR No.1 Page 163 of 246 During the detailed route selection, the route will be surveyed and marked. Centreline surveys will then be conducted by teams typically consisting of an engineer, a botanist, a wildlife ecologist and an archaeologist. A fisheries biologist will be included to assist in finalizing water crossing locations. Representatives of First Nations for the traditional territories that overlap that part of the pipeline will also be invited to the team. Each biophysical specialist, the archaeologist and the First Nations representative will be responsible for identifying important design constraints, possible alternatives to avoid or minimize effects on sensitive features and requirements for specialized construction methods during pipeline installation. Where a feature cannot be avoided, mitigation measures will be identified including details on seasonal restrictions for certain activities, habitat compensation, and reclamation methods. If there are conflicts, the team will work to select the route based on the route selection criteria, including pipeline safety and avoiding or minimizing effects on as many sensitive features as possible.
Once the detailed pipeline route is finalized, environmental alignment sheets will be developed. Within each set, the alignment sheets will identify the specific location (i.e., kilometer post start and finish) of environmental- sensitive or cultural-sensitive features characteristics and detail the mitigation measures to be employed during construction in order to minimize Project effects.
d) Maps overlaying the proposed pipeline route and associated infrastructure with caribou core and high value habitat, caribou herd range boundaries, Ungulate Winter Ranges, and Wildlife Habitat Areas will be provided to Environment Canada as a single digital atlas on a DVD.
e) A density of 1.8 km/km2 of ‘corridor’ (including roads, cutlines and RoWs) was selected as the threshold for determining significance with respect to mortality risk for caribou for the Project. This threshold was first identified for boreal caribou in the Yukon (Francis et al. 2002) and adopted by Salmo and Diversified (2003) for northeast BC, a region that includes boreal, northern and mountain caribou. Salmo and Diversified (2003) identified this threshold as the ‘critical’ threshold for caribou in areas zoned for general development in northeast BC. Three of the five caribou herds that interact with the Project are found in northeast BC (Narraway, Quintette and Hart Ranges). This threshold was also considered to be suitable for northern caribou elsewhere in BC (i.e., the Telkwa herd) and for boreal caribou in Alberta (i.e., the Little Smoky herd). Thus, a single threshold was identified for all five herds.
References:
Francis, S., R. Anderson and S. Dyer. 2002. Development of a threshold
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Northern Gateway Response to Federal Government IR No.1 Page 164 of 246 approach for assessing industrial impacts on woodland caribou in Yukon. Presentation provided at the Assessment and Management of Cumulative Effects Workshop, Whitehorse, YT. March 25-26, 2002.
Salmo Consulting Inc., and Diversified Environmental Services (Salmo and Diversified). 2003. Cumulative Effects Assessment and Management for Northeast British Columbia. Volume 2. Cumulative Effects Indicators, Thresholds and Case Studies. Prepared for the BC Oil and Gas Commission and the Muskwa–Kechika Advisory Board, Fort St. John, BC.
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Construction and environmental management plan - pipeline and Kitimat terminal
77 Reference:
Preamble: As indicated in above information requests, Environment Canada recommends that for SARA-listed species, migratory birds and the key habitats upon which they depend, species-specific mitigation measures, descriptions of the scenarios under which they would be applied and alternative approaches for instances where they would not be applied be included during the environmental assessment stage. As indicated above, developing mitigation frameworks and example worst case scenarios would be an alternative approach at this stage should it be determined that developing site-specific mitigation after the environmental assessment stage is appropriate to the project.
Request: Provide an amended Construction and Environmental Management Plan that provides assurance that wildlife populations, including SARA-listed species, migratory birds and key habitats, would be managed broadly and thoroughly in the short and long-term.
Response: As specified in the Application (Volume 7A, Section 1), once the pipeline route is finalized, detailed mitigation measures will be developed and environmental alignment sheets prepared. The detailed Construction Environmental Protection and Management Plan (EPMP) will provide specific measures to address site- specific concerns. By so doing, it will provide assurance that wildlife populations, including SARA-listed species, migratory birds and key habitats, would be managed broadly and thoroughly in the short and long-term.
Also specified in the Application (Volume 7A, Section 1), the detailed Construction EPMP will be comprised of a number of separate documents each specific to the construction of unique Project components. Amendments to the EPMP will be made in consultation with the wildlife resource managers and where appropriate, these amendments will also be incorporated into the Environmental Alignment Sheets.
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Key indicators - marine terminal and marine transportation
78 Reference:
Preamble: In point 7.11 on page 32 of its October 2010 Response, the proponent indicated that it would provide Environment Canada with additional information on how the key indicator species were chosen for the review. Information on how impacts to bird groups and species present in relatively high concentrations in the Confined Channel Assessment Area and Open Water Area (aside from the four key indicators) have been assessed remains outstanding.
Over 55 species of marine birds were observed in the Confined Channel Assessment Area during the proponent's marine bird surveys. According to Table D-1 of Volume 8C, Appendix D of the Assessment Report there are over 80 species of marine birds associated with the Open Water Area.
The use of four key indicators to assess impacts to all marine bird species is, in Environment Canada's estimation, insufficient. This is of particular concern with respect to the risk assessment and management of spills for marine transportation and the Kitimat Terminal. By focusing the discussion on only four species, particular oil spill sensitivities of other species and species groups are missed. Environment Canada recognizes that individual assessments of all marine bird species within the project assessment areas is not a reasonable approach; however, we recommend that the Assessment Report include a more thorough assessment of impacts to marine birds than has been provided to date, including when, how, where and why certain groups and individual species use the area and what their particular vulnerabilities to an oil spill are.
Request: The rationale supporting the suite of Key Indicators selected to account for impacts on marine bird species groups and SARA-listed species in the Project Environmental Assessment Area is requested.
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Northern Gateway Response to Federal Government IR No.1 Page 167 of 246 Response: The selection of key indicator (“KI”) species for marine birds is closely associated with the identification of interactions between the Project and marine birds, and the types of effects the Project is expected to have on marine birds as a result of these interactions. The marine bird KIs typically represent major components of the biological environment (e.g., groups of related species) that might be altered by the Project. Specific criteria considered in the selection of marine bird KIs included:
• Occurrence and use of available habitats in the Project Effects Assessment Area (“PEAA”) • Sensitivity to Project effects • Importance to local communities and resource users • National or international importance (including status under the Species at Risk Act) • Value as an indicator of environmental effects for related resources and broader systems • Ecological importance
Additional criteria that were considered to select particular KI species included the availability of baseline information, how the Project may affect the KI (i.e., knowledge of how certain activities might affect a species), and the ability to measure the change in effect.
The Application (Volume 6B, Section 12.2.1) lists the major effects of routine activities associated with the marine terminal (construction and operations) as they are expected to relate to marine birds and include:
• Change in habitat • Sensory disturbance • Risk of mortality
The Application (Volume 6B, Section 12.2.2) presents, the final list of marine bird key indicators; Marbled Murrelet, Surf Scoter, and Bald Eagle, and the rationale for their inclusion (described in further detail below). In combination, the ecological requirements of the three KI species overlap extensively with other marine bird species potentially occurring within the PEAA and associated habitats.
The three KIs are expected to be representative of how Project activities may affect different groups of marine birds.
• The ecological requirements of Marbled Murrelet include both marine and mature terrestrial habitats of the PEAA for breeding and foraging. This species has been shown to be sensitive to alterations in marine ecosystems, exhibiting extended recovery periods from population declines due to late sexual maturation and low recruitment rates.
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Northern Gateway Response to Federal Government IR No.1 Page 168 of 246 Interactions between marine terminal Project-related activities and Marbled Murrelet include physical habitat change, sensory disturbance and risk of mortality through physical habitat change or avoidance, and decreased reproductive success if nests are abandoned during Project construction. For these reasons, Marbled Murrelets are expected to be reliable indicators of overall ecosystem health, particularly for other sensitive marine bird species or groups. Their occupancy within the PEAA across seasons enhances the sensitivity and accuracy of environmental monitoring and the effective application and adaptation of mitigation strategies.
• The Surf Scoter is associated with shallow coastal waters of the PEAA during non-breeding periods. This species experiences seasonal constraints in these habitats due to the reduction in prey species and a moulting period when they are flightless and dependent on these habitats for forage and shelter. Surf Scoter is anticipated to interact with marine terminal Project effects such as physical habitat change, sensory disturbance, risk of mortality through direct loss or indirect avoidance of intertidal foraging habitat, and mortality caused by collision with terminal infrastructure. Surf Scoters are expected to be representative of species with similar seasonal and ecological requirements and constraints. Their documented occurrence within the PEAA allows for seasonal monitoring of ecosystem health, and the application and adaptation of relevant mitigation plans.
• The Bald Eagle relies on marine and terrestrial habitats within the PEAA breeding and foraging throughout the year, similar to other marine bird species groups. This species is the predominant raptor occupying the PEAA throughout all seasons, and a keystone predator of marine birds, their prey and other animals across all of these same habitats. Bald Eagle is expected to be affected by marine terminal Project-related activities as they relate to direct loss of terrestrial roosting habitat, disturbance from the construction and operation of terminal infrastructure, direct mortality through decreased reproductive recruitment, and mortality as a result of collision with electrical hazards associated with the terminal. As such Bald Eagle can act as an indicator of ecosystem sustainability and effective indicators of changes to marine and terrestrial ecosystem requirements for other marine bird groups.
Baseline data, and existing literature, presented in the Marine Bird Technical Data Report indicate that the three KI species have consistent occurrence rates in the PEAA during each season when compared to other marine bird species, with the exception of gulls which are ubiquitous to the Project area. The breeding and non-breeding populations of these KIs will support the on-going monitoring and assessment of overall ecosystem health relative to expected seasonal distributions of other marine bird
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Northern Gateway Response to Federal Government IR No.1 Page 169 of 246 species and further allow mitigation plans to be developed and adapted in the early stages of Project development.
As an example of representation, while more than 55 species are expected to occur within the CCAA, terrestrial marine bird surveys conducted within the PEAA identified 23 species (Marine Bird Technical Data Report, Table 4-18) and 61% of terrestrial based survey observations are represented by KI species selected for the marine bird effects assessment. All three KI species were among the top 4 species detected during terrestrial based marine bird surveys.
Northern Gateway acknowledges concerns related to the selection of the KI species for marine birds within the PEAA and recognizes that ecological differences exist between species and species groups potentially occurring in the PEAA.
Although Northern Gateway supports the selection of KIs used to assess effects on marine birds within the PEAA, Northern Gateway is prepared to discuss the selection of additional marine bird species with Canadian Wildlife Service for baseline and monitoring studies prior to and during Project development and operation. Specifically, during a meeting with Environment Canada on August 9, 2011, Northern Gateway committed to the development of a table that summarizes all marine bird species in the CCAA and OWA, and indicates how each species may or may not be represented by one of the existing KI species in terms of (i) responses to Project effects and (ii) suitability for monitoring. Northern Gateway will develop the table and meet with Environment Canada to discuss the selection of KIs and the suitability of the KIs chosen. The table will be completed shortly and Northern Gateway will arrange to meet with Environment Canada thereafter. Following discussions with Environment Canada, Northern Gateway will provide a final copy of the table to the Joint Review Panel and will make the table available to others through the Northern Gateway website.
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Pre-construction and pre-operations baseline data - marine terminal and marine transportation
79 Reference: Preamble: One of the key limitations with respect to the assessment of damages and biological resource recovery from the Exxon Valdez Oil Spill is the lack of baseline information (Bodkin et al. 2002; Esler et al. 2002; See 2001). Pre- perturbation baseline data are key for evaluating the population and community level consequences following an oil spill event. In addition, this information is important for informing response planning.
Environment Canada notes that point 7.18 on page 50 of the October 2010 Response indicates that the proponent plans to establish a large number of permanent environmental monitoring transects and survey areas along the Confined Channel Assessment Area and that the proponent expects that at least two years of information will be obtained prior to the start of operations to provide additional baseline data. Environment Canada recommends that as part of the Assessment Report, the proponent provide for review, a comprehensive list of biological baseline information to be collected pre-operations. The monitoring plan should also identify marine bird information gaps that would need to be addressed in these baseline studies, including the need for marine bird survey data which encompasses a minimum of three years (ideally consecutive). The inclusion of firm commitments within the Assessment Report regarding the development of a robust marine bird baseline is a high priority issue for Environment Canada.
Request: With respect to marine birds, provide rigorous preconstruction and pre- operations baseline data.
Response: Northern Gateway has committed to the development and implementation of a Marine Environmental Effects Monitoring Program (“EEMP”) for the marine terminal and marine transportation. The intent of the program would be to initially document baseline conditions including:
• the existing quality of the marine environment • the existing abundance, distribution and diversity of marine biota, focusing on certain indicator species, groups and functions
This initial phase of the EEMP would be completed following Project approval but in advance of Project construction (the marine terminal) or the start of operations (marine terminal and marine transportation).
Following the start of Project operations, the Marine EEMP would continue to assess and document:
• the response of indicator species, groups or functions to construction
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Northern Gateway Response to Federal Government IR No.1 Page 171 of 246 activities and/or operational activities • the effectiveness of recommended Project design features and mitigation measures for environmental protection and management
The program would be designed to address specific environmental effects of concern associated with routine activities for the Project; however, would also provide a database on baseline conditions in the event of an accident or malfunction during terminal operations or marine transportation.
As discussed with Environment Canada on August 9, 2011, the Framework document will describe the Marine EEMP in greater detail and will include additional information on:
• purpose and objectives of the Marine EEMP • geographic scope • duration • general approach and methodology • funding commitments • process and mechanisms for involvement of government agencies, Aboriginal groups, public stakeholders, other industry partners, and universities • reporting • internal and external communication protocols
The draft Framework is under preparation and will be reviewed with Environment Canada. Following input from Environment Canada, the document will be finalized and made available to the Joint Review Panel.
Of note, the Marine EEMP would undertaken by Northern Gateway to meet its commitments in the Application for Follow-up and Monitoring, as defined under the CEA Act. While the Marine EEMP may be integrated with independent third party research under the proposed Marine Chair, and information between the two programs may be shared, it is not part of that program.
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Coastal sensitivity mapping
80 Reference:
Preamble: This information request results from the Technical Data Report on Sensitive Area Mapping under the Coastal Operations and Sensitivity Mapping for the Confined Channel Assessment Area and the Technical Data Report on the Coastal Operations and Sensitivity Mapping for the Open Water Area.
Environment Canada supports the proponent's intention to ground truth and to add additional relevant information to the Coastal Sensitivity Atlas Maps as indicated in point 7.19(ii) on page 51 of the October 2010 Response. Environment Canada advises that there are additional existing information sources and data gaps that would need to be addressed to ensure that the final Atlas Maps are rigorous with respect to marine bird sensitivities.
Request: The inclusion of areas of importance to marine birds in the Coastal Sensitivity Atlas Maps is requested.
Response: Examples of the environmental sensitivity atlases were provided in the Application (Volume 8C). A complete set of map sheets for the Confined Channel Assessment Area (“CCAA”) was provided in the Technical Data Report: Coastal Operations and Sensitivity Mapping for the Confined Channel Assessment Area. A complete set of map sheets for the coastal areas of the Open Water Area (“OWA”) is provided in the Technical Data Report: Coastal Operations and Sensitivity Mapping for the Open Water Area. These atlases were provided as examples of what will eventually be developed prior to the start of operations of the marine terminal and marine transportation.
The two atlases, together with a comprehensive marine and shoreline database, will help decision-makers identify and prioritize the protection of areas in the event of an emergency response. Information included in the existing atlases include information on:
• shoreline types (e.g., mud, sand and rock) • shoreline sensitivity (e.g., areas of ecological importance or importance to Aboriginal groups) • coastal operations (e.g., locations of airports, boat launches and anchorages)
For these atlases, coastal sensitivity with respect to oil spills was simplified into two categories:
• coastline where long-term oil persistence would be possible or likely, because of combined low wave energy exposure and coarse, porous
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Northern Gateway Response to Federal Government IR No.1 Page 173 of 246 substrate (such as cobble or boulder) • coastline where oil effects and persistence could be longer term, because of low-energy, fine-grained habitats such as mud-vegetated flats
Most information in the existing atlases is largely based on shoreline data maintained by the Province of British Columbia (ILMB 2009). The primary databases and shoreline imagery consulted for additional information include:
• ILMB coastal datasets • Coastal Resource Information Management System (“CRIMS”) (ILMB 2009a) • Fisheries and Oceans Canada (“DFO”) • British Columbia Parks • Coastal Aerial Survey Videotapes (1999 and 2000) that were collected in development of the ILMB source data
Verification of data (e.g., shoreline ground-truthing, updating of the biophysical and human use data layers) is proposed in collaboration with government agencies such as the Canadian Wildlife Service and Fisheries and Oceans Canada, participating local Aboriginal groups, and public stakeholders. Operations and sensitivity maps will be revised after receiving information from ground truthing and input from participating government agencies, Aboriginal groups and stakeholders. Information from the Environmental Effects Monitoring Program proposed by Northern Gateway, as well as additional field surveys (e.g., marine bird surveys, marine mammal surveys) and third party research under a Marine Research Chair (funding for which will be provided by Northern Gateway) can also be used to update the environmental sensitivity maps. Traditional land use studies by coastal First Nations can also be used in updating the environmental sensitivity maps. The environmental sensitivity atlases will be revised and submitted for review by Environment Canada at least 6 months prior to commencement of operations of the marine terminal.
Northern Gateway will commit to the inclusion of areas of importance to marine birds in the Coastal Sensitivity Atlas maps. Existing information sources that will help define these areas is provided below; the list will be reviewed for completeness with government representatives (including Canadian Wildlife Services) and coastal Aboriginal groups, and will integrate Coastal Planning initiatives. Updated Coastal Sensitivity Atlas maps will be provided at least six months prior to commencement of operations.
References:
British Columbia Marine Conservation Analysis Project Team. 2011. Marine Atlas of Pacific Canada
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Northern Gateway Response to Federal Government IR No.1 Page 174 of 246 Pacific North Coast Integrated Management Area Initiative. 2011. Atlas of the Pacific North Coast Integrated Management Area
McFarlane Tranquilla, L., Truman, K., Johannessen, D., and Hooper, T. 2007. Appendix K: Marine Birds. In Ecosystem overview: Pacific North Coast Integrated Management Area (PNCIMA).
Bird Studies Canada. 2008. British Columbia Coastal Waterbirds Survey
The Pacific Wildlife Foundation
The Pacific Seabird Group
Enbridge Northern Gateway, Technical Data Report: Marine Birds
Enbridge Northern Gateway, Section 52 Application, Volume 6B: Environmental and Socio-Economic Assessment (ESA) – Marine Terminal, Section 12: Marine Birds
Enbridge Northern Gateway Project, TERMPOL Surveys and Studies, Section 3.3: Fisheries Resources Surveys, Subsection 2.4: Marine Birds.
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AIR QUALITY
Air Quality including Greenhouse Gas Emissions
81 Context
Environment Canada's mandate for managing air quality and greenhouse gas emissions is derived from the Department of the Environment Act, and the Canadian Environmental Protection Act, 1999 (CEPA 1999).
The Canadian Council of Ministers of the Environment (CCME) has established Canada-wide Standards for managing air quality issues and emissions (under the Canada-wide Environmental Standards Sub-Agreement). Both Environment Canada and the Province of British Columbia are signatories to these Canada-wide Standards.
The Canada-wide Standards for Particulate Matter (PM) and Ozone include the implementation of 'Continuous Improvement' and 'Keeping Clean Areas Clean' programs for "ensuring that new facilities and activities incorporate the best available economically feasible technologies to reduce PM and ozone levels". The Continuous Improvement principle states that remedial and preventative actions should be taken "to reduce emissions from anthropogenic sources in these areas to the extent practicable".
The comments below relate to Volume 6A Part 1, Section 4 of the Assessment Report.
Response: Appears to be preamble, rather than a question.
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82 Reference:
Preamble: Environment Canada suggests that the proponent show leadership by not only ensuring that Canadian and provincial ambient air quality standards are met, but also by ensuring that emissions are minimized in keeping with the Canada-wide Standards principles of Continuous Improvement and Keeping Clean Areas Clean, such that to the extent practicable, ambient pollutant concentrations are maintained well below the appropriate air quality standards.
It is noted that the referenced Best Available Technology and Best Management Practices document is a consultant's report commissioned by Environment Canada, not Environment Canada policy.
Request: Provide confirmation that the project will be designed and operated using Best Available Technology and Best Management Practices to minimize the degradation of air quality and to minimize greenhouse gas emissions due to new emissions sources associated with pipeline/terminal construction and terminal operations.
With respect to construction, consider the Best Practices for the Reduction of Air Emissions from Construction and Demolition Activities document.
Response: Northern Gateway will use the Best Available Technology Economically Achievable (“BATEA”), best industry practices, and other mitigation measures to limit emissions from the Project. Best practices will be used during all Project stages including design, construction, operations and maintenance, and decommissioning.
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83 Reference:
Preamble: With reference to point 7.27(vi) on page 65 of its October 2010 Response, the proponent acknowledged that "during detailed engineering, Northern Gateway will be able to quantify the number and types of equipment and activities that are potential emission sources". Determination of the "significance" of a change in emission sources should be made through a collaborative discussion between the proponent, Environment Canada and the Provinces of Alberta and British Columbia.
Request: Provide confirmation that, as the project progresses through the design stages, should there be any significant alteration to emission sources or should any significant new emission sources be introduced, a revised air quality (modeling) assessment will be undertaken to determine the environmental impact of the planned changes.
Response: Northern Gateway will conduct a revised air quality dispersion modeling assessment should there be substantial changes to or addition of emission sources that could result in a meaningful change in predicted ambient air quality concentrations. Due to the conservative dispersion modeling assessment already completed, professional judgment will be used to determine if Project emission source changes are significant enough to warrant additional modeling.
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Air Quality including Greenhouse Gas Emissions
84 Reference:
Preamble: Regulators and the public should be able to access information documenting the proponent's efforts to minimize air emissions, consistent with the Canada-wide Standards principles of Continuous Improvement and Keeping Clean Areas Clean. Request: Requests that the applicant provides a commitment to design and implement an air quality and emissions management plan for project activities in the Kitimat area to: • ensure that project emissions from the entire range of sources are tracked; • meet any emission reporting that is legally required (e.g. National Pollutant Release Inventory); • demonstrate the application of Best Available Technology and Best Management Practices; • document the proponent's continuous improvement efforts to ensure that impact is minimized to receptors for an appropriate period as determined in • consultation with Environment Canada and the Provinces of Alberta and British Columbia; and • ensure that contaminants of potential concern are monitored for an appropriate period as determined in consultation with Environment Canada and British Columbia Ministry of Environment (e.g. SO2).
The plan should include an annual report for distribution to Environment Canada and appropriate provincial contacts.
Response: Northern Gateway will design and implement an air quality and emissions management plan for Project activities in the Kitimat area. The plan will involve, but is not limited to, the following:
• Ambient monitoring for contaminants of potential concern (i.e., SO2) • Emissions tracking for Project sources in the Kitimat area. • Annual reporting
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85 Reference:
Preamble: The proponent's statement in Volume 6A, Subsection 4.4.3.5 on page 4-51 of the Assessment Report "Given the base levels of SO2 emissions in the region, Northern Gateway is prepared to work cooperatively with the Government of British Columbia, the District of Kitimat and other major industrial proponents to identify and implement measures to reduce air emissions in the region" is acknowledged. Given that the industry sectors in the District of Kitimat support an extensive air quality monitoring network, it is recommended that the proponent also participate in this ongoing monitoring of SO2 and H2S (and others to be determined in consultation with the Province of British Columbia).
It is noted that the estimates of SO2 emissions from the project are likely also conservative since there will be some SO2 emissions associated with the project from gasoline and diesel fired transportation sources. With the phasing in of federal regulations requiring reductions in the sulphur content of both on-road and off-road diesel fuel, the estimates of sulphur emissions are appropriately conservative. The Sulphur in Diesel Fuel Regulations under CEPA, 1999 establish norms in respect of the sale, import and production of ultra low sulphur diesel for off-road engines as of October 1, 2010. Similar norms for rail and marine diesel engines will come into force in 2012: http://www.ec.gc.ca/ceparegistry/documents/regs/qa_guid/questions.cfm.
Request: Requests that the applicant provides a commitment to participate in ongoing monitoring in Kitimat of SO2 and H2S (and others to be determined in consultation with the Province of British Columbia).
Response: Northern Gateway will:
• Conduct passive sampling for SO2 in the vicinity of the Kitimat terminal to ensure that emissions from marine vessels do not have an effect on vegetation adjacent to the Jetty. • Participate in the ongoing monitoring of SO2, H2S, and potentially other parameters, in consultation with other stakeholders.
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86 Reference:
Preamble: This information is required in order that data shown in table can be validated.
Request: Provide methodology/assessment used to extract the data shown in Table 4-5 "Total Existing Criteria Air Contaminant Emissions in the Kitimat Terminal PEAA" on page 4-26 in Volume 6A of the Assessment Report from the British Columbia 2000 Emissions Inventory.
Response: The emissions data in the Application (Volume 6A, Table 4-5) was determined as follows:
• Permitted point source emissions were taken from the 2000 British Columbia Emissions Inventory of Criteria Air Contaminants: Methods and Calculations (BC MOE 2004). This document summarizes the CAC emissions for all point sources by region (see Table F.3). It was determined that two major permitted point sources were located in the Kitimat Terminal PEAA; the Rio Tinto Alcan Kitimat Aluminum Smelter and the Eurocan Pulp and Paper Co. These emissions were presented in the Application (Volume 6A, Table 4-3).
• Area, mobile, and other non-industrial emissions were provided by BC MOE. A shapefile of the Kitimat Terminal PEAA was provided to BC MOE who then extracted the emissions data for the requested area from their Air Contaminant Emissions (ACE) database. The ACE database spatially allocates the area, mobile and other emissions from the 2000 British Columbia emissions inventory (BC MOE 2004) into 1 km by 1 km grid cells. These emissions can then be pulled out for any requested area of the Province. These emissions were presented in detail in the Application (Volume 6A, Table 4-4).
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87 Reference:
Preamble: This information is required to confirm that the project will not impact air quality within the Terrace airshed.
Request: Provide information on assessments conducted (including professional judgment) to rule out potential dispersion to Terrace.
Response: Dispersion modeling was completed following the Guidelines for Air Quality Dispersion Modeling in British Columbia (BC MOE 2005). The dispersion modeling domain is a 30 km by 30 km area centered on the Kitimat Terminal. The dispersion modeling domain was defined as the region that encompasses predicted concentrations above 10% of the applicable AAQO (BC MOE 2005). For BC MOE, this is the extent to which the Project has a meaningful effect on ambient air quality. Terrace, BC is located approximately 50 km north of the Kitimat Terminal, which is outside the area where meaningful Project effects are predicted.
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Air Quality including Greenhouse Gas Emissions
88 Reference:
Preamble: Table 4-21 outlines projects and physical works that may have an environmental effect on climate. Wetlands are important to the global cycling of carbon and account for 10% of the total PEAA. Disturbance of these wetlands may lead to CO2 emissions and a reduction/loss of carbon sequestration capacity.
Request: Include wetlands in Table 4-21 on page 4-67 of Section 4 of Volume 6A of the Assessment Report and assess whether mitigation measures are needed.
Response: Only direct greenhouse gas emissions were calculated and included in the assessment. Indirect emissions are much lower and therefore were not considered.
Based on the Vegetation Assessment (Volume 6A, Section 8), approximately 22 hectares (about 5%) of wetlands will be lost in the Project disturbance area. According to (Badiou et al. 2010), the rate of soil carbon sequestration for prairie pothole wetlands is approximately 2.1 Mg C ha-1y-1. Therefore, based on the 22 hectares lost, this would result in an additional 169 t/y of indirect CO2 emissions. The calculation is as follows:
CO2 (t/y) = (Wetland area lost) * (sequestration rate) * (MW CO2/MW C) = (22 ha) * (2.1 Mg C ha-1y-1) * (1 t / 1 Mg) * (44/12) = 169
Compared to the direct Project CO2 emissions of 60,460 t/y associated with the Kitimat terminal operations, this value of 169 t/y CO2 from wetland loss is very small and considered not significant.
In order to avoid wetland damage, the following mitigation measures are recommended:
• avoid muskeg and wetland areas as much as possible • access wetlands during frozen ground conditions to the extent possible • a minimum 30-m setback distance from wetlands will be implemented where possible. • limit the use of extra temporary workspace • limit grubbing to the ditch line • build a log corduroy, or implement other measures, alongside the wetlands for heavy machinery • allow wetlands affected by the Project to recover naturally
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ACCIDENTS AND MALFUNCTIONS
Oil Spill Response
89 Reference: General Oil Spill Response Plan (GOSRP), March 2011 Enbridge presents a general oil spill response plan.
Preamble: Required for Transport Canada to ensure that the outlined response equipment, techniques and mechanisms will be adequate in meeting the regulatory requirements in consideration of the proposed products to be transferred and shipped.
Required to facilitate interpretation of the GOSRP by Transport Canada.
Required to determine how challenges of poor working conditions in the Open Water Area and Confined Channel Assessment Area will be addressed when tracking and recovering heavy oil.
Required for Transport Canada to ensure that Enbridge meets regulatory requirements.
Required to determine Enbridge's proposed response to a condensate spill and/or a spill of diluted bitumen of which a percentage is condensate.
Request: Transport Canada provides general comments below (not a review for oil spill response plan compliance) on the General Oil Spill Response Plan submitted by Enbridge in support of its Northern Gateway Project.
a) Transport Canada requests that Enbridge provide:
I. interpretation of operational ramifications related to the fate and effects of the diluted bitumen or syncrude as unconventional oils in cold water environment. II. current information on emulsification and sinking potential of diluted bitumen and syncrude in a cold water environment. III. performance rating of booms, skimmers and pumps to recover heavy oil, specifically diluted bitumen. IV. its response treatment efficacy analysis as well as Western Canada Marine Response Corporation's response treatment efficacy analysis. V. a response gap analysis which identifies locations, periods and frequencies in which sea conditions (waves, wind, fog, cold) precludes safe or practical spill response. VI. the framework for requesting, hiring, registering, screening, training, supervising, and paying a workforce to respond to a spill, including onwater operations, shoreline cleanup, oiled
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Northern Gateway Response to Federal Government IR No.1 Page 184 of 246 wildlife response, and oily waste management. VII. information on final oily waste transportation and disposal. VIII. information on how a condensate spill will be responded to including who is going to respond, how salvage will be undertaken, response objectives and strategies, and how hazard exposures will be reduced. IX. information as to the degree and nature of tanker casualty / spill response preparedness in the designated anchorages or potential places of refuge. X. further information on the parties responsible for oiled wildlife planning. Definitive answers as to the Non-Government Organization who will provide the triage and rehabilitative services is key to pre-planning and eliminating any problems when this group or these groups are contracted. XI. information on who the Responsible Party will be under different spill sources (pipeline, terminal, tug / escort, and tanker)
b) Transport Canada requests that Enbridge considers and presents the ramifications of condensate evaporation and the duration so that recovery operations of bitumen can occur safely.
c) The Response Organization has limited authority to finalize the final oily waste transportation and disposal. Transport Canada requests that Enbridge outline how Enbridge will manage this in a spill of significance as the responsible polluter, given the various remote location(s) that a ship source spill may occur.
Response: a) Preliminary information related to request a) I. through XI. is provided below. Note the level of detail requested will be provided in the operational Oil Spill Response plans, which are to be completed at least six months prior to commencement of operations.
I. The following provides examples of conventional oil types whose behavior and fate would be similar to the less conventional oils associated with the Project. There would be little differences between the operational responses to a spill of Project oils and conventional oils.
Diluted bitumen would behave similarly to a light to medium Intermediate Fuel Oil (IFO 30) when initially spilled. As it weathers, its consistency and properties will be similar to a somewhat heavier IFO (IFO120).
Synthetic crude would behave much like a #2 Fuel oil (home heating oil), as the fresh and weathered properties are similar. As the
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Northern Gateway Response to Federal Government IR No.1 Page 185 of 246 synthetic crude evaporates, it may be slightly more viscous and dense than the #2 fuel oil. However, this was not be sufficient to significantly alter the general fate of the oil from an operational perspective.
Adhesion tests were conducted on fresh and weathered oils to provide an indication of the potential for these oils to adhere to shoreline sediments and infrastructure (SL Ross 2010a, Table 3-5). Adhesion measurements were collected for diluted bitumen, condensate and synthetic crudes, as well as other relatively well- known oils both when fresh and after artificial weathering.
Reference:
SL Ross. 2010a. Properties and Fate of Hydrocarbons association with Hypothetical Spills at the Marine Terminal and in the Confined Channel Assessment Area Technical Data Report. Prepared for Northern Gateway Pipelines Inc. Calgary, AB.
II. Data on the emulsion formation tendency and density of fresh and weathered diluted bitumen, synthetic crude oils and condensate are provided in Tables 3.2, 3.3 and 3.4 of the aforementioned Technical Data Report (SL Ross 2010a).
The Syncrude product tested did not emulsify until 30% evaporative loss, at which point the emulsion had a water content in the 25 to 35% range (SL Ross 2010a and 2010b). The density of syncrude remained below 1.0 g/cc (~0.94) at 1°C when weathered in the lab to 30% loss by volume. The spill scenarios modelled predict that syncrude spills would disperse prior to forming water-in-oil emulsions. Syncrude would not sink in the cold fresh or saltwater environments when fresh or weathered.
The diluted bitumen products both formed meso-stable emulsions when fresh, but were unlikely to form emulsions if subjected to mixing with water after the loss of 10% or more of their light ends (SL Ross 2010a). The density of the un-emulsified but evaporated (14 and 17% loss by volume) diluted bitumens were 0.98 or 0.99. These weathered products would not sink in salt water, but may be over-washed. They would be neutrally buoyant in fresh water. The spill scenarios modelled with diluted bitumen predict emulsion densities approaching 1.015 g/cc. These emulsions would not sink in salt water but would be over-washed by waves. Weathered diluted bitumen may sink in freshwater environments.
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Northern Gateway Response to Federal Government IR No.1 Page 186 of 246 References:
SL Ross. 2010a. Properties and Fate of Hydrocarbons from Hypothetical Spills in the Confined Channel Assessment Area and at the Marine Terminal Technical Data Report. Prepared for Northern Gateway Pipelines Inc. Calgary, AB.
SL Ross. 2010b. Properties and Fate of Hydrocarbons from Hypothetical Spills in the Open Water Area Technical Data Report. Prepared for Enbridge Northern Gateway Pipelines Limited Partnership. Calgary, AB.
III. Specific response equipment required for recovery of heavy oil, specifically diluted bitumen, will be selected in consultation with the response organization during detailed design and planning.
For recovery of high viscosity oils like Cold Lake bitumen and Mackay River bitumen, skimmers that use brush or belt technology with a positive displacement pump for pumping the oil discharge are considered appropriate. The skimmer that will be selected for recovery of the high viscosity hydrocarbons may be equipped with an annular water injection capability. Annular water injection will substantially reduce the friction inside discharge hoses during pumping of high viscosity oil. Skimmers with interchangeable disc, brush and belt cassettes will also be considered because of their wide application in recovering the less viscous synthetic crude and any condensate residual remaining after the lighter fractions evaporate.
Details on response equipment, equipment performance, suitable operating environments and equipment manufacturers are provided in World Catalog of Oil Spill Response Products.
IV. Northern Gateway has not yet established or contracted a Project response organization and is unable to complete the efficacy analysis. Northern Gateway will establish equipment inventories including boom quantities, skimming capacity and storage requirements commensurate with a 32,000 tonne response capacity. Northern Gateway will also establish the necessary infrastructure to mobilize and support the operation of equipment in the confined channel assessment area.
Western Canada Marine Response Corporation (“WCMRC “) is certified as a 10,000 tonne Response Organization.
V. Refer to Northern Gateway’s response to Coastal FN IR 1.19g).
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VI. Procedures for requesting, hiring, registering, screening, training, supervising and paying a workforce to respond to a spill, including on-water operations, shoreline cleanup, oiled wildlife response, and oily waste management would be developed through detail design and planning.
VII. Waste transportation and final disposal will be in accordance with provincial and federal legislation. Prior to operation of the marine terminal, Northern Gateway will identify approved waste handlers that can provide disposal services for liquid and solid wastes through the use of incineration, landfill and off site remediation. Northern Gateway will utilize industry best practices to minimize the recovery of water during skimming operations, segregate waste, and minimize the collection of uncontaminated solid waste. If necessary, Northern Gateway will arrange for secondary and tertiary storage for liquid and solid waste to accommodate for final waste disposal arrangements.
Northern Gateway will work with the Regional Environmental Emergencies Team and Environment Canada prior to Project operations to develop standards and guidelines for marine oily waste handling treatment and disposal similar to the initiates in the four Atlantic provinces.
VIII. Response strategies and objectives associated with a condensate spill, and procedures for reducing hazard exposures are to be developed through detailed design and planning.
IX. Refer to subpart VI. The designated anchorage at Anger Island is capable of accommodating the design class of tankers. Pilots have noted that there may be viable anchorages in the area of Browning Entrance, and have suggested that McIntyre Bay may serve as an emergency anchorage under certain conditions. The head of Kitimat Arm is also used for temporary anchorage and may be suitable for emergency situations with an escort tug in attendance. Please refer to Northern Gateway’s response to Coastal FN IR 1.10a).
Decisions concerning places of refuge fall under the responsibility of Transport Canada. The process for selecting places of refuge is described in both the National Places of Refuge Contingency Plan (“PORCP”) and the Places of Refuge Contingency Plan, Pacific Region.
X. Government and non-government organizations available for wildlife consultation, triage and rehabilitation services are listed in
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Northern Gateway Response to Federal Government IR No.1 Page 188 of 246 Attachment Federal Government IR 89. Additional details regarding wildlife response will be included in the operational plans.
XI. Marine Terminal Spill
As owner and operator of the marine terminal, Northern Gateway will be the Responsible Party for spills originating at the terminal if:
• a spill occurs at the terminal, unrelated to a cargo transfer, or
• a spill occurs during cargo transfers and the source of the spill is from a terminal pipeline
In the event of a spill at the marine terminal, Northern Gateway would fairly review and cover claims for losses. In the event of a spill from a ship, Northern Gateway would liaise with the community and the pollution fund administrators and insurers to ensure that losses are fairly reviewed and covered.
Please also see Northern Gateway responses to JRP IR 6.5, (a.2), (b) and (c.5).
Tanker Spill
Over one million barrels of crude oil and petroleum products are shipped into and out of Canadian ports on the Atlantic and Pacific coasts each day. These ports include Saint John NB, Montreal and Vancouver, as well as Kitimat.
Under Canadian law and international conventions, liability for oil pollution from ships calling on these ports is imposed, on a no-fault basis, on the ship owner.
Oil handling facilities are not liable for ship-sourced spills. Oil handling facilities and vessel owners are required to ensure that emergency response plans are in place and that emergency response arrangements are made with a certified Response Organization. The costs of those Response Organizations are borne by industry. Northern Gateway will be subject to the same rules and regulations as all other Canadian liquids terminal operators. Northern Gateway is dedicated to having the necessary arrangements in place to meet or exceed the requirements of the Canada Shipping Act and regulations.
Please also see Northern Gateway response to JRP IR 6.5 (c.1).
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Northern Gateway Response to Federal Government IR No.1 Page 189 of 246 Harbour Tug and Escort Tugs Spills
In the case of a spill associated with a tug, the tug owner would be the “Responsible Party”, except where the tug is providing contract services to the tanker.
Pipelines Spill
Under statutory and common law, the operator of a pipeline is responsible for operating the pipeline in a safe and responsible way. In the event of a spill, Northern Gateway would:
• implement immediate and comprehensive measures to identify and remediate damage caused to the environment, and
• address property loss and personal injury compensation claims fairly and efficiently.
In such cases, compensation payments typically provide redress for loss of revenue and inconvenience and are estimated using standard industry practices and methods.
Liability for prevention, remediation and cleanup is provided for under various federal and provincial statutes. Depending on the nature and location of the event, applicable legislation could include the:
• National Energy Board Act, R.S. 1985, c. N-7 • Fisheries Act, R.S. 1985, c. F-14. • British Columbia Environmental Management Act, S.B.C. 2003, Chapter 53. • Alberta Environmental Protection and Enhancement Act, R.S.A. 2000, E-12.
Please also see Northern Gateway’s response to JRP 6.5(a.1).
b) During a spill involving bitumen diluted with condensate, the majority of light ends of the hydrocarbon mixture, under typical conditions, would be expected to evaporate or disperse within approximately three to six hours (SL Ross 2010a). Initial response actions would involve identifying safety and environmental risks and avoiding any actions that would endanger the public or expose response personnel to an unacceptable level of risk. Please refer to Table 3-1 in the General Oil Spill Response Plan (“GOSRP”) for a description of the typical response strategies that would be undertaken, including those to protect the safety of the public and response personnel.
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Northern Gateway Response to Federal Government IR No.1 Page 190 of 246 First response staff will have the appropriate personal protective equipment to conduct an initial site assessment including hydrocarbon vapour monitoring. They will monitor combustible vapors in the area, and establish the perimeter of any vapor clouds. Readings must be provided to the Incident Commander or Safety Officer and recorded in the Incident Log. Additionally monitoring for breathing hazards would be completed throughout an emergency to ensure protection of response personnel and the public.
c) Northern Gateway will identify, through detailed engineering and planning and in consultation with the wider spill response community, transfer and disposal options for recovered oily liquids and other oiled wastes. Northern Gateway will work with federal and provincial governments to develop appropriate strategies for oily waste disposal for incorporation into Marine and Terminal Oil Spill Response plans. Plans are to be finalized at least six months prior to the commencement of operations.
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Accidents and Mulfunctions
90 Reference: Volume 7B
Preamble: The additional information is being requested to assist DFO in determining the potential risk of the proposed pipeline installations and potential accidents and malfunctions.
Request: DFO is concerned about the potential impacts to fish and fish habitat from a pipeline spill of petroleum products directly or indirectly into fish habitat. In particular, the Department is concerned about the direct damage to riparian and instream fish habitat as well as indirect damage that may occur as a result of any cleanup efforts. For a range of scenarios from very small to very large, the proponent should provide:
1. An estimate of the scale, duration and severity of potential effects; and
2. Any mitigation measures proposed.
Response: 1. The effects of potential pipeline spills on fish are assessed in the Application (Volume 7B). A review of effects of pipeline spills on various biophysical components, including fish and fish habitat is provided in Section 7 (see Section 7.8 for fish and fish habitat). In section 9 of the same report, effects of four spill scenarios are assessed. Scenario 3 (Large Hydrocarbon Release in a Low-Gradient Watercourse (KP 718.2, Crooked River) and Scenario 4 (Large Hydrocarbon Release in a High-Gradient Watercourse (KP 1098.7, Hunter Creek) both address the adverse environmental effects of a specific spill scenario on fish and fish habitat.
In addition, Northern Gateway submitted additional information to the Joint Review Panel on March 31, 2011, with maps showing consequence areas associated with maximum potential volume releases for each kilometer of the pipeline between Bruderheim, Alberta and Kitimat, British Columbia (see Northern Gateway Response to Request for Additional Information from the JRP Session Results and Decision (Jan 19, 2011). Information is included on watercourses and wetlands.
2. Mitigation measures for pipeline oil spills are provided in the Application (Volume 7B). Section 5 describes spill response actions and plans. In Section 7.8, mitigation measures are recommended to reduce effects of a hydrocarbon spill on fish and fish habitat. Additional recommendations on mitigation are provided in Section 9.3.3 and Section 9.3.4 in regard to the spill scenario for the Crooked River and Hunter Creek.
Before the start of operation of the pipelines, Northern Gateway will complete a Project-specific Pipeline Oil Spill Response Plan (“POSRP”) for
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Northern Gateway Response to Federal Government IR No.1 Page 192 of 246 filing with the NEB. The POSRP will describe emergency response actions, objectives and strategies to mitigate the effects on land or in water during all seasonal conditions under a range of operational and environmental settings. Effects on fish and fish habitat will be an important component of this plan. The POSRP will be consistent with Enbridge’s corporate emergency response procedures. The POSRP will also include mapping of environmental consequence areas for the RoW and downstream of the RoW where appropriate. Segment identification in term of exposure potential for sensitive areas will also be included in the POSRP. This will allow for preplanned protections measures to be implemented for key sensitivities (e.g., sensitive fish habitat, water intakes) in the event of a spill, including need to minimize effects of cleans up operations on fish habitat.
As described in the Application (Volume 7B, Section 5.7), a key aspect of contingency planning will be the identification of control points at specific locations along the RoW where tactical planning for spill responses is established before the pipelines become operational. Response objectives and strategies will be developed for potential response intercept or control sites along major rivers crossed by the pipeline route. Guides will be prepared that outline site-specific information such as access, staging, site characteristics, environmental sensitivities and suggested equipment and deployment.
These guides supplement the POSRP. Example river control tactic sheets are provided in the Technical Data Report: River Control Point for Oil Spill Response. As appropriate, government agencies, including DFO, Aboriginal groups and public stakeholders will be engaged in the development of the Control Points and identification of sensitive areas. Means to minimize effects of clean up operations on sensitive habitats will also be considered in the control point maps.
In the event of a hydrocarbon spill that affects fish habitat, Northern Gateway would conduct an assessment of effects on fish and fish habitat. Through discussions with DFO, Aboriginal groups and affected public stakeholders, Northern Gateway would develop and implement an appropriate fish habitat compensation plan.
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Ecosystem - level Impacts of Spills Resulting from Accidents and Malfunctions
91 Reference: Technical Data Reports (Marine Environmental Risk Assessment, SL Ross Environmental Research Ltd., Open Water & Confined Channel/Marine Terminal)
Preamble: The additional information is being requested to assist DFO in determining the risk that fish and fish habitat is potentially exposed to in the event of spills due to accidents and malfunctions.
Request: The Marine Environmental Risk Assessment Technical Data Reports (TDR) consider discharge of volatile hydrocarbon and trace elements from normal operations, and the properties and fate of hydrocarbons associated with hypothetical spills. These TDRs do not consider ecosystem level impacts, e.g., quantitative level of exposure that fish (as defined under Fisheries Act) are subjected to through various pathways. Although mitigation measures and potential effects are generally described in Volume 8C, there are no commitments made to specific mitigation and there is no analysis provided describing potential effects on species interactions (i.e., ecosystem level effects). The proponent should provide the following considering a range of accidents or malfunctions from very small to very large:
1. Ecological risk assessment of fish (as defined under the Fisheries Act) as end receptors potentially exposed to deleterious substances released from potential spills under various spill scenarios; 2. The quantitative level of ecotoxicological risk that fish (as defined under the Fisheries Act) and their habitat would be exposed to; and 3. The mitigation measures.
Volume 7B (Risk Assessment and Management of Spills - Pipelines), Subsection 7.8 and Section 9 Subsection 7.8 provides general discussion on effects on fish and fish habitat, but does not provide information on specific spill-related effects on fish and fish habitat. Proponent should provide quantitative exposure levels under various spill scenarios, especially for fish- bearing streams.
Section 9 provides examples of hypothetical spills along pipelines, but does not provide details regarding exposure levels to which fish and fish habitat would be subjected to, impacts of such exposure, duration and intensity of impacts, and recovery from impacts. Such details would assist DFO in determining the level of exposure and impacts that fish and fish habitat would be subjected to in the events of spills due to accidents and malfunctions.
Response: The ecological and human health risk assessment of accidental spills at the Kitimat Terminal and in the Confined Channel Assessment Area TDR (Stantec 2010) provides both quantitative and qualitative assessments of risk to aquatic
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The toxicological model used for quantitative assessments of aquatic biota exposed to hydrocarbons in the water column and in sediments is the Target Lipid Model (“TLM”) of DiToro and co-workers (2000a, 2000b). The TLM, which focuses on the non-polar narcosis mechanism of hydrocarbon toxicity, has by far the broadest and best validated range of application to a large suite to aquatic receptor classes, life stages and environmental media (water and sediment), and in addition is best able to address hydrocarbon mixture toxicity (as opposed to focusing on responses to single chemicals). Validation studies include McGrath et al. (2004), McGrath et al. (2005), DiToro et al. (2007) and McGrath and DiToro (2009). In addition, DiToro et al. (2000a) is cited in the Canada-Wide Standard for Petroleum Hydrocarbons (“PHC”) in Soil: Scientific Rationale Supporting Technical Document (CCME 2008) as the basis for the values presented in Table 4.7: Toxicity Aquatic Life Benchmarks for the CCME Subfractions.
Therefore, the assessment addresses “fish” as defined under the Fisheries Act. The generic receptor in the TLM represents a sensitive (5th percentile) species on a species sensitivity distribution that represents 33 species, including fish, amphibians, arthropods, mollusks, polychaetes, coelenterates, and protozoans.
The other major mechanism of hydrocarbon toxicity to fish is termed blue sac disease (“BSD”). BSD, which is associated with low-level exposure to three- to five-ringed PAHs, including alkylated PAHs, is characterized by an array of symptoms including pericardial and yolk sac edemas, spinal curvature, craniofacial malformation, fin rot, impaired swimming ability and mortality, and particularly affects developing fish embryos. While BSD symptoms have been documented at hydrocarbon concentrations lower than those associated with non-polar narcosis, a recent study (McIntosh et al 2010) found that under realistic exposure scenarios for spilled and dispersed oil (scenarios that are consistent with the results of modeling by Stantec (2010)), the brevity of exposure duration results in toxicity thresholds (EC50 or LC50) for gametes, free-swimming embryos, and embryos exposed to crude oil that are comparable to or higher than the narcosis-based toxicity thresholds used in this assessment.
While the TDR provides quantitative assessments of risk for aquatic biota, it also presents qualitative evaluations of damage and recovery based on studies following the Exxon Valdez oil spill. Such studies inherently address, and often focus on, the questions of community and ecosystem level effects in a way that laboratory-based toxicological studies cannot. As such, the conclusions of the TDR also take into consideration ecosystem level effects that cannot be directly predicted through quantitative analysis.
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Northern Gateway Response to Federal Government IR No.1 Page 195 of 246 It should also be noted that in the response to Federal Government IR 118, Northern Gateway has agreed to commission human health and ecological risk assessments in respect of hypothetical spill scenarios along the pipeline route.
References:
CCME. 2008. Canada-Wide Standard for Petroleum Hydrocarbons (PHC) in Soil: Scientific Rationale Supporting Technical Document. Canadian Council of Ministers of the Environment, PN 1399. January 2008.
Di Toro, D.M., J.A. McGrath and D.J. Hansen. 2000a. Technical basis for narcotic chemicals and polycyclic aromatic hydrocarbon criteria. I. Water and Tissue. Environ. Toxicol. Chem. 19: 1951-1970.
Di Toro, D.M. and J.A. McGrath. 2000b. Technical basis for narcotic chemicals and polycyclic aromatic hydrocarbon criteria. II. Mixtures and Sediments. Environ. Toxicol. Chem. 19: 1971-1982.
DiToro, D.M., J.A. McGrath and W.A. Stubblefield. 2007. Predicting the toxicity of neat and weathered crude oil: toxic potential and the toxicity of saturated mixtures. Environ. Toxicol. Chem. 26: 24-36.
McGrath, J.A., T.F. Parkerton and D.M. DiToro. 2004. Application of the narcosis target lipid model to algal toxicity and deriving predicted-no-effect concentrations. Environ. Toxicol. Chem. 23: 2503-2517.
McGrath, J.A., T.F. Parkerton, F.L. Hellweger and D.M. DiToro. 2005. Validation of the narcosis target lipid model for petroleum products: gasoline as a case study. Environ. Toxicol. Chem. 24: 2382-2394.
McGrath, J.A. and D.M. DiToro. 2009. Validation of the target lipid model for toxicity assessment of residual petroleum constituents: monocyclic and polycyclic aromatic hydrocarbons. Environ. Toxicol. Chem. 28: 1130-1148.
McIntosh, S., T. King, D. Wu and P.V. Hodson. 2010. Toxicity of dispersed weathered crude oil to early life stages of Atlantic herring (Clupea harengus). Environ. Toxicol. Chem. 29: 1160-1167.
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Effects of hydrocarbon spills on vegetation
92 Reference: Vol. 7B, Section 7.6 (Effects of Hydrocarbon Spills on the Biophysical Environment: Vegetation), p. 7-11 to 7-13
Preamble: It is important to consider effects of all documented oil spills in other northern forested areas in order to assess the risks and proposed mitigation strategies for this Project.
Request: There is a lack of information regarding impacts of crude oil spills during operation of the pipeline on forest ecosystems. This section contains a single reference that reports responses of a northern forested ecosystem to an oil spill, even though there is considerable experience in Alaska, northern Canada, and Russia on such issues; impacts might be expected to be greater or more persistent on, for example, drier forest ecosystems.
NRCan requests that Enbridge: • Prepare a more detailed description of expected impacts of condensate and diluted bitumen spills on northern forest ecosystems, preferably tabulated by forest type (or site series/ecosite phase), with relative vulnerability (low, medium, high) for each site series or ecosite phase estimated; these ratings can be added to the tables in Section 3 of the Vegetation Technical Data Report.
Response: The potential impacts of condensate and diluted bitumen spills on northern forest ecosystems will depend on several factors including type of hydrocarbon, volume of spill, geography, weather, time of year and vegetation species as discussed in the Application (Volume 7B, Section 7.1).
As described in the Application (Volume 7B, Section 7.6), condensate is a more toxic hydrocarbon due to penetration of the tissues, interference with metabolic and photosynthetic processes and ability to dissolve the waxy cuticle allowing excessive water loss. The heavier non-volatile fraction (bitumen) may coat leaves and stems, which can prevent gas exchange and photosynthesis causing mortality. Partial coating could reduce photosynthetic activity but would allow the vegetation to survive.
In wetlands, riparian types and areas of high water table, hydrocarbons float causing direct mortality to above ground vegetation. However, root systems below the water table typically survive and regenerate above ground vegetation the next growing season.
Using the higher toxicity of condensate and the protection provided by high water tables, upland forest were estimated to be relatively more vulnerable than wetland/riparian areas to spills of condensate and diluted bitumen. The
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Northern Gateway Response to Federal Government IR No.1 Page 197 of 246 estimates ranging from low to high are shown on Tables 3-2 (Rev 1), 3-6 (Rev 1), 3-12 (Rev 1), 3-18 (Rev 1), 3-25 (Rev 1), 3-32 (Rev 1), and 3-39 (Rev 1) from Section 3 of the Vegetation Technical Data Report.
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Effects of hydrocarbon spills on tree growth
93 Reference: Vol. 7B, Section 7.6 (Effects of Hydrocarbon spills on biophysical environment: Vegetation)
Preamble: The Project will pass through over 7000 ha of forest. Hydrocarbon spills could affect tree growth and ecosystem productivity.
Request: Potential impacts of hydrocarbon spills on tree growth and ecosystem productivity are not evaluated
NRCan requests that Enbridge: • Review, evaluate, and report on likely growth and survival responses of tree species on different site types and climates encountered in the Project Effects Assessment Area; this information can be added to Vol. 7B.
Response: The potential impacts on tree growth and ecosystem productivity will depend upon the factors listed in the Application (Volume 7B, Section 7.1). Potential effects on trees may include immediate mortality as well as longer term die- back and growth reductions in the vicinity of the spill. Upland forests are estimated to be more vulnerable to spills as compared to wetlands and riparian areas as listed in Federal Government IR 1.92. Depending on the type of soil treatment and the rate of residual hydrocarbon breakdown, recovery of forest productivity will occur over several years. The potential effects and mitigation in upland forested areas would likely be similar to examples of hypothetical spills on agricultural lands and wetlands described in the Application (Volume 7B, Section 9).
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Near shore sediment properties and oil spills
94 Reference: Volume 1 Section 11.12 Executive Summary of Volume 7C Risk Assessment and Management of Spills - Kitimat Terminal (Tank and Marine Terminals): pages 11-29 to 11-33
Volume 1 Section 11.15 Executive Summary of Volume 8C Risk Assessment and Management of Spills - Marine Transportation: pages 11-41 to 11-46
Preamble: In the case of an oil spill it is important to know the nature of the materials in the affected shoreline area. It is also important to have an understanding of suspended sediment in the area (usually discharged from rivers) as oil forms oil-clay or oil-mineral aggregates (OMAs) with these particles. These aggregates are neutrally buoyant and can be carried long distances. Further, they may aid in the natural dispersion of oil during operation, and especially during a spill incident
Request: Enbridge states: "A summertime release into the marine environment would result in hydrocarbons released into the water, spreading onto the shore and evaporating into the air. The results indicate the effects at the marine terminal would be reversible, with the greatest risk being contamination. Organisms likely to be exposed include marine birds, fish (primarily those spawning and rearing in nearshore areas), marine mammals and intertidal invertebrates and vegetation. Terrestrial biota along the shoreline may also be exposed. Human activities (e.g., traditional harvesting, subsistence, commercial and recreational activities) may also be adversely affected"
NRCan was unable to locate information in this Application related to grainsize and sediment properties for all shorelines in the potentially affected areas.
Provide comments on ability of contaminants or oil to adhere to sediment of different shoreline types and comment on sediment mobility and shoreline exposure or energetics. Explain which shorelines would be at greatest risk to long term oil fouling. Provide an overview of shoreline properties throughout the region (e.g. could be in the form of a map of sediment types), especially sediment grain size and potential mobility. Further, provide more details including number of years impacted and number of species and individuals affected.
Reflect the work that has been done to identify potential sensitive shorelines in later chapters in Volume 7C executive summary.
Response: Sediment data are provided in the Coastal Operations and Sensitivity Mapping Technical Data Reports (Polaris 2010a; 2010b, referenced below) in terms of the predominant size class of the materials in the shore zone.
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Northern Gateway Response to Federal Government IR No.1 Page 200 of 246 It is not possible to generalize on this topic as the adhesion properties of contaminants or oil to adhere to sediment of different shoreline types is a function of the contaminant or oil properties and of the material upon which this would be deposited. The adhesional properties of the contaminant or oil are material-specific and may vary with time. An adhesive oil may mix with water (an oil-in-water emulsion) and become non-adhesive (as was the case in the “Braer” spill). Similarly, the shoreline substrate type may be one to which a contaminant or oil may typically adhere, but if the oil strands in the lower intertidal tidal zone that remains water wetted or strands elsewhere in the tidal zone during a rain event, then the layer of water on the substrate forms a non- adhesive barrier that would most likely preclude deposition.
Sediment mobility and shoreline exposure or energetics are important factors in the initial stranding of oil, in the potential for reworking of stranded oil, and in the potential for burial of stranded oil. This topic is discussed at length for different shoreline types and substrates in the Environment Canada Field Guide to Oil Spill Response on Marine Shorelines (Owens and Sergy 2010). Potential sediment mobility is a function of the combination of grain size and exposure to wave action, which varies from location to location within the Project area.
The risk for long term oil fouling of shorelines, in other words, the potential for the long-term persistence of stranded oil, is discussed in a number of peer- reviewed publications. The risk is related primarily to the type and volume of oil that reaches a given section of shoreline and the substrate character of that location. Very few locations worldwide have had multi-year persistent oil from marine spills and these are notable because of the rarity and because of the limited extent of the oil residues (in terms of volume and distribution). The three best documented examples are the “Arrow” (Owens 2010), “Metula” (Owens and Sergy 2005), and “Exxon Valdez” (Taylor and Reimer, 2008) spills. One feature common to all three spills is the presence of coarse sediments, a topic discussed by Owens et al. (2008).
References:
Owens, E.H., 2010. Shoreline Response and Long-Term Oil Behaviour Studies following the 1970 “ARROW” Spill in Chedabucto Bay, NS. Proceedings 33rd Arctic and Marine Oilspill Programme (AMOP) Technical Seminar, Ottawa, ON.
Owens, E.H. & Sergy, G.A. 2010. A Field Guide to Oil Spill Response on Marine Shorelines. Emergencies Science and Technology Section, Science and Technology Branch, Environment Canada, Ottawa, Ontario.
Owens, E.H. and Sergy, G.A., 2005. Time Series Observations of Marsh Recovery and Pavement Persistence at Three Metula Spill Sites after 30½ Years. Proceedings 28th Arctic and Marine Oilspill Programme (AMOP)
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Owens, E.H., Taylor, E. and Humphrey, B., 2008. The Persistence and Character of Stranded Oil on Coarse-sediment Beaches. Marine Pollution Bulletin, 56, 14-26.
Polaris. 2010. Coastal Operations and Sensitivity Mapping for the Confined Channel Assessment Area Technical Data Report. Prepared for Northern Gateway Pipelines Inc. Calgary, AB.
Polaris. 2010. Coastal Operations and Sensitivity Mapping for the Open Water Area Technical Data Report. Prepared for Northern Gateway Pipelines Inc. Calgary, AB.
Taylor, E. and Reimer, P.D. 2008. Oil persistence on beaches in Prince William Sound – A review of SCAT surveys conducted from 1989 to 2002 Marine Pollution Bulletin, 56, 458-474.
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River plumes in the marine environment
95 Reference: Volume 1 Appendix M Technical Data Report Summaries Chapter M.2 Marine TDRS (in support of Volumes 6B and 8B) Section M.2.7 Marine Physical Environment Subsection M.2.7.3 Findings and Conclusions, Page M-21
Preamble: In the case of an oil spill it is important to know the nature of the materials in the affected shoreline area. It is also important to have an understanding of suspended sediment in the area (usually discharged from rivers) as oil forms oil-clay or oil-mineral aggregates (OMAs) with these particles. These aggregates are neutrally buoyant and can be carried long distances. Further, they may aid in the natural dispersion of oil during operation, and especially during a spill incident.
It is important to clarify data sources which have been used to determine sediment concentrations as related to the presence of river plumes.
Request: This section indicates that river plumes may not be present in the CCAA. However, the methods section 2.7.2 of the EIS does not describe any suspended sediment concentration studies to show whether or not the plumes are present. Salinity is much lower at the surface, indicating that there may be high river discharge and possibly an existence of plume sediment.
The EIS could be enhanced by clarification of discharge of rivers and their sediment loads and plume dynamics. In addition, Enbridge states: "Apart from a few photographs, there is no direct evidence of river plumes in the CCAA." Clarify which photographs (provide reference), and what type of survey was conducted. Confirm which rivers are being referred to in the above statement.
Response: Additional information on rivers and freshwater runoff within the confined channel assessment area (“CCAA”) is provided in the Northern Gateway Marine Physical Environment Technical Data Report (ASL, 2010a, referenced below). In particular, the importance of river runoff on the marine physical environment is described for: Ocean Currents, including plume dynamics, in Section 3.2 and Appendix B; Freshwater Discharges and Temperature-Salinity Distributions in Section 3.3 and Appendix C; and Other Water Properties (turbidity) in Section 3.6 and Appendix F. Appendix C provides an extensive analysis of the seasonal and interannual variability of the three major rivers within the CCAA (Kitimat, Kemano and Zymoetiz rivers), for which Environment Canada operates river measurement gauges. In addition, the seasonal and interannual characteristics of all the major drainage basins in the CCAA are presented and the corresponding effects of the runoff on ocean salinity and other marine water properties are discussed in some detail.
The comment that there is no direct evidence of river plumes in the CCAA reflects the results of an extensive literature search in which few maps or other
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Northern Gateway Response to Federal Government IR No.1 Page 203 of 246 data sets were obtained. However, this comment is not intended to mean that river plumes are rare or not present in the assessment area. The river plume photographs that were obtained for the ESA are presented in Appendix F of the Marine Physical Environmental TDR (ASL, 2010a). These include 1947 and 1963 aerial photographs of the Kitimat Arm area in the vicinity of the Marine Terminal area and Bish Creek, which provide evidence of the Kitimat River plume. A map of the Kitimat River plume, based on its salinity properties, is presented in Appendix C of the Marine Physical Environmental TDR (ASL, 2010a).
Reference:
ASL Environmental Sciences Inc.. (ASL) 2010a. Marine Physical Environment Technical Data Report. Prepared for Northern Gateway Pipelines Inc. Calgary, AB.
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Near shore sediment properties and oil spills
96 Reference: Volume 1 Appendix M Technical Data Report Summaries Chapter M.3 Risk TDRs (in support of Volumes 7B, 8B and 8C) Section M.3.1 River Control Points for Oil Spill Response Subsection M3.1.2 Methods Page M-24 Enbridge states: "Ground-truth surveys involved visual site inspections, photography, site assessment, and flow velocity measurements."
Preamble: Sediment concentrations and/or sediment properties are missing from the EIS.
Request: Provide sediment concentrations and/or sediment properties or the rationale why they were not included.
Response: Part of the site assessment at tactical intercept points (River Control Points) is to characterize the stream/river banks, shoals, and bottom in terms of sediment size, steepness, and vegetation. This information is to be included on Control Point Tactics Sheets for each control point. Control Point Tactic Sheets are to be developed for incorporation in the operational Pipeline Oil Spill Response Plan ("POSRP") to be finalized at least six months prior to the commencement of operations.
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Near shore sediment properties and oil spills
97 Reference: Volume 1 Appendix M Technical Data Report Summaries Chapter M.3 Risk TDRs (in support of Volumes 7B, 8B and 8C) Section M.3.6 Properties and Fate of Hydrocarbons from Hypothetical Spills at Three Sites in the Open Water Area Subsection M.3.6.3 Findings and Conclusions and Section M.3.7 Properties and Fate of Hydrocarbons from Hypothetical Spills in the Confined Channel Assessment Area and at the Marine Terminal
Preamble: These sections, as others, do not include the role of mineral aggregates in case of an oil spill.
Request: Identify whether oil mineral aggregates (OMAs) were considered in the assessment of oil transport in case of a marine spill, and provide a rationale if they were not.
Response: The formation of oil-mineral aggregates (“OMAs”) is likely to vary considerably over spatial and temporal scales. It is understood that OMA formation can affect the rates of dispersion and biodegradation of spilled hydrocarbons, particularly in surf zones. Oil-sediment interaction processes would enhance natural dispersion and degradation processes in the surf-zone where appropriate concentrations of mineral fines and oil types co-exist. Inclusion of this process in the spill model would result in a more rapid assimilation of the oil and thus the existing modeling can be considered conservative from this perspective.
The following reference is considered applicable to the study of OMA formation and associated oil dispersion effects:
• Khelifa, A., P.S. Hill and K. Lee. 2005. The role of oil-sediment aggregation in dispersion and biodegradation of spilled oil. Developments in Earth and Environmental Sciences, 3, 131-145.
The Marine Water Quality Model (“MWQM”), used for the ecological and human health risk assessment, incorporates processes to represent potential flux of hydrocarbons to sub-tidal sediment for an “open water” scenario. Such processes involve the incorporation of suspended sediments that increase the density of OMAs, the sorption of dissolved hydrocarbons to suspended sediments, and weathering that causes the density of the hydrocarbon to increase.
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Physical property data
98 Reference:
Preamble: Data are reported for selected physical properties required for spill modelling and behaviour, fate and effects prediction in original data reports SLRoss 2010a and 2010b. These data are reproduced in Table 1 in Appendix C to this document.
Also included in the SLRoss data reports are the properties of interfacial tension, dynamic viscosity, flash point, emulsion stability ranking, density, emulsion water content (where applicable) and simulated distillation results, for both evaporatively weathered oil and fresh oils. An evaluation of the behaviour and fate modeling also requires information on these properties. As well as data for just the weathered oils, data for the fresh oils are important too as this provides the starting point for the simulations. Access to the empirical weathering data are also very important for model development.
The foregoing data, as well as meteorological and hydrodynamic data, are critical to both planning for and response to spills. Having ready access to these data can save significant amounts of effort, time and money during a response.
Request: Include physical properties data from the original data reports (SL Ross 2010a and 2010b) required for spill modeling and behaviour, fate and effects prediction in the General Oil Spill Response Plan document and archive electronically such that there would be immediate availability of this data to responders in the event of a spill. Additionally, meteorological and hydrodynamic data should also be held ready to be available to spill responders and risk assessors. The data should be provided in a form convenient for contingency planning and responding to spills.
Response: The General Oil Spill Response Plan (“GOSRP”) is, in effect, a generic overarching document. The Marine, Terminal and Pipeline Oil Spill Response plans (“MOSRP”, “TOSRP” and “POSRP”), which are to be completed at least six months prior to commencement of operations, are to serve as the core reference documents for spill responders and risk assessors in the event of a spill incident. Operational spill response plans will provide data on the physical properties of each Project-specific hydrocarbon from the following Technical Data reports and other sources, where appropriate (e.g., Environment Canada Oil Properties Database).
References:
SL Ross. 2010a. Properties and Fate of Hydrocarbons from Hypothetical Spills in the Confined Channel Assessment Area and at the Marine Terminal Technical Data Report. Prepared for Northern Gateway Pipelines Inc. Calgary,
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SL Ross. 2010. Properties and Fate of Hydrocarbons from Hypothetical Spills in the Open Water Area Technical Data Report. Prepared for Enbridge Northern Gateway Pipelines Limited Partnership. Calgary, AB.
Northern Gateway has collected local meteorological data between 2005 and 2010, and studies have been undertaken on behalf of Northern Gateway that describe local ocean hydrodynamics. Local meteorological and oceanographic data are provided in the following Technical Data Reports:
• Hay & Company Consultants (Hay & Co). 2010. Wind Observations in Douglas Channel, Squally Channel and Caamaño Sound Technical Data Report. Prepared for Northern Gateway Pipelines Inc. Calgary, AB.
• ASL Environmental Sciences Inc. (ASL). 2010b. Weather and Oceanographic Conditions at Sites in the CCAA and in Queen Charlotte Sound, Hecate Strait and Dixon Entrance Technical Data Report. Prepared for Northern Gateway Pipelines Inc. Calgary, AB.
Local meteorological and ocean hydrodynamic data are pertinent inputs into marine spill scenario modelling. However, during an actual spill incident, responders, risk assessors and spill trajectory modelling technicians will require real-time data on meteorological and oceanographic conditions. Prior to Project operations, data sources for determining real-time meteorological and oceanographic conditions will be made readily accessible to those involved in spill response.
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Emulsion formation tendency
99 Reference:
Preamble: The data on emulsion formation are very important to the behaviour and ultimate fate of the oil when spilled. Testing has been conducted on similar products at Environment Canada's Emergencies Science and Technology Section. Selected data for Albian Heavy Synthetic (Albian HS) crude, and Wabasca Heavy (Wabasca H) are listed in the right-most columns of Table 1. Emulsion formation testing revealed that stable water-in-oil emulsions formed readily for the AHS crude oil when fresh, and that entrained-water states (water incorporated into the oil not by chemical stabilization, but by viscosity of the product) formed readily for the WH bitumen product.
Table 6-1 on page 6-1 of TERMPOL Study No. 3.15 indicates that emulsions are unlikely to form in all cases with the products indicated, save for weathered synthetic crude oil. The original data reports (SLRoss 2010a & 2010b), however, indicate that true emulsions and/or entrained-water states were observed and quantified for both the synthetic crude and the diluted bitumen products at both warm and cold temperatures. A significant omission from the TERMPOL documentation is the data for the fresh oils, which are present in the original data reports. Experience on previous spills indicates that emulsified states can form quickly. The emulsification tendencies of the fresh product are also quite relevant to the oil behaviour and fate.
Given both the indications in the original data report and in the independent measurements by Environment Canada's Emergencies Science and Technology Section of similar products, the tendencies of the specimen oils to form emulsions may be underestimated, particularly for the synthetic crude and the diluted bitumen products.
Request: Further study of the emulsification behaviour of these specimen oils is recommended, including emulsion formation tendency, emulsion rheometry, aging, stability and water content data.
Increased levels of emulsion formation may need to be incorporated into the oil fate compartment models included in section 12, the mass balance examples for response planning, and section 13, the risk assessment chapter of TERMPOL Study No. 3.15.
Response: Table 6-1 of TERMPOL Study No. 3.15 describes the emulsion formation tendencies of Project-relevant hydrocarbons that have weathered by 3 to 4 hours and by 24 hours. The table was included to demonstrate how physical properties of the hydrocarbons may change over time with weathering. It was not intended to summarize emulsion formation tendencies for all studied states of weathered and fresh hydrocarbons. The operational spill response plans are
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Northern Gateway Response to Federal Government IR No.1 Page 209 of 246 to detail the emulsification tendencies for all Project-relevant hydrocarbons, and will include those associated with fresh hydrocarbon states.
Data on water content (as a percentage of total), and emulsification tendency and stability are presented for the Project-relevant hydrocarbons in Section 3 of the following Technical Data Report:
• SL Ross. 2010a. Properties and Fate of Hydrocarbons Associated with Hypothetical Spills at the Marine Terminal and in the Confined Channel Assessment Area Technical Data Report. Prepared for Northern Gateway Pipelines Inc. Calgary, AB.
The results of rheometrical testing of each of the Project-relevant hydrocarbons (SL Ross 2010a, Appendix A) indicate that while condensate is very unlikely to form emulsions, diluted bitumen may form stable emulsions readily following release. Synthetic crude does not form stable emulsions when weathered to up to 30% loss by volume. In all of the spill scenarios modeled for the confined channel assessment area (“CCAA”), evaporation never exceeded 30% prior to loss of the surface slicks, so it is unlikely that stable emulsions will form with this product.
Emulsification was included in the initial time-series of modelled oil weathering undertaken by SL Ross (2010a). The time-series were based on a single particle trajectory (Hay & Company 2011) and weathering data. Mass balance modelling (Hay & Company 2011) was based primarily on the percentage of hydrocarbon evaporated and percentage dispersed when describing the spill scenarios. SL Ross data on emulsion properties such as water content, viscosity, density and thickness could be presented in the simulation, in addition to percent evaporated and percent dispersed. Please also refer to Northern Gateway’s response to Federal Government IR 104.
References:
Hay & Company Consultants. 2011. Hydrocarbon Mass Balance Estimates: Inputs for Spill Response Planning Technical Data Report. Prepared for Northern Gateway Pipelines Inc. Calgary, AB.
SL Ross. 2010a. Properties and Fate of Hydrocarbons Associated with Hypothetical Spills at the Marine Terminal and in the Confined Channel Assessment Area Technical Data Report. Prepared for Northern Gateway Pipelines Inc. Calgary, AB.
The Marine Water Quality Model (“MWQM”), used for the ecological and human health risk assessment, incorporates emulsification of surface oil based on properties of the hydrocarbons involved and their tendency to form emulsions. The stability of a water-in-hydrocarbon mixture is described
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Northern Gateway Response to Federal Government IR No.1 Page 210 of 246 according to four classes (entrained, unstable, mesostable and stable) using a numerical index presented by Fingas and Fieldhouse (2004). As hydrocarbons in the entrained and unstable emulsions are assumed to quickly return to the slick, only mesostable and stable mixtures are considered as emulsions in the spill modelling.
Reference:
Fingas, M. and B. Fieldhouse. 2004. Formation of water-in-hydrocarbon emulsions and application to hydrocarbon spill modelling. Journal of Hazardous Materials, 107: 37-50.
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Chemical distribution data
100 Reference:
Preamble: Chemical distribution data are provided in Table 6-2 on page 6-2 of TERMPOL Study No. 3.15 and are reproduced in Table 2 in Appendix C to this document. Data include the mono-aromatic benzene, toluene, ethylbenzene and xylene (BTEX) compounds as well as selected polycyclic aromatic hydrocarbon (PAH) compounds. The Canadian Councils of Ministers of the Environment (CCME) Petroleum Hydrocarbon (PHC) fraction values are also reported.
Data for the two similar products measured by Environment Canada's Emergencies Science and Technology Section are also included in the right- hand columns of Table 2. For assessing emulsion behaviour and for predicting oil fate, of particular interest for spill modeling and risk assessment are data on the resin and asphaltenes values. Similarly, a more inclusive determination of the alkylated PAHs in the oils is useful for spill modeling, but most important for gauging oil effects and performing risk assessments. Five or six families of alkyl derivatives of the parent PAH molecules are typically assessed. Sulphur- PAH homologous families, such as the dibenzothiophenes, are often also included in these assessments. Two typical data sets for the two oils similar to the TERMPOL specimen oils, measured by Environment Canada's Emergencies Science and Technology Section, can be seen in Table 3 in Appendix C to this document. These data are also plotted in Figure 1 in Appendix C to this document.
On Figure 1, the characteristic humped distribution patterns for the alkylated homologous families of PAHs can be seen. The parent PAH compound (designated C0-) is typically in low abundance. The most abundant group of PAHs in an oil typical have two methyl or one ethyl group (the total amounts of these PAH compounds are designated C2-).
Request: In order to account for the majority of the PAHs in the oils, the alkylated families' data be provided for at least the most common 2-, 3- and 4-ring PAH series.
In addition, data on the resin and asphaltenes content in the specimen oils would also be useful to both spill planners and responders. Ideally, this data would be provided for both the fresh oils and weathered samples
Response: Available information on the chemical composition of the hydrocarbons, including PAHs, is provided in Table E-1, of Appendix E, in the following Technical Data Report:
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Northern Gateway Response to Federal Government IR No.1 Page 212 of 246 • Stephenson, M., A. St-Amand, P. Mazzocco and J.-M. DeVink. 2010. Marine Ecological Risk Assessment for Kitimat Terminal Operations Technical Data Report. Prepared for Northern Gateway Pipelines Inc. Calgary, AB.
Notwithstanding the above information, the alkylated PAHs have not yet been characterized in the diluted bitumen, synthetic crude, or condensate samples. Based upon input received through this and other IRs, Northern Gateway has initiated supplemental chemical analysis of the hydrocarbons, and will provide further detail regarding alkylated PAHs in the hydrocarbons when it becomes available. The analysis will include naphthalene (C1-N, C2-N, C3-N and C4- N), phenanthrene (C1-P, C2-P, C3-P and C4-P), dibenzothiophene (C1-D, C2- D and C3-D), fluorene (C1-F, C2-F and C3-F) and chrysene (C1-C, C2-C and C3-C).
Asphaltene concentrations (mg/kg) are provided for diluted bitumen and synthetic oil in Table E-1, of Appendix E, of the above-referenced Technical Data Report. We do not expect significant asphaltene content in the condensate.
Data on resins concentrations are not available based on the chemical analysis completed to date, but Northern Gateway will investigate options to provide data on resins that would be available in the future for use by spill planners and responders.
Analytical data for weathered product samples are not presently available.
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Northern Gateway Response to Federal Government IR No.1 Page 213 of 246
Estimates of weathering process
101 Reference:
Preamble: Evaporative weathering models are presented in the TERMPOL documentation for both diluted bitumen and the (heavy) synthetic oil. These weathering models are in good agreement with those measured by Environment Canada's Emergencies Science and Technology Section for the similar Wabasca H and Albian HS respectively.
However, the TERMPOL documents do not present weathering data for the condensate, with only Subsection 6.3.9 on page 6-5 of TERMPOL Study 3.15 reporting that more than half evaporates in 30 minutes. The original data in SLRoss 2010a shows the evaporation model for condensate (CRW) in Figure 3- 5 on page 3-6, reproduced in Figure 2 in Appendix C to this document. This evaporation model indicates that complete evaporation of the condensate will occur in approximately 12 hours, while after 24 hours 135% will evaporate and after 120 hours, 160% of the condensate will evaporate. This model is clearly not realistic.
In comparison, the measured evaporation data set is reported on page A-24 (SLRoss 2010a) for the CRW condensate, shown on Figure 3 in Appendix C to this document, indicates that:
1) the material will evaporate at a much slower rate than predicted by the evaporation model; and 2) as much as 25% of the condensate may not evaporate.
Unfortunately, the experimental data are plotted in terms of the MacKay "Evaporative Exposure" parameter, and not time. Thus the experimental data and the model are not easily comparable. However, it is clear that the experimental data of SLRoss 2010a do not support the evaporation model (Figure 2) used for the CRW Condensate. For example, the terminal value of 160% for the CRW evaporation model is non-physical and more than double SLRoss' own experimental data. Furthermore, the curve of the CRW Condensate experimental data is more gradual than that of the model, indicating the model overstates the evaporation rate. The model appears to overestimate both the extent and rate of evaporation of the CRW Condensate. The evaporation model for the CRW condensate is overly aggressive, over- estimating both the rate and limit of evaporation of the product. As this model appears to have been used to evaluate the behaviour of the condensate in spill scenarios, this non-physical behaviour may be present in the results of the Section 12 simulations in TERMPOL Study No. 3.15. This may also affect the model for evaporation used in the ecological and human risk assessments in Section 13.
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Northern Gateway Response to Federal Government IR No.1 Page 214 of 246 This information request also affects Information Requests 102 and 103.
Request: Improve the evaporative model used for the CRW condensate. Ensure that predicted evaporation rates and volumes are realistic and reflect measured values.
Response: Figure 2 (SL Ross 2010a, Appendix C) should not have been extended past 1.0 fraction evaporated on the Y axis. This is an extrapolation of an empirical evaporation model past the region of its validity. The attached Figure 2-1 should be used to replace this figure.
Figure 2-1 Evaporation of CRW Condensate
1.000 0.900 0.800 0.700 0.600 0.500 0.400 0.300 Water Temp (°C ): 17 0.200 Wind Speed (knots): 5 0.100 Thickness (mm): 20 0.000 0 6 12 18 24 30 36 42 48 54 60 66 72 Elapsed Time (hr) Fv (Volume Fraction Evaporated) Fraction (Volume Fv
In Figure 3 (SL Ross 2010a, Appendix C), the X axis extends to 8 hours. The wind tunnel weathering started with a 20 mm oil layer, used an approximate wind speed of 5 knots, and was completed at 17° C. These values have been entered into the evaporation model that was used to generate the new Figure 2-1. At 8 hours, the evaporative loss by the model from the new Figure 2-1 is predicted to be about 62%. This is lower than the actual wind tunnel results that resulted in 75% loss over 8 hours under the same environmental conditions and starting oil thickness (see end point in Figure 3). The evaporation model used for the condensate was actually conservative (i.e., under-predicts evaporation, somewhat). A review of the modeling results for the confined channel assessment area (“CCAA”) scenario shows condensate evaporation of only 45 to 65% in total. Improvement of the evaporative model used for the CRW condensate is, therefore, not considered necessary.
Reference:
SL Ross. 2010a. Properties and Fate of Hydrocarbons from Hypothetical Spills
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Northern Gateway Response to Federal Government IR No.1 Page 215 of 246 in the Confined Channel Assessment Area and at the Marine Terminal Technical Data Report. Prepared for Northern Gateway Pipelines Inc. Calgary, AB.
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Northern Gateway Response to Federal Government IR No.1 Page 216 of 246
Mass-balance scenarios
102 Reference:
Preamble: As indicated in the rationale for Information Request 101, the evaporation model for CRW Condensate mentioned in Section 6 of TERMPOL Study No. 3.15, and described in SLRoss 2010a, appears to greatly over-estimate the rate and extent of evaporation. Thus, the fate model for Scenario 7 appears to underestimate the dispersion of the condensate into the water column. If necessary, an empirical fit to the measured data of SLRoss 2010a, pA-24 could be used. This also affects Information Request 103.
Request: Recalculate Scenario 7 using a more realistic model for the condensate evaporation (related to Information Request 101).
Response: Please see Northern Gateway’s response to Federal Government IR 101. The evaporation model used for condensate is considered to be realistic.
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Northern Gateway Response to Federal Government IR No.1 Page 217 of 246
Mass-balance scenarios
103 Reference:
Preamble: There is no large-volume or open water scenario presented for the CRW Condensate. Given the expected inbound traffic of condensate, a largescale simulation for condensate would be appropriate for the risk assessment. Also see Information Requests 101 and 102.
Request: Include additional CRW Condensate scenario(s) for ship-source spills.
Response: Given rapid evaporation and dispersion, a large CRW condensate spill would typically have a limited window of surface oiling and be less persistent in sub- tidal sediments and along shorelines compared to a diluted bitumen or synthetic oil spill. The large synthetic crude oil spill scenarios considered would result in larger quantities of dispersed hydrocarbons in the water column due to lower evaporation rates compared to a condensate spill of a similar size. The dispersed oil footprint from the large synthetic crude spills scenarios, therefore, provides a reasonable basis for evaluating the potential effects of a large CRW spill.
The in-water CRW concentrations near the spill source would, however, be high and would have the potential to cause acute toxicity (fast-acting, short duration) to aquatic receptors until dispersion and dilution reduce the exposure concentrations, likely within a few days (Stephenson et al. 2010a). As indicated by the chemical composition of liquid hydrocarbon samples (Appendix E, Stephenson et al. 2010b), hydrocarbons associated with a CRW spill that would enter the water column are predominantly low molecular weight aliphatic compounds, which tend to be more soluble than higher molecular weight hydrocarbons but are also less persistent.
Chemical health risks to ecological and human receptors (other than those associated with the vapour cloud) associated with a small condensate spill (250 m3) near the proposed marine terminal have been estimated (Stephenson et al. 2010a), and can be compared with risks associated with a similar sized spill of diluted bitumen. Chemical health risks associated with a much larger (36,000 m3) spill of diluted bitumen are also presented in Stantec (2010). Although ecological and human health risks associated with a CRW spill have not been modeled, they are expected to be smaller and less persistent than those associated with a comparable spill of diluted bitumen.
Vapour cloud modeling was considered most pertinent for the CRW, given the condensate’s spill-related properties. This modeling was conducted and is described in a Technical Data Report as cited below.
Northern Gateway assessed the entire open water area (“OWA”) in terms of the
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Northern Gateway Response to Federal Government IR No.1 Page 218 of 246 anticipated effects of an oil spill (see Application (Volume 8C)). A range of scenarios were evaluated for the purpose of examining how oil may compartmentalize under realistic conditions and identifying appropriate emergency response actions. Scenarios were selected to match areas that were identified by Det Norske Veritas as Increased Risk Areas. Increased Risk Areas are specific sites where incidents may be more likely based on the Quantitative Risk Analyses.
References:
Det Norske Veritas (DNV). 2010. Quantitative Risk Analysis. Prepared for Northern Gateway Pipelines Inc. Calgary, AB.
Bercha Engineering Limited. 2010. Vapour Cloud Modelling and Conditional Quantitative Risk Analysis Technical Data Report. Prepared for Enbridge Northern Gateway Pipelines Limited Partnership. Calgary, AB.
Stephenson, M., A. St-Amand, P. Mazzocco and D. Yee. 2010a. Risk Assessment for Accidental Hydrocarbon Spills at the Kitimat Terminal and in the Confined Channel Assessment Area Technical Data Report. Prepared for Northern Gateway Pipelines Inc. Calgary, AB.
Stephenson, M., A. St-Amand, P. Mazzocco and J.-M. DeVink. 2010b. Marine Ecological Risk Assessment for Kitimat Terminal Operations Technical Data Report. Prepared for Northern Gateway Pipelines Inc. Calgary, AB.
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Northern Gateway Response to Federal Government IR No.1 Page 219 of 246
Mass-balance scenarios
104 Reference:
Preamble: Floating oil and emulsified oil are not separated in the compartment models, and are reported only as surface oil. It is therefore difficult to assess how realistic the fate models are for emulsion formation or breaking. Emulsions and floating oil can behave very differently in spill transport models, for example, due to the higher profile presented to winds by the emulsion in the water.
Request: Include emulsified oil fate in compartment model. Spill scenario reporting should sub-divide the "surface oil" compartment into "floating oil" and "emulsified oil".
Response: As all of the spill scenarios considered are batch spills (i.e., a finite volume and short release time), all of the released oil is assumed to weather at a similar rate across the scenarios. Consideration of “fresh” and “emulsified” oil compartments is not deemed appropriate as the majority of the oil will be of similar consistency (unlike a long-term blowout scenario). Northern Gateway acknowledges that, in a batch spill, it is possible for different oil slicks to weather independently depending on local conditions (i.e., a portion of oil in one area could emulsify, while oil in another area may not).
According to SL Ross, confidence in trajectory modeling has not advanced to the point where different drift velocities for fresh versus weathered oil is practical. The movement of surface oil by wind blowing over the water surface is calculated as a fraction of the wind speed (the drift factor) and an optional offset in direction that accounts for coriolis effect over large distances. The difference in drift characteristics between emulsified and non-emulsified oils is small and typically not considered in oil spill models. Variation in drift due to localized wind and current conditions are likely to mask any differences due to the presence of fresh versus emulsified oil.
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Northern Gateway Response to Federal Government IR No.1 Page 220 of 246
Mass-balance scenarios
105 Reference:
Preamble: There appears to be no consideration of oil-sediment interactions. Oil sediment interactions have been found in both laboratory-scale studies and in recent field studies to greatly enhance dispersion of oil into the water column, particularly if mixing energy (wind, wave) is readily available. This is of particularly concern in surf zones. These factors may be expected in areas with high-sediment beaches or which are fed by surface run-off. These include Scenario examples 1 to 3 and the marine terminal Scenario 6. The behaviour of condensate in water with significant sediment loading is unknown.
Request: Include or provide environmental information to model oil sediment interaction fate. Information on sediment characterization in the vessel traffic areas (marine terminal, Wright Sound and Hecate Strait at a minimum) should be provided. Information should include sediment size (e.g., volume mean diameter, size distribution profiles), concentrations, and sediment type, including seasonal variability of these sediment characteristics. Ideally, sediment interactions would be included in the model.
Response: Please see Northern Gateway’s response to Federal Government IR 97.
Information available on total suspended sediment and suspended sediment particulate size in Kitimat Arm is included in Appendix B, Marine Sediment Quality Model, of the Marine Ecological Risk Assessment for Kitimat Terminal Operations (Stephenson et al. 2010b). Information is not available for Wright Sound and Hecate Strait. In general, suspended sediment loads in both these areas are considered low.
Reference:
Stephenson, M., A. St-Amand, P. Mazzocco and J-M. Devink. 2010b. Marine Ecological Risk Assessment for Kitimat Terminal Operations Technical Data Report. Prepared for Northern Gateway Pipelines Inc. Calgary, AB.
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Mass-balance scenarios
106 Reference:
Preamble: There appears to be no consideration in these models for sinking oil. For oils with densities close to that of water, like both the diluted bitumen and synthetic crude products, even a small amount of sediment can cause sinking. Recent experience with spills of similar products has shown that a major part of the oil may sink both as small particulates or a bulk "patties" or "mats". The models, as presented, seem to be missing this significant possible behaviour of the heavier oils. Oil sinking and submergence would be expected to be significant in Scenarios 2, 3, 4, and 6.
Request: Include sinking/sunken oil fate: A sunken oil compartment should be included in the model scenarios, particularly for those scenarios involving the diluted bitumen product.
Response: It is understood that oil-suspended particulate matter (“SPM”) interactions can affect the sinking and sedimentation of spilled hydrocarbons, in particular hydrocarbons with a density close to that of water (which include the diluted bitumen and synthetic oil). Oil-SPM interactions may vary considerably over spatial and temporal scales. The following reference is considered applicable to the study of oil-SPM interactions and oil sinking:
• Muschenheim, D.K. and Lee, K. 2002. Removal of Oil from Sea Surface through Particulate Interactions: Review and Prospectus. Spill Science and Technology Bulletin, 8 (1), 9-18.
Flocculation may result from oil-inorganic suspended material, oil-organic particulate matter and oil-plankton interactions, as described by Muschenheim and Lee (2002). Oil transferred to the seabed through such interactions may be potentially beneficial in the presence of water surface sensitivities, or potentially adverse in the presence of benthic and epibenthic sensitivities.
The Marine Water Quality Model (“MWQM”), used for the ecological and human health risk assessment (Stephenson et al. 2010b), incorporates processes to represent potential flux of hydrocarbons to sub-tidal sediment for an “open water” scenario. Such processes involve the incorporation of suspended sediments that increase the density of OMAs, the sorption of dissolved hydrocarbons to suspended sediments, and the sinking of surface oil due to weathering processes that cause the density of the hydrocarbons to exceed that of seawater. The associated Marine Sediment Quality Model (“MSQM”) accepts the sinking flux of hydrocarbons from the MWQM and predicts the hydrocarbon concentrations in a depositional sediment profile as it evolves due to hydrocarbon degradation, bioturbation and burial over a period of up to 20 years. Benthic invertebrates are assumed to be exposed to the surface 5 cm
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Northern Gateway Response to Federal Government IR No.1 Page 222 of 246 layer of sediments.
Reference:
Stephenson, M., A. St-Amand and P. Mazzocco. 2010b. Ecological and Human Health Risk Assessment of Accidental Spills at the Kitimat Terminal and in the Confined Channel Assessment Area. Prepared for Northern Gateway Pipelines Inc. Calgary, AB.
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Response counter-measures
107 Reference:
Preamble: In TERMPOL Study 3.15, mechanical recovery is mentioned as an option in all scenarios, with time windows for deployment of booming and other countermeasure to be effective described. Travel times and set-up times on station should be noted from proposed equipment cache locations for each scenario presented.
Request: Include time required for response.
Response: The time required for spill response will be included in the operational Oil Spill Response Plans, which are to be completed at least six months prior to commencement of operations.
Northern Gateway has developed a preliminary on-water response system to estimate the response times for the major mechanical recovery barges to arrive on site. An approximate 6-hour and 12-hour response window is shown in Attachment Federal Government IR 107. It was assumed that each responding tug and barge combination would operate as a ‘task force’ and mobilize from a pre-established ‘home’ base location. The response radii for 6 and 12 hours is based on a one-hour activation and a tow speed of 8 knots.
The actual response time would depend on the tug configurations, final response base locations, and barge storage locations.
In the CCAA, at least one major on-water recovery ‘task force’ would be on site within 12 hours; in most cases, before 6 hours.
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Northern Gateway Response to Federal Government IR No.1 Page 224 of 246
Response counter-measures
108 Reference:
Preamble: Dispersants are mentioned for all scenarios involving oils (i.e. Scenarios 1-6 in Table 4 in Appendix C of this document). The current Environment Canada guidelines (Environment Canada, Guidelines on the Use and Acceptability of Oil Spill Dispersants, Regulation, Codes, and Protocols Report EPS 1-EP-84-1, Environmental Protection Programs Directorate, 31 p., 1984) suggest that using dispersants in shallow waters or narrow embayments should be done with care. Current best practices in other jurisdictions are that dispersants not be applied within 3 nautical miles of the shore or in water shallower than 30m (100 feet). These guidelines would preclude the use of dispersants in all but Scenarios 4 and 5. Furthermore, Environment Canada normally will not recommend the use of dispersants without both dispersant effectiveness testing (Swirling Flask Test, ASTM F2059), and acute toxicity testing on Rainbow Trout (EPS1/RM/09). Toxicity testing for Daphnia species (EPS1/RM/11) and Luminescent Bacteria (EPS1/RM/24) are also very strongly encouraged. When considering response, Environment Canada will almost always prioritize removal over mitigation. As a primary mitigation technique, dispersant use should be an available option for responders, but should be prioritized lower than removal options such as mechanical collection or in situ burning. This priority of response options should be made clear both in Section 12 and the response chart Figure 7-3 on page 7-10 of TERMPOL Study No. 3.15 as well as in the General Oil Spill Response Plan.
Request: Consider appropriateness of dispersant use more carefully.
Response: Dispersant use in regions where pre-approval has not been granted (currently Environment Canada’s policy is to not pre-approve dispersant use) would be considered on a case-by-case basis for all waters regardless of depth and proximity to shore as per international best practices. Only dispersants that have received prior approval for use by Environment Canada would be used in a response. Corexit 9500 is presently the only dispersant with this approval (Environment Canada correspondence to SL Ross dated November 30, 2009). Detailed spill response plans, which are to be prepared at least six months prior to commencement of operations, are to reference any outcomes of a net environmental benefit analysis with respect to dispersant use under similar operating conditions or specific to the Project as these become available. Northern Gateway would be interested in working with Environment Canada during detailed planning to identify zones or areas where pre-approved dispersant use may be considered. This may be particularly relevant in offshore regions considered to be important marine bird habitat.
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Response counter-measures
109 Reference:
Preamble: The option of in situ burning is not discussed in Section 12 (though it is listed on the response option diagram on page 7-10) of TERMPOL Study 3.15. It is mentioned briefly in the General Oil Spill Response Plan. Burning can be a very useful option for removal of heavier oils, which can remain thick enough to burn for longer periods than lighter products. Emulsions and entrained-water states have also been found to burn readily. Recent experiences have shown that burning can be approximately twice as effective as traditional mechanical recovery options for net oil removal from the environment. This should be included as an option both in discussions of the option in TERMPOL Study No. 3.15 and in the General Oil Spill Response Plan. There exist many good guides for in situ burning. These should be referenced in the General Oil Spill Response Plan, as well as in TERMPOL Study No. 3.15.
Request: Consider use of in situ burning.
Response: Environment Canada studied in situ burning of Orimulsion (a mixture of Venezuelan bitumen and water), Venezuelan bitumen and heavy bunker fuel oil in the early 2000s. The experimental burns ranged in size from 10 cm in diameter to 1.5 m square pans. They concluded that: “Heavy oils such as Bunker C burn quite well. Orimulsion, once separated into bitumen and water, can be ignited in mid-scale situations and will burn with useful efficiency. Ignition of the Bunker C and Orimulsion is best accomplished with the addition of a primer such as diesel fuel.” (Fingas et al. 2003).
There have been no experimental studies of in situ burning of synthetic crudes, but there is no reason to believe that they would not burn in situ on water just as well as natural crudes of similar API gravity (31°).
In situ burning is referred to in Section 7.6 and Section 8.7 of the General Oil Spill Response Plan (“GOSRP”). Fingas and Punt (2000) provides guidelines for considering in situ burning as an oil spill response option.
Additional references on in situ burning to be considered for inclusion in the operational Oil Spill Response Plans include:
• Alaska Regional Response Team. 2008. In Situ Burning Guidelines for Alaska: Revision 1. Appendix II, Annex F, in The Alaska Federal/State Preparedness Plan for Response to Oil and Hazardous Substance Discharges/Releases.
• Allen, A.A. 1990. Contained controlled burning of spilled oil during the Exxon Valdez oil spill. Proceedings of the Arctic and Marine Oilspill
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Northern Gateway Response to Federal Government IR No.1 Page 226 of 246 Program Technical Seminar No. 13, Environment Canada, Ottawa, pp 305-313.
• American Society for Testing and Materials (ASTM). 2003. Standard guide for in situ burning of oil spills on water: Environmental and operational considerations. Designation: F 1788-2003.
• Buist, I.A., S.L. Ross, B.K. Trudel, E. Taylor, T.G. Campbell, P.A. Westphal, M.R. Meyers, G.S. Ronzio, A.A. Allen, A.B. Nordvik. 1994. The science, technology, and effects of controlled burning of oil spills at sea. MSRC Technical Report Series 94-013. Marine Spill Response Corporation, Washington, D.C.
• Buist, I., T. Coe, D. Jensen, S. Potter, L. Anderson, K. Bitting and K. Hansen. 2003c. In-Situ Burn Operations Manual. U. S. Coast Guard Research and Development Center Report CG-D-06-03, Groton, C.T.
• Fingas, M.F., “In-situ Burning of Orimulsion: Small Scale Burns”, in Proceedings of the Twenty-Fifth Arctic and Marine Oil Spill Program Technical Seminar, Environment Canada, Ottawa pp. 809-817, 2002
• Fingas, M.F., P. Lambert, M. Goldthorp and L. Gamble,“In-situ Burning of Orimulsion: Mid-Scale Burns”, in Proceedings of the Twenty-Sixth Arctic and Marine Oil Spill Program Technical Seminar, Environment Canada, Ottawa pp. 649-660, 2003
• Fingas, M. & Punt, M. 2000. In-Situ Burning: A Cleanup Technique for Oil Spills on Water. Emergencies Science Division, Environmental Technology Centre, Environment Canada, Ottawa, Ontario.
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Northern Gateway Response to Federal Government IR No.1 Page 227 of 246
Response counter-measures
110 Reference:
Preamble: The use of surface washing agents is not discussed in Section 12 of TERMPOL Study No. 3.15. They are mentioned in passing in the General Oil Spill Response Plan, and placed on the same level as highly damaging options such as high-pressure steam washing, which have been found to be effective but a net negative environmental benefit during the Exxon Valdes Oil Spill clean-up. Recent spills in Canada have shown that, with proper application, even heavier products can be removed from shorelines with low-energy low-temperature flushing, in contrast to the highly-damaging high-pressure, high temperature washing used during the Exxon Valdes Oil Spill. On the appropriate shorelines, rocky coasts and artificial shores, surface washing agents have been found to be very effective options for removal of oil. Quick, practical field tests have been developed for spot testing of surface washing agents with spilled product which can make go-no go decisions very straightforward. These options would be good additions in both the TERMPOL document and the General Oil Spill Response Plan.
Request: Consider alternate low-impact beach cleaning techniques.
Response: The relative potential environmental effects of surface washing agents (“SWA”), low-pressure, low temperature flushing and other shoreline treatment techniques are considered in Table 10-1 of the General Oil Spill Response Plan (“GOSRP’). High-pressure, hot water flushing is shown to represent the “most adverse habitat effect” for all shoreline types applicable to the treatment.
The following document, which provides a guide for considering shoreline clean-up options, including a range of low impact cleaning techniques, is to be referred to when detailing response options where appropriate.
Reference:
Owens, E.H. & Sergy, G.A. 2010. A Field Guide to Oil Spill Response on Marine Shorelines. Emergencies Science and Technology Section, Science and Technology Branch, Environment Canada, Ottawa, Ontario.
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Response counter-measures
111 Reference:
Preamble: Good recent examples for clean-up endpoints exist. They should be included in the General Oil Spill Response Plan.
Request: Provide a framework for clean-up endpoints.
Response: Owens and Sergy (2007) provides guidelines for selecting cleanup endpoints and outlines the principles of Net Environmental Benefit Analysis. This document will be referred to in the operational General Oil Spill Response Plan.
Reference:
Owens, E.H. & Sergy, G.A. 2007. Guidelines for Selecting Shoreline Treatment Endpoints for Oil Spill Response. Emergencies Science and Technology Section, Science and Technology Branch, Environment Canada, Ottawa, Ontario.
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Risk assessment modeling
112 Reference:
Preamble: There is conflicting information given for the scenario models used in Sections 12 and 13 of the TERMPOL Study No. 3.15. From the information provided, both in the TERMPOL 3.15 document and in the original data report from Stantec (Stephenson et al., 2010a), it appears that different behaviour and fate models are being used for the compartment spill scenario models developed by SLRoss (SLRoss 2010a/b), described in Section 12 and the Risk Assessment Marine Water Quality Model in Section 13. The description of the Marine Water Quality Model, as seen by Figure 3-5 on page 2-17 of Stephenson et al., 2010a, considers many more compartments than the SLRoss model, separating emulsion classes and intertidal and benthic sediment compartments, for example. The relationship between the behaviour and fate models used for Sections 12 and 13 needs to be clarified. If there is sharing of models or data between the two modeling studies, the Marine Water Quality Model will also:
1) overestimate the rate of evaporation and final residual amount of CRW condensate; 2) underestimate emulsion formation; and 3) need to incorporate oil-sediment and oil sinking fates. If different models are being used for these two modeling efforts, the correlations between the two (e.g. compartment fate models for both) should be explicitly shown in the TERMPOL documents.
Request: Show better linkages between models used for spill scenarios and for risk assessment.
Response: “Real-time” time series of winds, water temperatures and air temperatures were developed by Hay and Company Consultants (Hay and Co) for use in both the oil behaviour work completed by SL Ross and the trajectory and mass balance work conducted by Hay and Co. The fresh and weathered oil property data developed by SL Ross and the environmental data from Hay and Co was used in SL Ross’s in-house oil spill fate and behaviour model to predict bulk oil property change, emulsification, evaporation and dispersion with time. These data were then appended to Hay and Co’s oil trajectory results to derive the final mass balance figures generated by Hay and Co.
The various models have different objectives. The SL Ross models focus on the physical transport process and fate of spilled oil. The Marine Water Quality Model (“MWQM”) model was developed to predict concentrations of hydrocarbons in the water column and sediment of the open water areas affected by surface oil, and was used to support the ecological and human health risk assessment (Stephenson et al. 2010). The MWQM is run independently of the SL Ross models.
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Reference:
Stephenson, M., A. St-Amand and P. Mazzocco. 2010. Ecological and Human Health Risk Assessment of Accidental Spills at the Kitimat Terminal and in the Confined Channel Assessment Area. Prepared for Northern Gateway Pipelines Inc. Calgary, AB.
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Risk assessment modeling
113 Reference:
Preamble: The aromatic compounds selected as contaminants of potential concern, as indicated in Table 13-1 on page 13-5 of TERMPOL Study 3.15, need further consideration. As can be seen in Figure 1 in Appendix C to this document, the majority of aromatic PAH contribution lies in the C2- to C3-aPAHs, the di- and tri-alkylated compounds. None of these have been selected as contaminants of potential concern for the risk models. The toxicology of the alkylated PAHs is often quite different from that of the parent, unsubstituted compounds. While data on these compounds can be difficult to find, there exists some data on selected compounds. Retene, a C4-phenanthrene which has been well characterized in many petroleum crude oils, for example, might be a useful surrogate compound for the models.
Request: Chose oil-appropriate chemicals for risk assessment.
Response: Rather than selecting oil-appropriate chemicals for risk assessment (given there are thousands of individual chemical compounds represented in the hydrocarbon mixtures), it was considered more important to select an appropriate toxicity model to evaluate hydrocarbons. To this end, the Ecological Risk Assessment (“ERA”) is based upon the work of DiToro and co-workers (the Target Lipid Model (“TLM”), see references below). While we recognize that there are modes of toxicity other than the non-polar narcosis mechanism represented in the TLM, the TLM has by far the broadest and best validated range of application to a large suite to aquatic receptor classes, environmental media (water and sediment), and in addition is best able to address highly variable hydrocarbon mixture toxicity (as opposed to focusing on responses to single chemicals).
The analysis of representative hydrocarbons that was carried out incorporated some “double counting” of chemicals. For example, the hydrocarbon fractionation into aliphatic and aromatic substances would capture the polycyclic aromatic hydrocarbons (“PAHs”) as aromatic hydrocarbons, and their potential toxicity is evaluated within the overall mixture toxicity. The risk assessment shows that the acute and chronic risks associated with C0 PAHs in isolation in affected water and sediment are a small fraction of the total risk associated with the whole hydrocarbon mixtures.
References:
Di Toro, D.M., J.A. McGrath and D.J. Hansen. 2000. Technical basis for narcotic chemicals and polycyclic aromatic hydrocarbon criteria. I. Water and Tissue. Environ. Toxicol. Chem. 19: 1951-1970.
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Northern Gateway Response to Federal Government IR No.1 Page 232 of 246 Di Toro, D.M. and J.A. McGrath. 2000. Technical basis for narcotic chemicals and polycyclic aromatic hydrocarbon criteria. II. Mixtures and Sediments. Environ. Toxicol. Chem. 19: 1971-1982.
DiToro, D.M., J.A. McGrath and W.A. Stubblefield. 2007. Predicting the toxicity of neat and weathered crude oil toxic potential and the toxicity of saturated mixtures. Environ. Toxicol. Chem. 26: 24–36.
McGrath, J.A., T.F. Parkerton and D.M. DiToro. 2004. Application of the narcosis target lipid model to algal toxicity and deriving predicted-no-effect concentrations. Environ. Toxicol. Chem. 23: 2503-2517.
McGrath, J.A., T.F. Parkerton, F.L. Hellweger and D.M. DiToro. 2005. Validation of the narcosis target lipid model for petroleum products: gasoline as a case study. Environ. Toxicol. Chem. 24: 2382-2394.
McGrath, J.A. and D.M. DiToro. 2009. Validation of the target lipid model for toxicity assessment of residual petroleum constituents: monocyclic and polycyclic aromatic hydrocarbons. Environ. Toxicol. Chem. 28: 1130-1148.
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Composition of condensate 114 Reference:
Preamble: The Environmental Emergency Regulations apply to a number of substances (over certain concentrations and minimum quantities) as listed under Schedule 1 of the Regulations. The requested information will allow Environment Canada to determine whether the Regulations are applicable to this project.
Request: Provide information on the composition of condensate, specifically with respect to the substances listed in Schedule 1 of the Environmental Emergency Regulations under the Canadian Environmental Protection Act, 1999, including concentrations, minimum quantities, and whether the mixture is flammable.
Response: Information on the composition of Project condensate as it relates to substances listed in Schedule 1 of the Environmental Emergency Regulations is provided in Attachment Federal Government IR 114.
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Northern Gateway Response to Federal Government IR No.1 Page 234 of 246
Follow-up and monitoring program - marine terminal and marine transportation
115 Reference:
Preamble: Environment Canada recognizes and supports the proponent's objective to operate the marine terminal with zero spillage, and operational protocols and equipment specifications for achieving this end as indicated in point 7.13 on page 34 of the proponent's October 2010 Response. Environment Canada also acknowledges that the proponent has committed to developing a suite of environmental effects monitoring programs for the Marine Terminal and Confined Channel Assessment Area. Environment Canada recommends that frameworks for these programs be included for review during the environmental assessment stage. These should include, but not be limited to, information regarding the purpose, objectives, scope, level of effort, key indicators, reporting out requirements and adaptive management strategies.
Request: As part of the Follow-up and Monitoring Program, details on provisions for monitoring migratory bird and habitat impacts that could result from any chronic minor spills and leaks from routine operations associated with marine transportation and the Kitimat Terminal operations.
Response: As noted in the Application (Volume 6B, Section 2.3.2), several measures will be employed at the terminal to minimize the risk of chronic oil releases:
• all tankers will be equipped with fixed drip trays beneath the manifolds in accordance with the Oil Companies International Marine Forum recommendations. The drip trays will be drained into the cargo tank at the end of each loading or unloading operation and whenever else necessary. All ships receiving cargo will operate under “closed loading” conditions where tank lids and sighting ports will be securely closed and all vapours returned to the VRU at the marine terminal. Prior to cargo transfer, all sea water intakes or overboard discharge lines connected to cargo systems will be securely closed and sealed (if practical), and deck scuppers will be plugged to prevent any oil discharging overboard.
• the loading platform and access trestles will have concrete decks and will be fully curbed. The deck will be sloped to allow all runoff to be collected in a sump and then pumped to the oil-water separator. The loading arms will be equipped with fixed drip trays. Any material collected in the drip trays will be pumped to the recovered oil tank.
Chronic spills are, therefore, not intended or anticipated. However, as discussed in the Application (Volume 6B, Section 14.2.3.2), small amounts of hydrocarbon release may occur, even with best practices in place. In most instances such releases will be detected immediately and Northern Gateway
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Northern Gateway Response to Federal Government IR No.1 Page 235 of 246 would implement changes in operational procedures to eliminate the causes.
As discussed with Environment Canada on August 9, 2011, Northern Gateway has committed to the development and implementation of a Marine Environmental Effects Monitoring Program (“EEMP”) for the marine terminal and a separate but integrated study of baseline conditions for marine transportation. The EEMP for the marine terminal will include a focus on environmental quality, including regular monitoring of water and sediment quality and thereby the detection of chronic oiling. If chronic oiling was detected, Northern Gateway would implement changes in operational procedures to eliminate the causes of small oil releases. As a result, routine marine operations at the terminal will not result in any more than very small reductions in the quality of marine habitats (adjacent waters and seabed sediment) and none that would cause effects on marine birds.
As noted in Application (Volume 8B, Section 2), all vessels using the Kitimat Terminal will follow requirements for ballast water management and discharge under the Canadian Shipping Act, Canadian Ballast Water Control and Management Regulations (BWCMR), and implement an International Maritime Organization (IMO) approved Ballast Water Management Plan. Oil tankers will have segregated ballast on board that has been exchanged not less than 200 nautical miles from shore, as described by the Ballast Water Management Procedures under the BWCMR. Oily ballast water will not be discharged at the Kitimat Terminal. Solid waste and liquid waste will be managed according to the Canadian Shipping Act. As a result, routine marine operations in the CCAA and OWA will not result in chronic oiling or associated effects on marine birds.
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Northern Gateway Response to Federal Government IR No.1 Page 236 of 246
Assessment of risks from spills to species at risk and migratory birds - marine terminal and marine transportation 116 Reference: This information request is related to spill trajectory modeling and scenarios potentially impacting species at risk and migratory birds presented in Volumes 7C and 8C of the Application and the Marine Birds Technical Data Report.
The scenarios included in the Assessment Report do not include an example of a worst case scenario for a tanker fire and explosion. According to Table 8-2 on page 8-122 of the Marine Shipping Quantitative Risk Analysis Technical Data Report, with mitigation taken into consideration, the probability of a fire and explosion for many route segments is relatively similar to the probability estimates for collision and grounding incidents. Furthermore, based on Tables 6-2, 6-5, and 6-9 (on pages 6-79, 6-83, and 6-88, respectively of the Marine Shipping Quantitative Risk Analysis Technical Data Report), the frequency distribution for damage categories shows a greater percentage of major damage incidents for fire and explosions than for collisions or grounding. Finally, the southern portion of route segment 8 overlaps with the shelf break, which is a very important area from an ecological perspective, particularly with respect to marine birds. As such, Environment Canada recommends that an example spill scenario associated with a fire/explosion incident be developed for the southern portion of route segment 8.
See Information Request 103 of this document for rationale related to request for additional worst case spill scenarios for condensate.
Preamble: Environment Canada recommends that spatiotemporal figures be included in the fate and effects assessment, as these are important for showing the potential geographic extent of spill impacts.
With respect to migratory birds, the Risk Assessment Related to Hydrocarbons in the Marine Environment (Volume 8C, Section 11 of the Application) discusses long term impacts on the key indicators using results from Exxon Valdez Oil Spill studies. It does not provide information regarding marine bird sensitivities specific to the Confined Channel Assessment Area and Open Water Area. While drawing on the results from Exxon Valdez Oil Spill studies is useful, Environment Canada recommends that analyses of the expected differences in impacts on marine birds between Exxon Valdez Oil Spill and a spill in the Confined Channel Assessment Area and Open Water Area also be included.
Finally, Environment Canada recommends a more rigorous discussion regarding the long-term results of the studies from the Exxon Valdez Oil Spill be included in the Assessment Report. It should be noted that the current discussion relies heavily on results from a 2006 paper by Harwell and Gentile, the conclusions of which have been debated in the literature (Ladis 2006, Peterson et al. 2003, amongst others). Environment Canada recommends that
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Northern Gateway Response to Federal Government IR No.1 Page 237 of 246 the discussion be developed with more rigour and include arguments from both sides of debates regarding long-term impacts of the Exxon Valdez Oil Spill on marine birds. In point 7.17 on page 47 of its October 2010 Response, the proponent states "Northern Gateway is aware of the literature provided by Environment Canada on the effects of the Exxon Valdez Oil Spill on Harlequin Ducks. In addition to these references, we believe it is of value to also consider the findings in publications by: Boehm et al. 2004; Harwell and Gentile 2006; Short et al. 2004; Wiens et al. 2010; Wiens 2007." Environment Canada agrees that all of these publications should be taken into consideration in the discussion. For clarification, our request is not for the proponent to consider the list of publications Environment Canada provided to the exclusion of other studies, but rather to incorporate the results from these, and other pertinent studies, into a more rigorous and balanced discussion that considers the range of available scientific literature.
References
Esler, D., Bowman, T.D., Trust, K.A., Ballachey, B.E., Dean, T.A., Jewett, S.C., O'Clair, C.E. 2002. Harlequin duck population recovery following the 'Exxon Valdez' oil spill: progress, process and constraints. Marine Ecology Progress Series. 241:271-286.
The Government of Canada. 1991. The Federal Policy on Wetland Conservation. Ottawa, Canada: Minister of the Environment.
Landis, W.G. 2009. "The Exxon Valdez oil spill revisited and the dangers of normative science." Integrated Environmental Assessment and Management. 3(3).
Peterson, C.H., Rice, S.D., Short, J., Esler, D., Bodkin, J.L., Ballachey, B.E., Irons, D.B. 2003. "Long-Term Ecosystem Response to the Exxon Valdez Oil Spill". Science. 302(2082).
See, M.G. 2001. Lessons learned: evaluating scientific sampling of effects from the Exxon Valdez oil spill. Exxon Valdez Oil Spill Restoration Project Final Report (Restoration Project 00530). Alaska Department of Environmental Conservation, Anchorage, Alaska.
Request: Additional worst case scenario based on the risk of a tanker fire/explosion. Additional worst case spill scenarios for condensate.
Spatio-temporal spill trajectory figures associated with the fate and effects modelling for each of the spill scenarios. Additional model outputs (including spatiotemporal spill trajectory figures) which reflect various tidal states, winds and temperatures in each of the spill locations.
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Northern Gateway Response to Federal Government IR No.1 Page 238 of 246 With respect to volume 8C, Section 11, a more comprehensive assessment of region-specific impacts (including particular sensitivities) for each of the spill scenarios on bird groups. Key areas and particular species sensitivities (nesting colonies, moulting sea ducks, key waterfowl habitat, etc.) that would be impacted should be noted. Environment Canada recommends that information in the Marine Birds Technical Data Report as well as information from Pacific North Coast Integrated Management Area (PNCIMA) reports, the British Columbia Marine Conservation Analysis and other existing sources be used to provide a more credible assessment of region-specific marine bird sensitivities.
Based on the information presented in Volume 7C, Section 7.8 and Volume 8C, Section 8.8.2 of the ESA, further analysis of potential chronic effects of oil exposure on marine birds, which considers the range of available scientific literature on the subject, is requested.
Response: During a meeting with Environment Canada on August 9, 2011, in Delta, British Columbia, Northern Gateway and representatives of Environment Canada, (including the Canadian Wildlife service) and several other federal departments (Department of Justice, Transport Canada, Natural Resources Canada) discussed:
• Additional worst case scenarios (other locations and condensate spills): Northern Gateway noted that spill trajectory models had been provided for five locations (three in the Confined Channel Assessment Area (“CCAA”) and two in the Open Water Area (“OWA”)) to demonstrate how oil may compartmentalize in the environment, the response actions and to support an assessment of the environmental consequence of a spill. The locations of the scenarios were selected based on the Increased Risk Areas (“IRAs”) identified in the Marine Shipping Quantitative Risk Analysis (Det Norske Veritas 2010, Section 7.7).
In the event that an incident occurs, and the less likely case where a spill resulted, it is impossible to predict where oil would end up and the associated consequences. Ultimately the trajectory of a spill and its consequences on marine biota will depend on factors such as:
• the type of oil spilled • where a spill occurred • the volume of oil spilled • the response and restoration actions taken • the weather and oceanographic conditions • the time of year • proximity to sensitive areas
Northern Gateway has developed trajectory models to aid spill response
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Northern Gateway Response to Federal Government IR No.1 Page 239 of 246 planning. In particular, in the event of a hydrocarbon spill, these models would be used to Project transport speed and direction over a very short-term (i.e., 12- 24 hours) so that spill response and environmental protection actions can be deployed to the estimated spill pathway. Such use would also incorporate local meteorological and oceanographic conditions to update and improve the accuracy of the trajectory model. Although some practitioners use trajectory models to predict longer term movement of a spill or stochastic models to predict probability of spill contact, and then assess the environmental consequences of the spill or stochastic simulation, Northern Gateway does not support this approach. Fingas (2011) and Simecek-Beatty (2011) both discuss the uncertainty associated with use of trajectory models and the appropriate use of these models primarily to aid in short-term spill response planning.
In terms of modeling condensate spills, Northern Gateway identified that they had already assessed the effects of condensate spills in the CCAA and the OWA in the Application (Volume 8B). In the Application (Volume 8B, Section 8), a review of potential effects of an oil spill on each biological group considered in the assessment are discussed first, followed by a review of potential effects of a condensate spill. Condensate spills were not considered in the mass balance examples in Section 10, since condensate would evaporate, dissolve and disperse rapidly (Section 10.4.1). Spills of diluted bitumen (which contains condensate) and synthetic oil were modeled as they represent worst case scenarios in terms of spill persistence.
To provide Environment Canada with additional information in regard to mass balance examples under different seasonal situations, Northern Gateway committed to complete mass balance models for each of the five scenarios described in Section 10, but for the opposite season (i.e., winter outflow conditions verses summer inflow conditions) to that already provided. For example, for the Emilia Island scenario (synthetic oil under outflow conditions during winter), a second model would be completed for summer inflow conditions. Conversely, for Butterworth Rocks in north Hecate Strait (synthetic oil under typical summer conditions), winter conditions would be modeled. Northern Gateway will complete the mass balance models, as well as a similar assessment of environmental effects on the marine biophysical environment and the human environment for each new scenario, following the same methodology used for the five existing scenarios. A Technical Data Report (“TDR”) will be provided to Environment Canada for review and then filed with the JRP. It will also be made publicly available on the Northern Gateway website.
References:
Det Norske Veritas. 2010. Marine Shipping Quantitative Risk Analysis Technical Data Report. Prepared for the Enbridge Northern Gateway Project.
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Northern Gateway Response to Federal Government IR No.1 Page 240 of 246 Fingas, M. 2011 Spill Modeling, Section 8.3 in (M. Fingas ed.) "Oil Spill Science and Technology", Elsevier, 198-199.
Simecek-Beatty, D. 2011 Oil Spill Trajectory Forecasting Uncertainty and Emergency Response, Chapter 11 in (M. Fingas ed.) "Oil Spill Science and Technology", Elsevier, 275-299.
• A more comprehensive assessment of region-specific impacts on birds: As discussed in the environmental assessment (see Application (Volumes 7C, Sections 7 and 9 and Volume 8C, Sections 8 and 10)) effects of some oil spills on marine biota have been documented to be adverse and significant. Given the complex factors that influence the trajectory and environmental consequences of a hydrocarbon spill (see previous discussion), it is conservatively assumed in the Application (Volume 8C) that all areas along the Northern and Southern Approaches could be at some risk of being oiled, given the multiple combinations of the factors that are possible. It is for this reason that the entire confined channel assessment area and open water area were qualitatively assessed at a high level for the potential effects of an oil spill on key resources and socio-economic interests (see Application (Volume 8C, Section 8)).
As was discussed with Environment Canada on August 9, 2011, regardless of the documented and debated acute and chronic effects of oil on the environment and the ability of cold-water ecosystems to recover following an oil spill, oil spills must be prevented. The safe operations of tankers and the marine terminal is an essential aspect of the Northern Gateway Project. Northern Gateway has devoted a substantial effort to addressing the prevention of marine oil spills during marine transportation, as well as at the Kitimat Terminal. A wide array of measures has or will be employed to ensure safe navigation and safe terminal operations.
To address the request of the Canadian Wildlife Service for more comprehensive assessment of region-specific effects on marine birds, Northern Gateway committed to completing a tabular summary that would describe for each major group of marine avifauna:
• Sensitivity to oil spills • Relative vulnerability to oil spills relative to distribution and occurrence in the CCAA and the OWA • Summary of observed effects in the published literature • Potential mitigation measures
A draft version of the table will be provided to Environment Canada for comment. The final table will then be provided to Environment Canada and the JRP and will also be made publicly available on the NEB and Northern Gateway websites.
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Northern Gateway Response to Federal Government IR No.1 Page 241 of 246
In addition, Northern Gateway is aware of the presence of sensitive coastal, pelagic and benthic species and communities proximate to the marine transportation route and, subject to Project approval, will refine the Coastal Operations and Marine Sensitivity Atlas to map these sensitivities in the CCAA and OWA. Geographic Response Plans ("GRPs") are also to be developed prior to the commencement of operations, to detail site-specific oil spill response tactics for priority sensitive sites. The Canadian Wildlife Service would be consulted in developing both these products.
Information identified in this Information Request, as well as other recent information on marine birds (including surveys of marine birds that Northern Gateway has committed to conduct following Project approval and prior to the commencement of operations of the marine terminal) will be used to update and verify the Marine Sensitivity Atlas and to inform the development of GRPs.
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Northern Gateway Response to Federal Government IR No.1 Page 242 of 246
ABORIGINAL
Aboriginal engagement
117 Reference: Exhibit B2-26, Volume 5A, Section 2.3, Page 2-3 and Exhibit B22-27, Volume 4, 2010 Update, Appendix P: Sample Project Fact Sheets, pdf pages 39-46 (fact sheets on Aboriginal Engagement, Aboriginal Benefits, Aboriginal Traditional Knowledge).
Enbridge states, "Northern Gateway’s Aboriginal engagement program is based on principles to: …identify and pursue Aboriginal group participation in the Project through community and economic development initiatives…" Since Aboriginal engagement activities began on the Project in 2002, the Applicant has provided funding to Aboriginal groups for community and/or economic development initiatives and with community investment contributions. On February 9, 2011, Enbridge released the details of the Aboriginal benefits package that is being offered to Aboriginal groups along the proposed pipeline route.
NRCan requests that Enbridge provide detail regarding the amount of direct funding to date that has been provided to Aboriginal groups for community and/or economic development initiatives and for community investment contributions as well as an estimate of future funding for these initiatives.
Preamble: The Government of Canada would like additional information regarding economic benefits for Aboriginal groups/communities associated with the project.
Request: Also provide information on whether Aboriginal groups/communities will uptake the Aboriginal Equity Ownership offering, as well as progress to date on the other elements of the Aboriginal Economic Opportunities Package. If this information remains confidential, please indicate when progress reports will be filed.
Response: An overview of the Aboriginal equity ownership offering has been provided to eligible groups in meetings that have occurred since November 2010. More recently, in August of 2011, the pro forma agreement was completed and issued in customized format to each of the eligible groups who had indicated a readiness to receive and consider it.
The agreement provides for an early execution date of December 15, 2011, and a final execution date of May 31, 2012. Northern Gateway anticipates receiving counter executed agreements from some groups as of the early date and from others as of the final date. Northern Gateway has not yet received nor has Northern Gateway expected to receive executed copies to date.
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Northern Gateway Response to Federal Government IR No.1 Page 243 of 246 The list of the Aboriginal groups involved in the offering, as well as copies of the letters and Aboriginal Ownership Agreement documents, are not submitted at this time for reason of confidentiality in order to safeguard the identities of the Aboriginal counterparties involved, while they consider acceptance of the equity ownership offering.
Progress to Date of Other Elements of the Aboriginal Economic Opportunities Package:
In Q4/2010, Northern Gateway commenced the communication and distribution of its Aboriginal economic opportunities package in the form of a Benefits Binder to eligible Aboriginal groups. The Benefits Binder contained:
• An Aboriginal Benefits Fact Sheet • A Summary of Key Terms relative to the Aboriginal Ownership Agreement to be provided subsequent to the roll out of the Aboriginal economic opportunities package • A bar chart revealing the estimated Average Nominal Cash Distribution for each Aboriginal group and the assumptions upon which the estimation was based • Information on Aboriginal Procurement, Employment and Training benefits, with a spreadsheet indicating total targeted amounts to be spent on pipeline construction and station construction for the Project • A copy of a pro forma Memorandum of Understanding (MOU) on economic participation that when signed between the Aboriginal group and Northern Gateway would verify interest level and start the parties on a voluntary, collaborative process to evaluate business, employment and training opportunities and to explore potential joint venture and limited partnership opportunities with third parties • Information about the Project’s proposed Community Investment Fund which is to be provided 1% of Northern Gateway’s pre-tax profit throughout the life of the Project for certain types of projects to benefit communities along the proposed RoW • In coastal Aboriginal group binders, additional information was provided regarding marine services opportunities
As of the end of September 2011, 15 Aboriginal groups have signed Memoranda of Understanding (“MOUs”) or comparable instruments concerning economic participation relative to the Project.
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Northern Gateway Response to Federal Government IR No.1 Page 244 of 246
Aboriginal Consultation
118 Reference:
Preamble: The Federal Crown is relying, to the extent possible, upon the Joint Review Panel (JRP) process to fulfill its duty to consult with Aboriginal peoples. The federal government is of the view that many of the issues that will be considered by the JRP in satisfying its mandate (as set out in the JRP Agreement) may be directly and indirectly related to potential or established Aboriginal and treaty rights. The JRP process provides an effective and reasonable means of ensuring that Aboriginal groups can access and bring forward the best available information with respect to potential project impacts upon treaty and Aboriginal rights.
The primary sources of information respecting potential project impacts upon treaty and Aboriginal rights, including title, and other related interests must, of necessity, emanate from the Applicant and/or affected Aboriginal groups.
While the Federal Crown may have knowledge of treaty and Aboriginal rights it does not possess knowledge respecting potential project impacts independent of the information provided by the Applicant and/or Aboriginal groups. Therefore, in order to properly fulfill and discharge its overriding duty respecting Aboriginal consultation, the Federal Crown submits this Information Request to the Applicant.
Request: The Applicant's Section 52 Application and Updates identify numerous Aboriginal groups that are potentially impacted by the project. In a very general manner, the Application and Updates reference discussions with those Aboriginal groups and potential mitigation approaches. Please provide more specific information for each Aboriginal group identified in the Section 52 Application and Updates, including but not limited to:
a. What are the specific issues and concerns raised by each Aboriginal group? b. What are the specific details of the Applicant's proposed mitigation plan to address issues and concerns raised by each Aboriginal group? c. Have the issues and concerns raised by each Aboriginal group been mutually resolved? o If so, please provide particular information regarding how each potential issue and concern has been addressed through mitigation, accommodation or otherwise. o If not, what issues and/or concerns remain outstanding?
Attached as Appendix B is a draft 'issues tracking chart' that may be used to satisfy this request.
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Northern Gateway Response to Federal Government IR No.1 Page 245 of 246 The Applicant's Section 52 Application and Updates indicate that some Aboriginal groups that are not otherwise identified in the Applicant's materials have raised issues and/or concerns that the project may impact upon their potential or established Aboriginal or Treaty rights or other related interests. Please identify each such Aboriginal group and provide more specific information, including but not limited to:
a. What are the specific issues and concerns raised by each Aboriginal group? b. What are the specific details of the Applicant's proposed mitigation plan to address issues and concerns raised by each Aboriginal group? c. Have the issues and concerns raised by each Aboriginal group been mutually resolved?
o If so, please provide particular information regarding how each potential issue or concern has been addressed through mitigation, accommodation or otherwise. o If not, what issues and/or concerns remain outstanding?
What is the current status of all Aboriginal Traditional Knowledge studies?
The Applicant has provided some information about spills and spill modeling. Please provide additional analysis of how Aboriginal groups may be impacted by spills. In particular, what are the related issues and concerns raised with respect to impacts upon potential or established Aboriginal or Treaty rights, and other related interests and what mitigation measures are proposed? Please ensure that the analysis includes:
a. marine hydrocarbon and condensate spills; and b. terrestrial hydrocarbon and condensate spills along the proposed pipeline route.
Response: In response to this request and a similar request made by the JRP (see Northern Gateway’s response to JRP IR 5.9), Northern Gateway has prepared a table that summarizes primary concerns and issues raised by Aboriginal groups along the proposed pipeline, as well as coastal First Nations; the mitigation measures proposed by those groups (where applicable); the standard or generally accepted mitigation measures that may be available to address such concerns or issues; whether the mitigation measures proposed by Northern Gateway have resolved such concerns or issues; and the status or need for further discussions. See Attachment JRP IR 5.9. Northern Gateway considers it important to emphasize that the table is intended for future review and updating, particularly as it relates to groups who have not yet completed ATK or traditional use studies containing specific mitigation measures as recommended by study participants. Northern Gateway also cautions that the list of concerns raised by Aboriginal groups was initiated in
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Northern Gateway Response to Federal Government IR No.1 Page 246 of 246 2002, when Northern Gateway first engaged Aboriginal groups in dialogue about the Project. Some of the issues and concerns may have taken on a different context or meaning since consultation began. Many of the Aboriginal groups have developed a more fulsome understanding of the Project through ongoing consultation with Northern Gateway and the completion and review of various studies and/or assessments. Consequently, certain issues and concerns may carry a higher or lesser degree of import currently than when they were first brought forward to Northern Gateway. It will be seen that where studies have been completed and specific concerns have been identified, these concerns can generally addressed through established mitigation measures and follow-up programs. Additional Information Regarding Spills and Spill Modeling The second part of the request seeks additional information regarding the effects of potential spills on the exercise of Aboriginal or treaty rights and mitigation measures proposed. Northern Gateway acknowledges concerns regarding potential spills among Aboriginal communities along the proposed route, and in coastal areas adjacent to shipping routes. Additional information regarding spill prevention, response and remediation is provided in many of the responses to Information Requests made by Aboriginal groups and environmental organizations elsewhere in the various Information Request filings. The effects of a spill in the terrestrial or marine environment would depend on a wide variety of factors, including spill location, volume, product composition, weather conditions and response effectiveness. Disruption of traditional use of resources affected by a spill would occur, and in some cases, effects on specific species could extend over a period of months or years. Protection of sensitive coastal areas would be a priority in marine response planning, and geographic response plans will also include a framework for ensuring that socio-economic effects would be properly addressed as part of a spill response. In response to the request for additional information on how potential spills might affect human and ecological health, including areas used for traditional purposes, Northern Gateway has commissioned human health and ecological risk assessments for a variety of locations along the proposed pipeline route. The hypothetical spill locations chosen will correspond to those considered in the Application (Volume 7B). Northern Gateway intends to have these additional assessments completed as soon as possible, and will provide them to the Federal Government and the JRP at that time.
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Attachment Federal Government IR 5A)
Enbridge Northern Gateway Project Kitimat Terminal - Site Selection Summary
Evaluation Criteria Site 1 Site 2 Site 3 Site 4
Suitability of the location for the tank Site within existing industrial complex, although it includes Site within existing industrial complex Site within existing industrial complex Site in area zoned for future industrial development terminal - existing land use planning a portion of a floodplain zoned for recreation.
Site generally underlain by shallow bedrock, with some compressible materials that are avoided with layout. Gentle gradient site underlain by thick deposits of Gentle gradient site underlain by thick deposits of Shallow rock will require grading to make suitable. The compressible materials which could settle under loads. compressible materials which could settle under loads. Area is underlain by shallow bedrock over most of the site. Suitability of the location for the tank elevation of the selected site is such that the in-situ civil Development would require extensive ground Development would require extensive ground Development would require extensive grading and terminal - foundation conditions materials (rock, earth, clays, etc.) are suitable for re-use on improvement and a complex foundation system. Risk of improvement and a complex foundation system. Risk of volumes would be greater than at Site 4. the site for the terminal construction, thereby reducing liquefaction and settlement may still exist. liquefaction and settlement may still exist. disposal volumes and the volume of materials to be shipped into the site
Location is in a wide channel providing safe manoeuvring room for berthing and unberthing operations. Harbour area near the berths provides a natural turning basin diameter of greater than 2,000 m. Berths can be designed so that Suitability of the location for the marine Site not suitable for marine berths. Berths would be Site not suitable for marine berths. Berths would be Site not suitable for marine berths. Berths would be vessels are aligned with the prevailing winds and currents berths located near Site 4. located near Site 4. located near Site 4. during final approach and while moored at the berths. Seabed slopes steeply downward from the shoreline, very large crude carrier (VLCC) class tankers can approach the berths.
Tank terminal is adjacent to marine berths and the 180 m Terminal Pipe Lengths (proximity of Additional linear infrastructure required to reach the berths. Additional linear infrastructure required to reach the berths. Additional linear infrastructure required to reach the berths. elevation difference between the tanks and berths tanks to berths) supports gravity loading of the oil.
Proximity to existing infrastructure Adjacent to the existing Rio Tinto Alcan site. Adjacent to the existing Rio Tinto Alcan site. Located within an existing industrial complex. Located the furthest from existing infrastructure.
Suitable road access Existing industrial road access exists. Existing industrial road access exists. Existing industrial road access exists. Site is accessed by existing industrial forestry access road.
Potential effects on watercourses, Site contains a small watercourse with marginal aquatic waterbodies, marine and aquatic Located adjacent to fish-bearing streams. Located adjacent to fish-bearing streams. Located adjacent to fish-bearing streams. habitat, is away from marine spawning areas, and is away vegetation and important fish areas from sensitive shorelines.
Existing forest disturbance in the area has removed up to Potential effects on terrestrial vegetation Existing disturbed industrial area, limited value as habitat Existing disturbed industrial area, limited value as habitat Existing disturbed industrial area, limited value as habitat 30% of mature forest cover. Avoids shorebird and wildlife habitat for sensitive wildlife. for sensitive wildlife. for sensitive wildlife. concentrations.
Potential effects on communities, Located relatively close to Kitimat residential area, Located relatively close to Kitimat residential area, and Located relatively close to Kitimat residential area. Is near Located the furthest of all sites from Kitimat residential landowners, land users and Aboriginal although slightly farther away than Site 1. Avoids partly includes a floodplain designated as recreational. to designated reserve lands. area. Avoids designated reserve lands. groups designated reserve lands. Avoids designated reserve lands.
Proximity to gentle terrain, streams and tidal estuary would Proximity to gentle terrain, streams and tidal estuary would Proximity to gentle terrain, streams and tidal estuary would Predominantly rocky shoreline will be less sensitive in the Potential effect on shoreline oiling increase the potential exposure to shoreline oiling in the increase the potential exposure to shoreline oiling in the increase the potential exposure to shoreline oiling in the event of accidental release of hydrocarbons. event of accidental release of hydrocarbons. event of accidental release of hydrocarbons. event of accidental release of hydrocarbons. Attachment Federal Government IR 13
1 of 3
Choose CAPP Forecast: R1=1 for Low forecast volumes and R1=2 for Growth forecast volumes. 2 Tables for text are in cols CW and on. Updated for March 2010 Muse Stancil final report. Checking at col DS WCSB Oil Production - CAPP Low Case, June 2009 WCSB Oil Production - CAPP Growth Case, June 2009
Conventional Oil Sands Total Conventional Oil Sands Total MuseStancil Oil Prices Oil and Natural Gas Prices, using Sproule's Differentials, without Gateway, but based on Muse Stancil WTI prices and exchange rates (constant $2009) 70% Yrs Ops Light and Heavy SCO Bit Blend Light and Heavy SCO Bit Blend Percent WTI Cushing WTI Pentanes + Edmonton Par SCO Cromer Medium Hardisty Bow River Hardisty-Lloyd WCSelect Hardisty Heavy Natural Gas Bit plus Bitumen Medium Medium Oilsands Muse Table A-5 40 API 32 API 29.3 API 24.9 API 20.5 API 20.5 API 12 API ratio to WTI 30% Constant $2009 (condensate) Blend Dilbit 11.13 Cond = WCS kbpd kbpd kbpd kbpd kbpd kbpd kbpd kbpd kbpd % kbpd FX Rate C$/Bbl US$/Bbl C$/Bbl C$/Bbl C$/Bbl C$/Bbl C$/Bbl C$/Bbl C$/Bbl C$/Bbl C$/Bbl C$/Mcf C$/Bbl C$/Bbl (Muse St avge) (ratio per Enb) 2007 571 382 623 835 2,411 2007 571 382 623 835 60.47% 2,411 2008 589 350 564 933 2,436 2008 589 350 564 933 61.45% 2,436 0.90 110.62 99.56 110.62 2009 582 323 701 972 2,578 2009 582 323 701 972 64.90% 2,578 0.92 67.01 61.65 67.01 67.07 65.49 67.60 62.21 59.59 57.63 57.63 55.66 6.02 57.63 53.58 2010 575 303 787 1050 2,715 2010 575 303 788 1,051 67.68% 2,717 0.91 80.43 73.19 80.43 80.61 78.71 81.06 73.99 70.84 68.48 68.48 66.12 7.23 68.48 63.28 2011 561 286 853 1099 2,799 2011 561 286 854 1,106 69.83% 2,807 0.90 84.36 75.92 84.36 84.61 82.61 84.98 76.00 72.70 68.57 68.57 66.09 7.58 68.57 61.69 2012 548 274 890 1138 2,850 2012 548 274 889 1,160 71.36% 2,871 0.89 87.29 77.69 87.29 87.58 85.52 87.90 77.82 74.40 70.13 70.13 66.70 7.84 70.13 62.64 2013 531 262 902 1224 2,919 2013 531 262 914 1,294 73.58% 3,001 0.88 89.02 78.34 89.02 89.41 87.30 89.60 78.57 75.08 70.71 70.71 66.35 8.00 70.71 62.70 2014 515 251 908 1336 3,010 2014 515 251 955 1,471 76.01% 3,193 0.87 90.95 79.13 90.95 91.36 89.21 91.51 80.29 76.72 72.26 72.26 67.80 8.17 72.26 64.07 2015 499 240 911 1371 3,021 2015 499 240 1,002 1,567 77.66% 3,309 0.86 92.94 79.93 92.94 93.38 91.18 93.48 82.06 78.41 73.85 73.85 69.29 8.35 73.85 65.49 1 2016 482 229 911 1395 3,017 2016 482 229 1,047 1,733 79.64% 3,491 0.85 94.98 80.73 94.98 95.44 93.19 95.50 83.87 80.14 75.48 75.48 70.82 8.53 75.48 66.93 2 2017 466 219 912 1407 3,004 2017 466 219 1,076 1,839 80.97% 3,600 0.85 95.93 81.54 95.93 96.42 94.14 96.43 84.73 80.96 76.26 76.26 71.55 8.62 76.26 67.62 3 2018 450 209 912 1418 2,989 2018 450 209 1,134 1,886 82.09% 3,679 0.85 96.89 82.36 96.89 97.40 95.11 97.37 85.60 81.79 77.04 77.04 72.28 8.71 77.04 68.31 4 2019 436 200 911 1424 2,971 2019 436 200 1,191 1,994 83.36% 3,821 0.85 97.87 83.19 97.87 98.40 96.08 98.33 86.48 82.63 77.83 77.83 73.02 8.79 77.83 69.01 5 2020 421 191 912 1431 2,955 2020 421 191 1,247 2,080 84.46% 3,939 0.85 98.85 84.02 98.85 99.38 97.04 99.31 87.34 83.46 78.60 78.60 73.75 8.88 78.60 69.70 6 2021 405 182 911 1440 2,938 2021 405 182 1,279 2,109 85.23% 3,975 0.85 99.85 84.87 99.85 100.39 98.02 100.31 88.22 84.30 79.40 79.40 74.50 8.97 79.40 70.40 7 2022 390 173 911 1447 2,921 2022 390 173 1,332 2,125 86.00% 4,021 0.85 100.85 85.72 100.85 101.40 99.01 101.32 89.11 85.15 80.19 80.19 75.24 9.06 80.19 71.11 8 2023 375 165 911 1451 2,902 2023 375 165 1,338 2,260 86.95% 4,137 0.85 101.86 86.58 101.86 102.41 100.00 102.33 90.00 86.00 81.00 81.00 76.00 9.15 81.00 71.82 9 2024 361 157 912 1456 2,886 2024 361 157 1,340 2,354 87.70% 4,212 0.85 102.88 87.45 102.88 103.44 101.00 103.36 90.90 86.86 81.81 81.81 76.76 9.24 81.81 72.54 10 2025 348 150 912 1458 2,868 2025 348 150 1,339 2,403 88.26% 4,240 0.85 103.92 88.33 103.92 104.48 102.02 104.40 91.82 87.74 82.64 82.64 77.54 9.34 82.64 73.27 11 2026 348 150 912 1,458 2,868 2026 348 150 1,339 2,403 88.26% 4,240 0.85 104.96 89.22 104.96 105.54 103.05 105.45 92.74 88.62 83.47 83.47 78.32 9.43 83.47 74.01 12 2027 348 150 912 1,458 2,868 2027 348 150 1,339 2,403 88.26% 4,240 0.85 106.01 90.11 106.01 106.59 104.08 106.51 93.67 89.51 84.30 84.30 79.10 9.52 84.30 74.75 13 2028 348 150 912 1,458 2,868 2028 348 150 1,339 2,403 88.26% 4,240 0.85 107.08 91.02 107.08 107.66 105.13 107.58 94.61 90.41 85.15 85.15 79.90 9.62 85.15 75.51 14 2029 348 150 912 1,458 2,868 2029 348 150 1,339 2,403 88.26% 4,240 0.85 108.15 91.93 108.15 108.74 106.18 108.66 95.56 91.31 86.00 86.00 80.70 9.72 86.00 76.26 15 2030 348 150 912 1,458 2,868 2030 348 150 1,339 2,403 88.26% 4,240 0.85 109.25 92.86 109.25 109.84 107.25 109.76 96.53 92.24 86.87 86.87 81.51 9.82 86.87 77.03 16 2031 348 150 912 1,458 2,868 2031 348 150 1,339 2,403 88.26% 4,240 0.85 109.25 92.86 109.25 109.84 107.25 109.76 96.53 92.24 86.87 86.87 81.51 9.82 86.87 77.03 17 2032 348 150 912 1,458 2,868 2032 348 150 1,339 2,403 88.26% 4,240 0.85 109.25 92.86 109.25 109.84 107.25 109.76 96.53 92.24 86.87 86.87 81.51 9.82 86.87 77.03 18 2033 348 150 912 1,458 2,868 2033 348 150 1,339 2,403 88.26% 4,240 0.85 109.25 92.86 109.25 109.84 107.25 109.76 96.53 92.24 86.87 86.87 81.51 9.82 86.87 77.03 19 2034 348 150 912 1,458 2,868 2034 348 150 1,339 2,403 88.26% 4,240 0.85 109.25 92.86 109.25 109.84 107.25 109.76 96.53 92.24 86.87 86.87 81.51 9.82 86.87 77.03 20 2035 348 150 912 1,458 2,868 2035 348 150 1,339 2,403 88.26% 4,240 0.85 109.25 92.86 109.25 109.84 107.25 109.76 96.53 92.24 86.87 86.87 81.51 9.82 86.87 77.03 21 2036 348 150 912 1,458 2,868 2036 348 150 1,339 2,403 88.26% 4,240 0.85 109.25 92.86 109.25 109.84 107.25 109.76 96.53 92.24 86.87 86.87 81.51 9.82 86.87 77.03 22 2037 348 150 912 1,458 2,868 2037 348 150 1,339 2,403 88.26% 4,240 0.85 109.25 92.86 109.25 109.84 107.25 109.76 96.53 92.24 86.87 86.87 81.51 9.82 86.87 77.03 23 2038 348 150 912 1,458 2,868 2038 348 150 1,339 2,403 88.26% 4,240 0.85 109.25 92.86 109.25 109.84 107.25 109.76 96.53 92.24 86.87 86.87 81.51 9.82 86.87 77.03 24 2039 348 150 912 1,458 2,868 2039 348 150 1,339 2,403 88.26% 4,240 0.85 109.25 92.86 109.25 109.84 107.25 109.76 96.53 92.24 86.87 86.87 81.51 9.82 86.87 77.03 25 2040 348 150 912 1,458 2,868 2040 348 150 1,339 2,403 88.26% 4,240 0.85 109.25 92.86 109.25 109.84 107.25 109.76 96.53 92.24 86.87 86.87 81.51 9.82 86.87 77.03 26 2041 348 150 912 1,458 2,868 2041 348 150 1,339 2,403 88.26% 4,240 0.85 109.25 92.86 109.25 109.84 107.25 109.76 96.53 92.24 86.87 86.87 81.51 9.82 86.87 77.03 27 2042 348 150 912 1,458 2,868 2042 348 150 1,339 2,403 88.26% 4,240 0.85 109.25 92.86 109.25 109.84 107.25 109.76 96.53 92.24 86.87 86.87 81.51 9.82 86.87 77.03 28 2043 348 150 912 1,458 2,868 2043 348 150 1,339 2,403 88.26% 4,240 0.85 109.25 92.86 109.25 109.84 107.25 109.76 96.53 92.24 86.87 86.87 81.51 9.82 86.87 77.03 29 2044 348 150 912 1,458 2,868 2044 348 150 1,339 2,403 88.26% 4,240 0.85 109.25 92.86 109.25 109.84 107.25 109.76 96.53 92.24 86.87 86.87 81.51 9.82 86.87 77.03 30 2045 348 150 912 1,458 2,868 2045 348 150 1,339 2,403 88.26% 4,240 0.85 109.25 92.86 109.25 109.84 107.25 109.76 96.53 92.24 86.87 86.87 81.51 9.82 86.87 77.03
Year Differentials from WTI C$/Bbl 2009 0.06 -1.52 0.59 -4.80 -7.42 -9.38 -9.38 -11.35 2010 0.19 -1.71 0.64 -6.44 -9.59 -11.95 -11.95 -14.31 2011 0.25 -1.74 0.62 -8.35 -11.66 -15.79 -15.79 -18.27 2012 0.29 -1.77 0.61 -9.47 -12.89 -17.17 -17.17 -20.59 2013 0.38 -1.72 0.57 -10.45 -13.95 -18.31 -18.31 -22.68 2014 0.41 -1.74 0.56 -10.67 -14.23 -18.69 -18.69 -23.15 2015 0.44 -1.77 0.54 -10.88 -14.53 -19.09 -19.09 -23.65 2016 0.46 -1.79 0.52 -11.11 -14.83 -19.49 -19.49 -24.15 2017 0.49 -1.79 0.50 -11.20 -14.97 -19.67 -19.67 -24.38 2018 0.51 -1.79 0.48 -11.30 -15.10 -19.86 -19.86 -24.61 2019 0.53 -1.79 0.46 -11.40 -15.24 -20.04 -20.04 -24.85 2020 0.54 -1.80 0.46 -11.51 -15.39 -20.24 -20.24 -25.09 2021 0.54 -1.82 0.47 -11.63 -15.55 -20.45 -20.45 -25.35 2022 0.55 -1.84 0.47 -11.74 -15.70 -20.65 -20.65 -25.60 2023 0.55 -1.86 0.48 -11.86 -15.86 -20.86 -20.86 -25.86 2024 0.56 -1.88 0.48 -11.98 -16.02 -21.07 -21.07 -26.12 2025 0.57 -1.90 0.48 -12.10 -16.18 -21.28 -21.28 -26.38 2026 0.57 -1.92 0.49 -12.22 -16.34 -21.50 -21.50 -26.65 2027 0.58 -1.94 0.49 -12.34 -16.51 -21.71 -21.71 -26.91 2028 0.58 -1.95 0.50 -12.47 -16.67 -21.93 -21.93 -27.19 2029 0.59 -1.97 0.50 -12.59 -16.84 -22.15 -22.15 -27.46 2030 0.59 -1.99 0.51 -12.72 -17.01 -22.37 -22.37 -27.74 2031 0.59 -1.99 0.51 -12.72 -17.01 -22.37 -22.37 -27.74 2032 0.59 -1.99 0.51 -12.72 -17.01 -22.37 -22.37 -27.74 2033 0.59 -1.99 0.51 -12.72 -17.01 -22.37 -22.37 -27.74 2034 0.59 -1.99 0.51 -12.72 -17.01 -22.37 -22.37 -27.74 2035 0.59 -1.99 0.51 -12.72 -17.01 -22.37 -22.37 -27.74 2036 0.59 -1.99 0.51 -12.72 -17.01 -22.37 -22.37 -27.74 2037 0.59 -1.99 0.51 -12.72 -17.01 -22.37 -22.37 -27.74 2038 0.59 -1.99 0.51 -12.72 -17.01 -22.37 -22.37 -27.74 2039 0.59 -1.99 0.51 -12.72 -17.01 -22.37 -22.37 -27.74 2040 0.59 -1.99 0.51 -12.72 -17.01 -22.37 -22.37 -27.74 2041 0.59 -1.99 0.51 -12.72 -17.01 -22.37 -22.37 -27.74 2042 0.59 -1.99 0.51 -12.72 -17.01 -22.37 -22.37 -27.74 2043 0.59 -1.99 0.51 -12.72 -17.01 -22.37 -22.37 -27.74 2044 0.59 -1.99 0.51 -12.72 -17.01 -22.37 -22.37 -27.74 2045 0.59 -1.99 0.51 -12.72 -17.01 -22.37 -22.37 -27.74 Attachment Federal Government IR 13
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SYNTHETIC CRUDE OIL, plus Conv Light + Med (constant $2009) BIT BLEND & HEAVY OIL (constant $2009) AVERAGE PRICES Gateway Export Revenues SCO Netbacks versus WTI Potential Price Uplift Revenue Gain SCO + Light+Med Heavy Oil Netbacks versus WTI Potential PriceUplift Revenue Gain Heavy & Blend Volumes ex Gateway Base Prices Split to Padd 5 Average Without With from March 2010, Muse Stancil Report, from March 2010 Muse Stancil Report, (versus China) Prices after Uplifts Price Price Increase Without Gateway With Gateway Table A 18, Gross Uplifts. SCO plus Conventional Light & Med Without Gateway With Gateway Table A 16, Gross Uplifts. Bit Blend plus Conventional Heavy (after split) Uplifts Uplifts Avge China etc Avge China etc Avge China etc SCO Dilbit SCO Dilbit Cond Bitumen SCO Dilbit SCO Dilbit Cond Bitumen PADD 2 PADD 3 PADD 5 China Singapore Conv L+M Conv L+M SCO SCO Conv L+M SCO PADD 2 PADD 3 PADD 5 China Singapore Heavy and Blend C$/Bbl C$/Bbl C$/Bbl C$/Bbl C$/Bbl C$/Bbl US$/Bbl C$/Bbl US$/Bbl C$million C$million C$/Bbl C$/Bbl C$/Bbl C$/Bbl C$/Bbl C$/Bbl US$/Bbl C$million US$mil kbpd kbpd C$/Bbl C$/Bbl C$/Bbl C$/Bbl % % C$/Bbl C$/Bbl C$/Bbl C$/Bbl C$million C$million C$million %
(gets Blend uplift)
0 0 0 67.60 57.63 67.07 53.58 0.00% 0.00% 67.60 57.63 67.07 53.58 0 0 0 0 0 0 81.06 68.48 80.61 63.28 0.00% 0.00% 81.06 68.48 80.61 63.28 0 0 0 0 0 0 84.98 68.57 84.61 61.69 0.00% 0.00% 84.98 68.57 84.61 61.69 0 0 0 0 0 0 87.90 70.13 87.58 62.64 0.00% 0.00% 87.90 70.13 87.58 62.64 0 0 0 0 0 0 89.60 70.71 89.41 62.70 0.00% 0.00% 89.60 70.71 89.41 62.70 0 0 0 0 0 0 91.51 72.26 91.36 64.07 0.00% 0.00% 91.51 72.26 91.36 64.07 0 0 0 0 0 0 93.48 73.85 93.38 65.49 0.00% 0.00% 93.48 73.85 93.38 65.49 0 0 0 1.34 1.14 1.96 1.67 236 751 2.56 2.18 1,837 1,561 200 300 95.50 75.48 95.44 66.93 0.00% 0.00% 97.47 78.05 95.44 70.60 15,237 15,661 424 2.78% 1.26 1.07 2.16 1.84 214 850 2.85 2.42 2,139 1,818 200 300 96.43 76.26 96.42 67.62 0.00% 0.00% 98.60 79.10 96.42 71.68 15,389 15,859 470 3.05% 1.31 1.11 2.68 2.28 214 1,110 3.39 2.88 2,591 2,203 200 300 97.37 77.04 97.40 68.31 0.00% 0.00% 100.06 80.43 97.40 73.15 15,544 16,111 567 3.65% 0.26 0.22 2.46 2.09 41 1,069 3.12 2.65 2,497 2,122 200 300 98.33 77.83 98.40 69.01 0.00% 0.00% 100.79 80.95 98.40 73.46 15,700 16,221 521 3.32% 0.58 0.49 2.67 2.27 89 1,215 3.51 2.98 2,907 2,471 200 300 99.31 78.60 99.38 69.70 0.00% 0.00% 101.98 82.11 99.38 74.71 15,857 16,436 579 3.65% 0.68 0.58 2.80 2.38 101 1,307 3.68 3.13 3,079 2,617 200 300 100.31 79.40 100.39 70.40 0.00% 0.00% 103.11 83.08 100.39 75.66 16,017 16,625 608 3.79% 0.67 0.57 2.69 2.29 95 1,310 3.47 2.95 2,912 2,475 200 300 101.32 80.19 101.40 71.11 0.00% 0.00% 104.01 83.67 101.40 76.07 16,178 16,754 577 3.56% 0.36 0.31 2.25 1.91 50 1,097 3.45 2.93 3,051 2,593 200 300 102.33 81.00 102.41 71.82 0.00% 0.00% 104.58 84.45 102.41 76.75 16,340 16,881 541 3.31% 0.33 0.28 1.99 1.69 43 973 3.65 3.10 3,343 2,841 200 300 103.36 81.81 103.44 72.54 0.00% 0.00% 105.35 85.46 103.44 77.75 16,504 17,048 544 3.30% -0.01 -0.01 2.00 1.70 -1 978 4.60 3.91 4,287 3,644 200 300 104.40 82.64 104.48 73.27 0.00% 0.00% 106.40 87.24 104.48 79.85 16,670 17,320 650 3.90% 0.45 0.39 2.31 1.96 58 1,129 3.52 2.99 3,282 2,789 200 300 105.45 83.47 105.54 74.01 0.00% 0.00% 107.76 86.99 105.54 79.04 16,838 17,392 554 3.29% 0.45 0.39 2.31 1.96 58 1,129 3.52 2.99 3,282 2,789 200 300 106.51 84.30 106.59 74.75 0.00% 0.00% 108.82 87.82 106.59 79.78 17,006 17,560 554 3.26% 0.45 0.39 2.31 1.96 58 1,129 3.52 2.99 3,282 2,789 200 300 107.58 85.15 107.66 75.51 0.00% 0.00% 109.89 88.67 107.66 80.54 17,178 17,732 554 3.23% 0.45 0.39 2.31 1.96 58 1,129 3.52 2.99 3,282 2,789 200 300 108.66 86.00 108.74 76.26 0.00% 0.00% 110.97 89.53 108.74 81.29 17,349 17,904 554 3.19% 0.45 0.39 2.31 1.96 58 1,129 3.52 2.99 3,282 2,789 200 300 109.76 86.87 109.84 77.03 0.00% 0.00% 112.07 90.40 109.84 82.06 17,525 18,079 554 3.16% 0.45 0.39 2.31 1.96 58 1,129 3.52 2.99 3,282 2,789 200 300 109.76 86.87 109.84 77.03 0.00% 0.00% 112.07 90.40 109.84 82.06 17,525 18,079 554 3.16% 0.45 0.39 2.31 1.96 58 1,129 3.52 2.99 3,282 2,789 200 300 109.76 86.87 109.84 77.03 0.00% 0.00% 112.07 90.40 109.84 82.06 17,525 18,079 554 3.16% 0.45 0.39 2.31 1.96 58 1,129 3.52 2.99 3,282 2,789 200 300 109.76 86.87 109.84 77.03 0.00% 0.00% 112.07 90.40 109.84 82.06 17,525 18,079 554 3.16% 0.45 0.39 2.31 1.96 58 1,129 3.52 2.99 3,282 2,789 200 300 109.76 86.87 109.84 77.03 0.00% 0.00% 112.07 90.40 109.84 82.06 17,525 18,079 554 3.16% 0.45 0.39 2.31 1.96 58 1,129 3.52 2.99 3,282 2,789 200 300 109.76 86.87 109.84 77.03 0.00% 0.00% 112.07 90.40 109.84 82.06 17,525 18,079 554 3.16% 0.45 0.39 2.31 1.96 58 1,129 3.52 2.99 3,282 2,789 200 300 109.76 86.87 109.84 77.03 0.00% 0.00% 112.07 90.40 109.84 82.06 17,525 18,079 554 3.16% 0.45 0.39 2.31 1.96 58 1,129 3.52 2.99 3,282 2,789 200 300 109.76 86.87 109.84 77.03 0.00% 0.00% 112.07 90.40 109.84 82.06 17,525 18,079 554 3.16% 0.45 0.39 2.31 1.96 58 1,129 3.52 2.99 3,282 2,789 200 300 109.76 86.87 109.84 77.03 0.00% 0.00% 112.07 90.40 109.84 82.06 17,525 18,079 554 3.16% 0.45 0.39 2.31 1.96 58 1,129 3.52 2.99 3,282 2,789 200 300 109.76 86.87 109.84 77.03 0.00% 0.00% 112.07 90.40 109.84 82.06 17,525 18,079 554 3.16% 0.45 0.39 2.31 1.96 58 1,129 3.52 2.99 3,282 2,789 200 300 109.76 86.87 109.84 77.03 0.00% 0.00% 112.07 90.40 109.84 82.06 17,525 18,079 554 3.16% 0.45 0.39 2.31 1.96 58 1,129 3.52 2.99 3,282 2,789 200 300 109.76 86.87 109.84 77.03 0.00% 0.00% 112.07 90.40 109.84 82.06 17,525 18,079 554 3.16% 0.45 0.39 2.31 1.96 58 1,129 3.52 2.99 3,282 2,789 200 300 109.76 86.87 109.84 77.03 0.00% 0.00% 112.07 90.40 109.84 82.06 17,525 18,079 554 3.16% 0.45 0.39 2.31 1.96 58 1,129 3.52 2.99 3,282 2,789 200 300 109.76 86.87 109.84 77.03 0.00% 0.00% 112.07 90.40 109.84 82.06 17,525 18,079 554 3.16% 0.45 0.39 2.31 1.96 58 1,129 3.52 2.99 3,282 2,789 200 300 109.76 86.87 109.84 77.03 0.00% 0.00% 112.07 90.40 109.84 82.06 17,525 18,079 554 3.16% 0.45 0.39 2.31 1.96 58 1,129 3.52 2.99 3,282 2,789 200 300 109.76 86.87 109.84 77.03 0.00% 0.00% 112.07 90.40 109.84 82.06 17,525 18,079 554 3.16%
Averages, 2016 to 2020 Averages, 2016 to 2020 avge 16 - 2 only 70% is Bit avge 16 - 20 0.95 2.39 ### 159 999 #DIV/0! 3.08 2.62 ##### 2,394 2,035 #DIV/0! 104.79 30% condensate 76.83 2440.5 ASSUMES Condensate 1571.25 is unchanged by uplifts 2094.95 Attachment Federal Government IR 13
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below for tables in the text - these numbers assume that the Gateway volumes are not incremental to the CAPP Growth Forecast. Updated for March 2010 Muse Stancil final report. Expected Net Revenue Benefits from Summary of Price Uplift Revenue Benefits Price Uplifts for Other Production Expected Price Uplifts for WCSB Other Production Price Uplifts for WCSB Other Production for WCSB Crude Oil Production and Sales CHECKING Conventional Oil Sands TOTAL Conventional Oil Sands TOTAL TOTAL Resulting from Gateway Project Other Production Other Production Other Production Checking against Muse Stancil Report Checking internal comsistency Uplifts Year Light and Heavy SCO Bit Blend Uplift Year Light and Heavy SCO Bit Blend Uplift Year Uplift (Net of costs to Canadian Refineries) Muse Table A 21 total total MINUS Net Net Other Gatew Total Medium Revenue per Bbl Medium Revenue per Bbl Gross Cost to Net Other Gateway rev uplift rev uplift Refins. Uplift Uplift Prod Prod Prod Benefits Refineries Benefits Sales Sales Total Net Uplifts pre Muse Diffs Diffs C$/Bbl C$/Bbl C$/Bbl C$/Bbl C$million C$/Bbl C$/Bbl C$/Bbl C$/Bbl C$/Bbl C$million C$/Bbl C$million US$million C$million C$million C$million C$million US$ mill Cdn$ mill shld be 0 refinery Cdn$ mill US$ mill US$ mill US$ mill Cdn$ mill Cdn$ mill Cdn$ mill Cdn$ mill shld be 0
2016 1.34 2.56 1.96 2.56 2,399 1.88 2016 2,399 492 1,821 2016 1,821 424 2246 1,905 2,242 4 24.10% 2,824 2,400 492 1,909 2,246 2,399 424 2,824 0 2017 1.26 2.85 2.16 2.85 2,733 2.08 2017 2,733 548 2,089 2017 2,089 470 2559 2,173 2,556 3 23.58% 3,203 2,723 548 2,175 2,559 2,733 470 3,203 0 2009 0.00 0.00 0.00 0.00 0 2018 1.31 3.39 2.68 3.39 3,349 2.49 2018 3,349 654 2,580 2018 2,580 567 3147 2,678 3,151 -4 22.96% 3,916 3,328 654 2,675 3,147 3,349 567 3,916 0 2010 0.00 0.00 0.00 0.00 0 2019 0.26 3.12 2.46 3.12 3,086 2.21 2019 3,086 564 2,423 2019 2,423 521 2944 2,501 2,942 1 21.48% 3,607 3,066 564 2,502 2,944 3,086 521 3,607 0 2011 0.00 0.00 0.00 0.00 0 2020 0.58 3.51 2.67 3.51 3,632 2.53 2020 3,632 637 2,882 2020 2,882 579 3461 2,945 3,465 -4 20.64% 4,211 3,579 637 2,942 3,461 3,632 579 4,211 0 2012 0.00 0.00 0.00 0.00 0 2021 0.68 3.68 2.80 3.68 3,879 2.67 2021 3,879 674 3,087 2021 3,087 608 3694 3,142 3,697 -2 20.43% 4,487 3,814 674 3,140 3,694 3,879 608 4,487 0 2013 0.00 0.00 0.00 0.00 0 2022 0.67 3.47 2.69 3.47 3,740 2.55 2022 3,740 645 2,982 2022 2,982 577 3559 3,027 3,561 -2 20.27% 4,317 3,670 645 3,025 3,559 3,740 577 4,317 0 2014 0.00 0.00 0.00 0.00 0 2023 0.36 3.45 2.25 3.45 3,656 2.42 2023 3,656 566 2,991 2023 2,991 541 3532 3,004 3,534 -1 18.20% 4,198 3,568 566 3,003 3,532 3,656 541 4,198 0 2015 0.00 0.00 0.00 0.00 0 2024 0.33 3.65 1.99 3.65 3,814 2.48 2024 3,814 574 3,139 2024 3,139 544 3684 3,130 3,682 1 17.70% 4,359 3,705 574 3,131 3,684 3,814 544 4,359 0 2016 1.34 2.56 1.96 2.56 2,399 1.88 2025 -0.01 4.60 2.00 4.60 4,613 2.98 2025 4,613 642 3,858 2025 3,858 650 4507 3,831 4,508 0 16.37% 5,263 4,473 642 3,831 4,507 4,613 650 5,263 0 2017 1.26 2.85 2.16 2.85 2,733 2.08 2026 0.45 3.52 2.31 3.52 3,914 2.53 2026 3,914 642 3,159 2026 3,159 554 3713 2018 1.31 3.39 2.68 3.39 3,349 2.49 2027 0.45 3.52 2.31 3.52 3,914 2.53 2027 3,914 642 3,159 2027 3,159 554 3713 2019 0.26 3.12 2.46 3.12 3,086 2.21 2028 0.45 3.52 2.31 3.52 3,914 2.53 2028 3,914 642 3,159 2028 3,159 554 3713 2020 0.58 3.51 2.67 3.51 3,632 2.53 2029 0.45 3.52 2.31 3.52 3,914 2.53 2029 3,914 642 3,159 2029 3,159 554 3713 2021 0.68 3.68 2.80 3.68 3,879 2.67 2030 0.45 3.52 2.31 3.52 3,914 2.53 2030 3,914 642 3,159 2030 3,159 554 3713 2022 0.67 3.47 2.69 3.47 3,740 2.55 2031 0.45 3.52 2.31 3.52 3,914 2.53 2031 3,914 642 3,159 2031 3,159 554 3713 2023 0.36 3.45 2.25 3.45 3,656 2.42 2032 0.45 3.52 2.31 3.52 3,914 2.53 2032 3,914 642 3,159 2032 3,159 554 3713 2024 0.33 3.65 1.99 3.65 3,814 2.48 2033 0.45 3.52 2.31 3.52 3,914 2.53 2033 3,914 642 3,159 2033 3,159 554 3713 2025 -0.01 4.60 2.00 4.60 4,613 2.98 2034 0.45 3.52 2.31 3.52 3,914 2.53 2034 3,914 642 3,159 2034 3,159 554 3713 2026 0.45 3.52 2.31 3.52 3,914 2.53 2035 0.45 3.52 2.31 3.52 3,914 2.53 2035 3,914 642 3,159 2035 3,159 554 3713 2027 0.45 3.52 2.31 3.52 3,914 2.53 2036 0.45 3.52 2.31 3.52 3,914 2.53 2036 3,914 642 3,159 2036 3,159 554 3713 2028 0.45 3.52 2.31 3.52 3,914 2.53 2037 0.45 3.52 2.31 3.52 3,914 2.53 2037 3,914 642 3,159 2037 3,159 554 3713 2029 0.45 3.52 2.31 3.52 3,914 2.53 2038 0.45 3.52 2.31 3.52 3,914 2.53 2038 3,914 642 3,159 2038 3,159 554 3713 2030 0.45 3.52 2.31 3.52 3,914 2.53 2039 0.45 3.52 2.31 3.52 3,914 2.53 2039 3,914 642 3,159 2039 3,159 554 3713 2031 0.45 3.52 2.31 3.52 3,914 2.53 2040 0.45 3.52 2.31 3.52 3,914 2.53 2040 3,914 642 3,159 2040 3,159 554 3713 2032 0.45 3.52 2.31 3.52 3,914 2.53 2041 0.45 3.52 2.31 3.52 3,914 2.53 2041 3,914 642 3,159 2041 3,159 554 3713 2033 0.45 3.52 2.31 3.52 3,914 2.53 2042 0.45 3.52 2.31 3.52 3,914 2.53 2042 3,914 642 3,159 2042 3,159 554 3713 2034 0.45 3.52 2.31 3.52 3,914 2.53 2043 0.45 3.52 2.31 3.52 3,914 2.53 2043 3,914 642 3,159 2043 3,159 554 3713 2035 0.45 3.52 2.31 3.52 3,914 2.53 2044 0.45 3.52 2.31 3.52 3,914 2.53 2044 3,914 642 3,159 2044 3,159 554 3713 2036 0.45 3.52 2.31 3.52 3,914 2.53 2045 0.45 3.52 2.31 3.52 3,914 2.53 2045 3,914 642 3,159 2045 3,159 554 3713 2037 0.45 3.52 2.31 3.52 3,914 2.53 2038 0.45 3.52 2.31 3.52 3,914 2.53 assumes CAPP Growth Forecast assumes CAPP Growth Forecast assumes CAPP Growth Forecast 2039 0.45 3.52 2.31 3.52 3,914 2.53 2040 0.45 3.52 2.31 3.52 3,914 2.53 Note: The refinery costs are from March 2010 Muse Stancil Table A 20 Checks OK with Avge 2041 0.45 3.52 2.31 3.52 3,914 2.53 The offset for refineries averages 20.6% in period to 2025 Muse Stancil Table A 21 20.57% 2042 0.45 3.52 2.31 3.52 3,914 2.53 and it gets smaller % over time as exports grow faster than 2043 0.45 3.52 2.31 3.52 3,914 2.53 domestic consumption of WCSB crude oil. 2044 0.45 3.52 2.31 3.52 3,914 2.53 2045 0.45 3.52 2.31 3.52 3,914 2.53
ASSUMES Light & Medium get the sco uplift Heavy gets the dilbit uplift sco gets the sco uplift Bit blend gets the Dilbit uplift MULTIPLIED BY THE PERCENTAGE AT TOP E.G. 100% IT ALL FLOWS THROUGH OR ZERO % NONE FLOWS THROUGH FROM GATEWAY EXPORTS UPLIFT TO OTHER PRODUCTION. Attachment Federal Government IR 19
Table 3. Estimated HADD values for High Risk Watercourse Crossings
Mean Scale of 2 Estimated HADD (m ) Channel Crossing Negative Name KP Width Flow Method Sensitivity Effects (m) (m3/s) Instream Riparian Total North 4.03 232.00 131.44 Open Cut 13.8 10.0 6960 900 7860 Saskatchewan River Paddle River 138.19 17.67 2.72 Isolate: Flume 13.0 7.0 370 900 1270
Sakwatamau River 200.37 38.67 1.67 Isolate: Flume 12.9 8.5 810 900 1710
Chickadee Creek 218.92 7.10 0.19 Isolate: Dam 13.3 8.0 150 900 1050 and Pump Two Creek 241.75 20.83 0.18 Isolate: Dam 13.4 8.0 440 900 1340 and Pump Little Smoky River 291.04 50.50 3.54 Isolate: Super 12.1 10.0 1060 900 1960 Flume Waskahigan River 318.18 13.47 0.12 Isolate: Dam 13.7 8.0 280 900 1180 and Pump Deep Valley Creek 338.78 40.00 0.74 Isolate: Dam 13.7 8.0 840 900 1740 and Pump Tributary to Deep 340.7 31.0 0.17 Isolate: Dam 13.5 8.0 650 900 1550 Valley Creek and Pump Latornell River 371.88 18.50 0.20 Isolate: Dam 13.4 8.0 390 900 1290 and Pump Big Mountain Creek 435.26 8.04 0.24 Isolate: Dam 13.7 6.0 170 900 1070 and Pump Bald Mountain 445.92 16.63 0.22 Isolate: Dam 11.5 8.0 350 900 1250 Creek and Pump Calahoo Creek 511.86 7.50 0.12 Isolate: Dam 13.2 6.0 160 900 1060 and Pump Missinka River 646.02 38.17 3.38 Open Cut 13.7 8.0 1150 900 2050 Attachment Federal Government IR 19
Name KP Mean Flow Crossing Sensitivity Scale of Channel (m3/s) Method Negative Estimated HADD (m2) Width Eff t Tributary to 808.93 5.20 0.28 Isolate: Dam 11.5 8.0 110 900 1010 Necoslie River and Pump Tributary to 24.5 1013.73 2.81 0.32 Isolate: Dam 13.6 7.0 60 900 960 Mile Creek and Pump Tributary to Gosnell 1055.86 1.39 0.41 Isolate: Dam 12.3 7.0 30 900 930 Creek and Pump Tributary to Gosnell 1057.38 3.83 1.53 Isolate: Flume 14.3 6.5 80 900 980 Creek Tributary to Gosnell 1060.48 8.25 0.91 Isolate: Dam 14.8 5.0 170 900 1070 Creek and Pump Tributary to Gosnell 1060.64 6.77 3.86 Isolate: Super 13.4 7.0 140 900 1040 Creek Flume Tributary to Kitimat 1102.32 5.05 1.03 Isolate: Flume 12.8 7.0 110 900 1010 River Deception Creek 1139.99 8.00 1.07 Isolate: Flume 13.0 6.5 170 900 1070
Tributary to Iron 1143.89 2.90 0.41 Isolate: Dam 13.4 7.0 60 900 960 Mine Creek and Pump Trout Creek 1147.10 7.17 1.58 Isolate: Flume 14.2 5.0 150 900 1050
Tributary to Kitimat 1154.52 13.58 2.08 Isolate: Super 12.5 7.0 290 900 1190 River Flume Duck Creek 1156.71 10.27 2.23 Isolate: Super 12.5 8.5 220 900 1120 Flume Anderson Creek 1163.76 26.63 1.71 Isolate: Flume 12.7 9.5 560 900 1460
Attachment Federal Government IR 19
Table 4. Estimated HADD Value for Medium-High Risk Watercourse Crossings
Mean Scale of 2 Estimated HADD (m ) Channel Crossing Negative Name KP Width Flow Method Sensitivity Effects (m) (m3/s) Instream Riparian Total South Redwillow 531.91 12.38 0.77 Isolate: Dam 10.4 8.0 260 900 1160 River and Pump Quintette Creek 575.14 9.63 0.34 Isolate: Dam 13.7 5.5 200 900 1100 and Pump Tributary to 650.06 7.18 0.24 Isolate: Dam 13.5 5.5 150 900 1050 Missinka River and Pump Chuchinka Creek 703.06 11.95 1.40 Isolate: Flume 10.6 8.0 250 900 1150
Maxan Creek 948.15 7.63 3.63 Isolate: Super 13.6 5.5 160 900 1060 Flume Tributary to Gosnell 1056.87 3.65 0.80 Isolate: Dam 13.8 5.0 80 900 980 Creek and Pump Tributary to Gosnell 1061.08 3.75 0.56 Isolate: Dam 13.8 5.0 80 900 980 Creek and Pump Tributary to Gosnell 1061.95 4.00 0.60 Isolate: Dam 13.8 5.0 80 900 980 Creek and Pump Tributary to Burnie 1067.86 1.67 0.64 Isolate: Dam 13.7 5.0 40 900 940 River and Pump Tributary to Kitimat 1097.12 1.00 0.41 Isolate: Dam 13.7 5.5 20 900 920 River and Pump Tributary to Cecil 1137.51 7.80 0.41 Isolate: Dam 13.6 5.0 160 900 1060 Creek and Pump Tributary to Kitimat 1151.44 2.68 0.41 Isolate: Dam 13.3 5.0 60 900 960 River and Pump Tributary to Kitimat 1151.72 3.20 0.52 Isolate: Dam 13.3 5.0 70 900 970 River and Pump Tributary to Goose 1156.03 5.73 0.41 Isolate: Dam 13.0 5.0 120 900 1020 Creek and Pump Attachment Federal Government IR 19
Table 5 - Estimated HADD Value for Medium Risk Watercourse Crossings
Mean Scale of 2 Estimated HADD (m ) Channel Crossing Negative Name KP Width Flow Method Sensitivity Effects (m) (m3/s) Instream Riparian Total Tributary to 216.0 5.7 0.02 Isolate: Dam 10.2 6.0 120 900 1020 Chickadee Creek and Pump Tributary to Two 238.4 14.7 0.01 Isolate: Dam 11.5 6.0 310 900 1210 Creeks and Pump Tributary to 328.7 6.0 0.02 Isolate: Dam 13.7 4.0 130 900 1030 Waskahigan River and Pump Tributary to 385.0 NA 0.02 Isolate: Dam 13.4 4.0 NA 900 900 Latornell River1 and Pump Patterson Creek 395.7 8.0 0.07 Isolate: Dam 13.7 4.0 170 900 1070 and Pump Tributary to Smoky 404.3 5.8 0.06 Isolate: Dam 12.4 4.0 120 900 1020 River and Pump Gold Creek 431.8 10.5 0.08 Isolate: Dam 10.4 6.0 220 900 1120 and Pump Hiding Creek 517.9 7.4 0.33 Isolate: Dam 11.7 6.0 150 900 1050 and Pump Angusmac Creek 710.4 16.7 1.90 Isolate: 11.3 7.0 Super 350 900 1250 Flume Tributary to Slender 737.4 1.2 0.25 Isolate: Dam 12.5 4.5 20 900 920 Lake and Pump Merton Creek at 739.2 11.1 0.65 Isolate: Dam 10.4 6.5 Slender Lake and Pump 230 900 1130 Confluence Tributary to Slender 740.5 16.5 0.24 Isolate: Dam 10.6 6.5 350 900 1250 Lake and Pump Attachment Federal Government IR 19
Name KP Mean Flow Crossing Sensitivity Scale of Channel (m3/s) Method Negative Estimated HADD (m2) Width Eff t Tributary to 853.6 19.0 0.13 Isolate: Dam 10.8 6.5 400 900 1300 Sutherland River and Pump Sutherland River 856.2 7.7 0.60 Isolate: Dam 11.7 6.0 160 900 1060 and Pump Tributary to Taltapin 896.7 0.8 0.14 Isolate: Dam 10.5 6.5 20 900 920 Lake and Pump Klo Creek 975.3 11.2 3.44 Isolate: 10.6 6.5 Super 230 900 1130 Flume Cedric Creek 1025.7 5.5 0.67 Isolate: Dam 11.6 5.0 120 900 1020 and Pump Tributary to Gosnell 1047.5 NA 0.10 Isolate: Dam 11.0 5.0 NA 900 900 Creek1 and Pump Tributary to Gosnell 1048.9 2.2 0.05 Isolate: Dam 14.7 3.0 50 900 950 Creek and Pump Tributary to Gosnell 1059.2 1.5 0.41 Isolate: Dam 12.4 5.0 30 900 930 Creek and Pump Tributary to Gosnell 1061.5 0.9 0.95 Isolate: Dam 12.9 5.0 20 900 920 Creek and Pump Tributary to Gosnell 1065.4 1.4 0.41 Isolate: Dam 11.7 7.0 30 900 930 Creek and Pump Tributary to Burnie 1066.9 1.7 1.85 Isolate: 11.2 6.5 40 900 940 River Flume Tributary to Burnie 1067.1 1.4 0.46 Isolate: Dam 9.6 7.0 30 900 930 River and Pump Tributary to Kitimat 1105.0 7.5 1.37 Isolate: 12.8 5.0 160 900 1060 River Flume Tributary to Kitimat 1161.0 7.2 1.00 Isolate: 11.7 7.0 150 900 1050 River Flume 1 Flooded wetland, channel measurement undetermined at time of survey. HADD values undetermined at this time.
Attachment Federal Government IR 19
Table 6 - Estimated HADD Value for Medium-Low Risk Watercourse Crossings
Mean Scale of 2 Estimated HADD (m ) Channel Crossing Negative Name KP Width Flow Method Sensitivity Effects (m) (m3/s) Instream Riparian Total Kinuseo Creek 2.7 0.19 Isolate: Dam 13.7 3.5 561.46 and Pump 60 900 960
Kinuseo Creek 4.9 0.88 Isolate: Dam 13.7 3.5 566.00 and Pump 100 900 1000
Tributary to 2.7 0.02 Isolate: Dam 13.4 3.5 Hominka River 624.08 and Pump 60 900 960
Tributary to 3.7 0.02 Isolate: Dam 13.7 3.5 Missinka River 641.66 and Pump 80 900 980
Tributary to 4.9 0.04 Isolate: Dam 13.8 3.5 Missinka River 643.85 and Pump 100 900 1000
Tributary to 3.7 0.04 Isolate: Dam 12.7 3.5 Missinka River 654.16 and Pump 80 900 980
Tributary to 4.2 0.12 Isolate: Dam 10.4 5.5 Wichcika Creek 677.95 and Pump 90 900 990
Tributary to 9.0 0.50 Isolate: Dam 11.5 4.5 Teardrop Lake 768.46 and Pump 190 900 1090
Tributary to Great 6.8 0.59 Isolate: Dam 11.6 4.5 Beaver Lake 774.23 and Pump 140 900 1040
Tributary to Great 5.0 0.34 Isolate: Dam 11 4.5 Beaver Lake 785.86 and Pump 110 900 1010 Attachment Federal Government IR 19
Name KP Mean Flow Crossing Sensitivity Scale of Channel (m3/s) Method Negative Estimated HADD (m2) Tributary to Pinkut 1.7W idth 0.20 Isolate: Dam 9.8 6.5Eff t
Creek 903.87 and Pump 40 900 940
Sauls Creek 1.4 0.37 Isolate: Dam 10.6 5 926.49 and Pump 30 900 930
Foxy Creek 4.9 0.81 Isolate: Dam 13.8 3.5 960.46 and Pump 100 900 1000
Foxy Creek 3.9 0.35 Isolate: Dam 13.7 3.5 964.52 and Pump 80 900 980
Tributary to Klo 2.2 0.17 Isolate: Dam 13.7 3.5 Creek 978.19 and Pump 50 900 950
Tributary to Buck 3.3 0.34 Isolate: Dam 7.4 7 Creek 981.54 and Pump 70 900 970
Tributary to Fenton 2.2 0.27 Isolate: Dam 13.7 3.5 Creek 1007.59 and Pump 50 900 950
Fenton Creek 3.2 0.31 Isolate: Dam 13.8 3.5 1007.78 and Pump 70 900 970
24.5 Mile Creek 3.8 0.57 Isolate: Dam 13.6 3.5 1013.47 and Pump 80 900 980
Tributary to 2.5 0.10 Isolate: Dam 13.8 3.5 Lamprey Creek 1017.42 and Pump 50 900 950
Tributary to Gosnell 2.7 0.03 Isolate: Dam 13.6 3 Creek 1047.42 and Pump 60 900 960 Attachment Federal Government IR 19
Name KP Mean Flow Crossing Sensitivity Scale of Channel (m3/s) Method Negative Estimated HADD (m2) Tributary to Gosnell 3.0W idth 0.07 Isolate: Dam 13.5 3 Eff t
Creek 1049.65 and Pump 60 900 960
Tributary to Gosnell 1.1 0.03 Isolate: Dam 13.8 3 Creek 1051.75 and Pump 20 900 920
Tributary to Gosnell 1.5 0.03 Isolate: Dam 12.8 3 Creek 1051.80 and Pump 30 900 930
Tributary to Kitimat 2.4 0.41 Isolate: Dam 13.4 3.5 River 1111.80 and Pump 50 900 950
Tributary to Kitimat 3.0 0.41 Isolate: Dam 13.5 3.5 River 1118.34 and Pump 60 900 960
Tributary to Kitimat 2.3 0.41 Isolate: Dam 13.5 3.5 River 1161.87 and Pump 50 900 950
Tributary to Kitimat 1.8 0.41 Isolate: Dam 12.7 3.5 River 1162.08 and Pump 40 900 940
Tributary to Kitimat 3.3 0.41 Isolate: Dam 10.5 5.5 Estuary 1165.95 and Pump 70 900 970
Attachment Federal Government IR 23
Draft Mitigation Measures for Watercourse Crossings
Crossing Method Mitigation Measures All Crossings Regulatory requirements
The design and construction of the Project will comply with applicable federal and provincial policies for the protection of water resources, and appropriate mitigation techniques will be employed during construction and operations of the Project. Applicable legislation, codes of practice and guidelines include:
• The Fisheries Act, Government of Canada • The Navigable Waters Protection Act, Government of Canada • The Water Act, Province of Alberta • The Water Act, Province of British Columbia • Code of Practice for Pipelines and Telecommunication Lines Crossing a Water Body (Alberta Environment 2001b, Internet site) • Code of Practice for Watercourse Crossings (Alberta Environment 2001c, Internet site) • Code of Practice for the Temporary Diversion of Water for Hydrostatic Testing, Province of Alberta (Alberta Environment 2001a, Internet site) • Pipeline Associated Watercourse Crossings (CAPP 2005) • The Forest Practices Code of British Columbia Act
Design
Design watercourse crossings for placement below the 1:100 year scour depth of the channel, unless otherwise directed. The pipeline sagbends will be set back sufficiently from the tops-of-bank to limit the risk the pipelines could be exposed to because of lateral channel movement. This may involve deep burial of the pipelines some distance beyond the top-of-bank line on either or both sides of the channel, as assessed by a qualified engineer.
For the burial design across alluvial fans, consider the potential for sudden channel avulsions and debris flows, which may require additional depth of cover over an extended pipeline reach.
For crossings of degrading channels, consider the potential for future downcutting will be taken into account in assessing pipe cover requirements.
Specific fisheries habitat protection measures will be shown on the construction drawings, environmental alignment sheets.
Vehicle Crossings
Vehicle and equipment watercourse crossings will comply with all federal and provincial
ENB LL 23751195
Attachment Federal Government IR 23
Crossing Method Mitigation Measures acts, regulations and codes of practice. The crossing method selected, construction and corresponding mitigation measures will follow DFO operational statements and provincial guidelines and best practices, where practical, otherwise the appropriate provincial and federal agencies will be consulted beforehand for the necessary approvals and authorizations.
The decision process for installing all vehicle watercourse crossings will meet federal and provincial requirements, and will consider the duration of use and the potential effects on fish and fish habitat.
Access at watercourse crossings will be managed through specific crossing techniques for clearing, construction and operations.
All installations will be appropriate for the sensitivity of the watercourse, the frequency of use and type of equipment.
All temporary bridges and vehicle support installations will be removed, and the surrounding areas will be restored when construction is complete.
Installing and removing vehicle watercourse crossings for access roads will be completed within DFO-approved work windows
Deleterious Substances
Pre-cast structures will be used, wherever practical.
All works involving the use of concrete, cement, mortars, and other Portland cement or lime-containing construction materials, will not deposit, directly or indirectly, any sediments, debris, concrete, concrete fines, wash water or contact water into or about any watercourse.
Releases of sediments, debris, concrete fines, wash or contact water will be reported immediately, as indicated in the Spill Contingency Plan (see Section A.2.1). If possible, the materials will be removed from the water immediately and emergency mitigation and cleanup measures implemented.
All fuelling, servicing or washing of mobile construction equipment will occur at least 30 m from all watercourse crossings, to limit the potential for water pollution.
Riparian Areas
Riparian areas adjacent to watercourses will be protected so that aquatic habitats are not adversely affected.
For construction activities adjacent to, or across, fish-bearing watercourses, a buffer zone of 16 m will be established.
Removal of vegetation and construction activities within the buffer zone will be limited.
ENB LL 23751195
Attachment Federal Government IR 23
Crossing Method Mitigation Measures The edge of the riparian buffer zone will be flagged before any site disturbance activities occur.
For a pipeline crossing of a watercourse, any extra temporary workspace will be located outside the buffer zone, and that portion of the buffer zone will not be cleared. However, site-specific topographic conditions, complex isolated crossings and trenchless crossings may require extra temporary workspace within the buffer zone. In this case, the location, size and time of clearing of the extra temporary workspace will require approval from the environmental inspector.
The size of any extra temporary workspace will be kept to the minimum necessary to conduct the work safely.
Clearing and Grading
Clearing and grading will be restricted to the minimum necessary to safely complete the work.
Clearing watercourse approach slopes and banks will be postponed until immediately before crossing construction except, if required, to install vehicle crossing structures. Where earlier clearing is approved by the environmental inspector, the vegetative ground mat and root structure will be left intact.
Trees will be felled away from watercourses and away from the limits of the RoW, to limit damage to watercourse banks, beds and adjacent trees. Hand clearing will be conducted, if necessary to limit disturbance. Trees, debris and soil inadvertently deposited within the high watermark will be removed in a way that limits disturbance of the bed and banks.
Grubbing will be restricted to the trench line, areas requiring grading and workside areas, where necessary, so that equipment can pass safely.
Erosion control will be implemented as soon as possible after riparian vegetation removal.
At fish-bearing watercourses, a Riparian Management Zone of 30 m will be established.
Habitat protection measures within this zone will include the following: • Measures to limit ground disturbance in riparian areas, which may include: • hand felling on steep slopes • trees being cabled skidded to piles located outside the Riparian Management zone. • Measures to limit erosion in riparian areas, grading, soil replacement and erosion controls • Riparian areas will be seeded as soon after construction as possible and shrubs will be planted as required. • Large woody debris will be incorporated into selected riparian reclamation plans in order to provide wildlife habitat and to limit access.
ENB LL 23751195
Attachment Federal Government IR 23
Crossing Method Mitigation Measures
All Trenched Sediment Control Crossings Temporary silt fences will be installed in areas where surface runoff might transport fines and silts to watercourses. Sediment interceptor methods will be used during construction as a contingency method, and will remain in place at the banks of the watercourse as a long- term mitigation measure.
Appropriate construction procedures will be undertaken for aquatic habitat preservation and restoration. Run-off barriers such as silt fencing, berms, boulder breaks, rock check dams and woven geotextile fabric silt fence, will be installed around disturbed areas and soil stockpile sites, as required, to prevent the transfer of sediments into watercourses.
Cross-ditches and diversion berms will be constructed on steep disturbed slopes, to divert surface runoff from the RoW and into well-vegetated areas away from watercourses.
As appropriate, surface imprinting such as cat tracking or straw crimping will be implemented as a runoff control measure on selected approach slopes. On steep erosion- prone approach slopes, erosion control matting or other suitable techniques will be considered.
Contingency materials such as bypass pumps, sandbags, polyethylene sheets, straw bales and silt fence materials will be used to intercept overland flow and trap suspended solids.
Disturbed areas may be reseeded as soon as they are no longer required for project access or other purposes. The approved seed mixture may include a cover crop to prevent surface erosion.
A qualified professional will determine the type, design and placement of instream sediment controls.
Instream sediment controls will be designed to reduce water velocities and allow suspended materials to settle.
Where approved by the environmental inspector, in consultation with a hydrotechnical engineer, instream filter berms constructed using non-woven geotextile fabric may be used combined with shot rock, crushed rock, or check dams.
Sediment mats will be used to trap large amounts of bedload and suspended sediment. The mats will be removed after construction, but biodegradable mats can be used during bank restoration.
Instream controls will be installed before construction begins.
Sediment control structures will be maintained during construction, and will include: • reinstalling and replacing structures, where necessary • removing accumulated sediment (disposing of sediments where they will not re- enter a water body)
ENB LL 23751195
Attachment Federal Government IR 23
Crossing Method Mitigation Measures
Unless otherwise determined, instream controls will be removed before spring freshet if they are used through winter; if they are used during fall, they will be removed before freeze-up.
Trench breakers will be installed to force bellhole seepage along the pipeline trench to the surface on steep slopes.
Trench breakers will be constructed of sandbags, bentonite mixed with local soils, urethane foam, or other compacted impervious materials..
The locations for trench breakers will be determined by on-site investigation, considering the potential for subsurface flow, erodibility of backfill material, and degree of slope. Geotechnical input will be provided in areas prone to instability.
The location of the trench breaker will be marked before backfilling.
Trench breakers will be installed adjacent to watercourses, at edges of wetlands and on other similar sites where unconsolidated backfill or organic materials are prone to washing out.
Underwater blasting
Where underwater blasting is required, the activity will be conducted according to DFO Guidelines for Using Explosives in or Near Canadian Fisheries Waters (Wright and Hopky 1998). These guidelines indicate the setback distances and threshold of instantaneous pressure changes with peak particle velocities that are required to protect fish from the effects of detonations in and near water. If the guidelines cannot be followed for any reason, a Section 32 authorization will be obtained from DFO.
No explosive is to be detonated in or near fish habitat that produces, or is likely to produce, an instantaneous pressure change (i.e., overpressure) greater than 100 kPa (14.5 psi) in the swimbladder of a fish.
Silt curtains will be placed strategically during blasting, to limit the dispersion and duration of suspended sediments, and limit sedimentation effects on sensitive species.
All blasts will be designed and approved by a certified and project-authorized blaster and will be designed in a way that limits the risk to fish or fish habitat.
The sediment plume generated during blasting will be monitored at distances to be established through consultation with DFO, to confirm that levels meet British Columbia water quality guidelines for total suspended solids and turbidity.
Watercourse monitoring
The watercourse monitoring plan will document:
• locations of sampling transects upstream and downstream of the watercourse
ENB LL 23751195
Attachment Federal Government IR 23
Crossing Method Mitigation Measures crossing • sampling depths • sampling frequency and duration
The information will be collected by a qualified specialist.
The environmental inspector will implement the watercourse monitoring plan at selected watercourse crossings with high fisheries values
During construction, the specialist will frequently inform the environmental inspection staff of the results, and provide advice about the significance of the information. The environmental inspection staff will use the information to maintain or modify the construction activities, in cooperation with the craft inspection staff and the contractor.
Monitoring information will be shared with regulatory authorities upon request, or when a problem is identified.
Communication will be maintained between the environmental inspector and construction manager during the water quality monitoring program, to confirm that sediment monitoring is completed in a professionally and safely, and that the data collected meets or exceeds the requirements of Northern Gateway and regulatory agencies.
The environmental inspector will participate in a preconstruction start-up meeting with the construction team. Northern Gateway representatives will review monitoring plans and schedules and discuss procedures for handling high sediment loads.
A construction briefing will be held for each watercourse crossing, to describe the potential effects of the sediment monitoring criteria on construction activities, and to comply with regulatory approvals.
Watercourse Reclamation
Watercourse reclamation will generally occur as soon as practical after construction. Additional reclamation works may be done in response to post-construction monitoring.
Northern Gateway will implement the following general practices, where appropriate:
• All sites will be reclaimed to a state comparable to that existing before the work. • Watercourse bed and banks will be recontoured and restored as closely as possible to the preconstruction profile to maintain long-term bank stability. The natural sinuosity, depth, width and thalweg of the watercourse will be maintained, where appropriate. • Gravel and cobble substrates will be salvaged before trenching, and replaced as part of restoration. • Instream cover features, such as large woody debris and boulders, will be salvaged before trenching, and replaced as part of restoration, subject to hydrotechnical review.
ENB LL 23751195
Attachment Federal Government IR 23
Crossing Method Mitigation Measures • Instream restoration of a watercourse will occur in isolation of the flow, to the extent possible. • The watercourse bed and banks will be stabilized and reclaimed after backfill of the trench, unless otherwise directed. Stabilization is required until complete watercourse reclamation can be implemented. This could depend on the construction schedule, access removal, time of year and weather conditions. • Existing cover provided by undercut banks or overhanging vegetation will be re- established, or habitat enhancement techniques used, as specified by Northern Gateway. • At specified watercourse crossings, disturbed portions of the watercourse bed will be capped with channel liner, clean granular material or clean rock. • Prominent drainage patterns along approach slopes will be returned to a condition that approximates preconstruction, by matching the existing drainage patterns in adjacent undisturbed areas: • The RoW will be graded to a stable slope and erosion and sediment control measures will be used to protect the watercourse. • Northern Gateway will assess sites that do not have a site-specific erosion and sediment control plan, and will identify appropriate mitigation measures to limit the potential for erosion and sedimentation. • Segregated topsoil or organic material will be replaced over the trench line on the banks and buffer zone of the watercourse, and seeded with an approved seed mix.
All reclamation methods, techniques and structures will be approved or specified by Northern Gateway in conjunction with regulatory authorities.
Reclamation methods that will be considered include: rock rip-rap, channel liner, brush layering, log and crib walls, tree revetments, root wads, transplanting and live staking.
Watercourse reclamation techniques will be conducted in isolation of the flow, if site conditions and methods permit.
Instream Habitat Reclamation
All reclamation methods, techniques and structures will be approved, or specified, by Northern Gateway in conjunction with regulatory authorities.
Watercourse reclamation techniques will be conducted in isolation of the flow, if site conditions and methods permit.
Instream techniques that will be considered include: deflectors, log and rock weirs and boulder clusters
Watercourse reclamation activities will be monitored during construction and at regular intervals after construction. All necessary permits will be obtained and complied with. Post-construction monitoring will focus on persistence and effectiveness.
ENB LL 23751195
Attachment Federal Government IR 23
Crossing Method Mitigation Measures
Where reclamation is not successful, corrective measures will be recommended.
Additional Mitigations for the Coastal Tailed Frog
During reclamation, reclaim moist forested habitat with abundant coarse woody debris along watercourses (at least 30 m wide on both banks), where required.
Take special care to avoid siltation of watercourse habitats.
Avoid altering watercourse-flow patterns, and maintain small pools within watercourses (pocket or stream pools) and abundant instream cover.
Maintain clean and stable cobble and boulder gravel substrates, natural step-pool channel morphology and watercourse temperatures within tolerance limits.
Maintain microclimatic, hydrological and sedimentation regimes, to:
• limit the frequency of occurrence of extreme discharge events • limit the mortality rate of tailed frogs during floods • meet foraging and dispersal requirements of the adults and metamorphs
Maintain riparian forest.
Maintain important structural elements (e.g., coarse woody debris).
Maintain water quality and naturally dispersed water flows.
Limit risk of windthrow.
Where access roads are required:
• construct roads to limit site disturbance and reduce groundwater interception in the cutslope • use sediment-control measures in cut-and-fill slopes (e.g., grass-seeding, armouring ditchlines and culvert outfalls) • deactivate roads but limit digging and disturbance to adjacent roadside habitat • limit site disturbance during harvesting, especially in terrain polygons with high sediment transfer potential to natal watercourses • fall and yard trees away from, or bridging, all other watercourse channels (ephemeral or perennial) within the wildlife habitat area, to limit channel disturbance and slash loading • Where watercourse crossings are required, the type of crossing structure and any associated roads will be designed and installed in a way that limits effects on the coastal tailed frog instream and riparian habitats. Use temporary clear span bridges
ENB LL 23751195
Attachment Federal Government IR 23
Crossing Method Mitigation Measures where practical.
Prevent fish introductions and rechannelization of areas supporting tailed frog populations
Maintain slash-free headwater creeks and forested riparian buffers, especially within fragmented areas.
Site specific mitigation measures
A strategic watercourse assessment team (SWAT) was organized to provide a detailed analysis of biophysical, fisheries, construction and access conditions at high, medium- high and medium risk watercourse crossings. The results will lead to recommendations as to site-specific mitigation measures, possible compensation and habitat enhancement, and other information critical to developing a suitable open cut or isolated watercourse crossing at these locations.
Open Cut Primary mitigation includes rapid execution, enhanced excavation methods and machinery, controlled placement of spoil materials, silt plume management and backfill alternatives.
Isolated (Dam and Primary mitigation includes constructing the dams from acceptable materials to meet the Pump, Flume, sensitivity of the crossing, fish salvage, sizing the pumps and flumes correctly, dissipating Superflume) the pump or flume outflow, controlling ditch water, and performing the entire operation in the correct sequence.
All Trenchless Primary mitigation includes vehicle crossing restrictions, clearing and grading reductions, Crossings containment of site activities and water quality monitoring.
For trenchless crossings a setback from fish habitat will be established, where possible, to retain riparian vegetation and function. However, setback dimensions will vary with the setting and method.
Clearing within the buffer zone for trenchless crossings, if required, will be limited as much as possible. Clearing may be required for a travel lane, sightline, and additional extra temporary workspace specifically authorized by the environmental inspector.
HDD Drawings for each HDD crossing plan will be prepared and approved by Northern Gateway. The plan will take into account the geotechnical data, topographic profile, river hydrology, the fisheries assessment, vertical elevations, horizontal distances, expected drilling pressures, water supply and risks.
At each crossing, Northern Gateway and the drilling contractor will review the geotechnical assessment and engineered design crossing documents. Based on this review, the drilling contractor will provide a drilling plan for each HDD crossing. The plan will incorporate information from the geotechnical report, and the contractor will be informed of potential adverse subsurface conditions that could affect steering, hole stability, fluid circulation and pull back.
Northern Gateway will conduct a water quality monitoring program and provide progress
ENB LL 23751195
Attachment Federal Government IR 23
Crossing Method Mitigation Measures information to the drilling contractor. All affected disposition holders will be notified of the start date and timing of construction activities. The contractor and Northern Gateway will jointly develop an emergency response plan to deal with fluid releases. The plan will be developed according to the guidelines in the Horizontal Directional Drilling Contingency Plan (see Section A.2.7).
All necessary HDD crossing approvals will be obtained before construction. Inconsistencies between conditions of different approvals will be resolved before construction.
Notification will be provided 10 working days before any HDD activities start. Notice will include description of activities and schedule. Applicable regulators will be kept informed of all HDD schedules.
Northern Gateway will hold a preconstruction HDD meeting with its agents, contractors and other representatives before project construction starts. Additional meetings will be held before starting construction in a new area and before implementing a new construction technique, so that environmental questions specific to the new construction are clear and understood. The contingency plans for potential problems resulting from crossing method failures or adverse conditions, taking into account any restricted activity periods, will be reviewed at this meeting. All key project personnel working in the RoW will be informed of these plans.
A contingency crossing plan will be prepared and available for each HDD crossing, to be implemented if the HDD method is unsuccessful. The alternative crossing methods, such as open-cut or isolation, may create instream disturbances. The applicable regulatory body will be notified according to the permit conditions.
Contractor responsibilities, including frac-out response, are outlined in the Horizontal Directional Drilling Contingency Plan (see Section A.2.7). The plan is provisional and is generally consistent with industry standards. This plan will be reviewed before construction starts, and will be submitted to appropriate regulatory authorities. All on-site personnel will be informed of the plan.
Before any crossing work starts, all required materials will be stockpiled on site. Surface water runoff and seepage controls will be installed before construction and maintained throughout installation. All HDD equipment will be assembled and checked for proper operation before activities start.
Every effort will be made to limit interference with the activities of other land disposition holders in the area.
Before starting any drilling operations, the drilling contractor or surveyor will clearly flag the entire expected drill path, including both sides of the watercourse.
The HDD entry site will be used for the pilot hole, reaming, cleaning and pipe pullback operations. The topsoil or duff and mineral soil in this area will be stripped and stored to the side, away from the work area. The subsoil will then be levelled, and a berm large enough to control surface runoff will be constructed around the site.
ENB LL 23751195
Attachment Federal Government IR 23
Crossing Method Mitigation Measures
The exit site work area will be prepared to the size stated in the construction drawing. Similar to the entry site, the HDD site will be stripped and topsoil stored to the side. Subsoil will be levelled and the area will be bermed. The staging area will be long enough to accommodate the construction for the overall curve distance of the crossing.
During drilling periods, the pipeline contractor will haul the pipe to the layout area and will string, weld, x-ray and coat the joints, and then place the pipe on pipe rollers when the section is ready for installation. For major or sensitive crossings, the pipe drag section will be tested for leaks before it is installed. The fully installed section will be re-tested as part of pipeline pressure testing.
The drilling fluid composition will consist of bentonite and fresh water. Additives to control mud chemistry are often used to improve drilling conditions and performance. Additives in the drilling fluid other than sawdust, nut shells or bentonite pellets require the approval of Northern Gateway, in consultation with the appropriate regulators.
A list of pre-approved additives will be developed before drilling work starts.
Drill fluid pressures and drilling rates will be monitored at all times by a trained operator and inspector, to watch for pressure spikes that could lead to a frac-out. Downhole annular pressure monitoring will be provided.
If a frac-out occurs, the environmental inspector will begin the water quality monitoring program, to: • provide feedback to the contractor • identify potential effects on water quality • oversee the implementation of environmental protection measures during construction Both the drilling contractors and project management will be diligent during all aspects of directional drilling, to limit the potential for releases of drilling fluid. If a frac-out occurs, all effects resulting from fluid migration to the surface will be addressed. Appropriate measures for containing drilling fluid or incorporating alternative drilling methods will be implemented. The HDD contractor will have sufficient equipment on site to deal quickly with any incidents. If drilling fluid or pressure loss is detected by the drilling operator, additional efforts will be made to determine whether a frac-out has occurred.
Water quality will be monitored to determine whether a frac-out has caused fluids into the watercourse. If a frac-out is detected, the contractor will implement strategies to seal or plug off fractures, to limit the loss of circulation. The contractor will also implement a procedure for tracking fluid loss and for sealing frac-outs.
The work area and entry point will be monitored during drilling, to detect potential losses to the surface. If losses are detected where a watercourse may be affected, drill rig production will stop, and drilling fluid will be contained, cleaned up and transferred back to the rig before drilling operations resume.
ENB LL 23751195
Attachment Federal Government IR 23
Crossing Method Mitigation Measures Dewatering of containment pits, sumps or ditches will require drilling fluids to be vacuumed into a pump truck and disposed of at an approved facility, or in an approved way.
Discharge of contaminated fluids on site will not be permitted.
Drilling fluid consists of clay particles mixed with water. In accordance with ERCB Directive 50, all excess drilling fluid and cuttings that cannot be disposed of on site will be hauled to an approved disposal site. The BC MoE is expected to accept these guidelines with review and comment.
After the pullback is complete, the drill rig and all equipment from both sides will be dismantled and removed from the work sites. After the pipelines are tied-in, the topsoil will be replaced and the site will be cleaned up. All disturbed areas, where bare soil has been exposed, will be reclaimed to project specifications.
Aerial Detailed plans and drawings for each aerial crossing will be prepared by Northern Gateway. The plans will take into account the geotechnical data, topographic profile, river hydrology, biophysical and land use concerns, vertical elevations, horizontal distances, water supply and risks.
Detailed design will include identifying measures to confirm that the terrain on which the support structures are constructed:
• is secure (considering the potential for surface erosion, the slope stability and hydrological events) • meets all safety and operations requirements
ENB LL 23751195
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REFERENCES: NTDB Topographic Mapsheets provided by the Majesty the Queen in Right of Canada, Department of Natural Resources. All rights reserved. SOURCE: Modified from Burleigh (2008, pers.comm.) JWA-1038983-020-001 ! CONTRACTOR: SEVERITY ! FIGURE NUMBER: DATE: ! > Kilometre Post ! O!o ! ts ! Stantec Ltd. Trace (<1%) a L 20111005 Morice ak 9-4 Pipeline Route ENBRIDGE NORTHERN GATEWAYe PROJECT PREPARED BY: PREPARED FOR: Lake Low (1-10%) SCALE: AUTHOR: APPROVED BY: Tunnel ! Moderate (11-29%) 1:1,200,000 CES DC Regional Effects Assessment Area Mountain Pine Beetle Infestation Severity ! Severe (30-49%) PROJECTION: DATUM: Lambert Conformal Conic Land and Resource Management Plan in the Route T REAA, British Columbia Central Meridian: 120°E 1st Standard Parallel: 50°N NAD 83 Very Severe (50%) Latitude of Origin: 40°N 2nd Standard Parallel: 70°N Z:\Clients\Enbridge\Gateway\Figures\MXD\JWA-CAL-020_E-Size_PineBeetle\JWA-1038983-020-001.mxd
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! Attachment Federal Government IR 53
Land Use Plans in the REAA
Plan Name Province Management Scale
Eastern Slopes Policy AB Provincial/regional
Proposed Land Use Framework AB Provincial/regional (Cumulative effects management approach – to be modeled in the Industrial Heartland)
Whitecourt and Anselmo Public AB Local Land Use Strategy
Forest Management Agreement AB Local and Forest Management Plans
Dawson Creek Land and Resource BC Subregional Management Plan
Prince George Land and Resource BC Subregional Management Plan
Fort St James Land and Resource BC Subregional Management Plan
Vanderhoof Land and Resource BC Subregional Management Plan
Lakes District Land and Resource BC Subregional Management Plan
Morice Land and Resource BC Subregional Management Plan
Kalum Land and Resource BC Subregional Management Plan
Official Community Plan (Kitimat) BC District Municipality
Burns Lake Rural Official BC Bulkley-Nechako Regional Community Plan (2009) District
Fort St James-Omineca Settlement BC Bulkley-Nechako Regional Corridor Official Community Plan District (2003) Attachment Federal Government IR 53
Plan Name Province Management Scale
Fort St James Rural Official BC Bulkley-Nechako Regional Community Plan District
Vanderhoof Rural Official BC Bulkley-Nechako Regional Community Plan (2009) District
Houston Topley Granisle Rural BC Bulkley-Nechako Regional Official Community Plan District
Crooked River-Parsnip Official BC Fraser-Fort George Regional Community Plan District
North Peace Fringe Area Official BC Peace River Regional District Community Plan
Kitimat-Stikine Official Community BC Kitimat-Stikine Regional District Plan
Attachment 1 Federal Government IR 70 Attachment 2 Federal Government IR 70 Attachment Federal Government IR 76b)
Table 1 Summary of consultation with ASRD on topics related to access management and wildlife-related re-routing
Topics Discussed Related to Access Date Agency Meeting Type Agency Attendees Management and Wildlife-Related Re-Routing 30 Jun 2005 ASRD Meeting E. Baranski, J. Bradley, S. • Width of corridor is becoming an issue; at Milne some point width becomes a barrier to wildlife movement • How much of Gateway corridor is in a common corridor? • Concern over addition of new corridor 10 Nov 2005 ASRD Telephone E. Smith • Concern about forested land being converted to maintained ROW; reclamation issues 14 Mar 2006 ASRD Meeting D. Cummings, D. • Concern over lack of their involvement in Heatherington, D. Stepnisky, route selection S. Taylor 27 Mar 2006 ASRD Meeting D. Stepnisky, S. Taylor, S. • Wants to review route selection Trostem 9 May 2006 ASRD Meeting E. Baranski • Avoid Little Smoky Caribou Protection Area, like the Alliance/Peace Pipe Corridor does • Not favourable to new corridor between Deep Valley Creek and Smoky River given presence of Chevron Midstream Pipeline • Re-route at Tony Tower to avoid encroachment on Waskahigan River • Wants justification for parts not following existing RoW 9 May 2006 ASRD Meeting Brent Bochon • Wants buffer to the Narraway Caribou Protection Area and the Swan Habitat • Wapiti District wants confirmation from Gateway that routing is adequately justified 17 Aug 2009 ASRD Tour of RoW C. Johnson • Possible re-route near Prince George to avoid higher-value fish streams; raises issues for other disciplines, including wildlife 28 Sep 2009 ASRD Meeting C. Found, D. Heatherington, C. • Key wildlife species and mitigation reviewed; Stambaugh, D. Stepnisky Routing discussions to be coordinated through ASRD Lands Office • SRD to hold internal meeting on routing through Little Smoky Caribou range ENGP: • Look into options for paralleling other RoWs, notably in Wapiti River area • Review routing through Little Smoky Caribou range, or alternative routes north of range • Re-examine routing through Narraway herd • Create map showing where alignment takes advantage of paralleling opportunities • Examine feasibility of using vegetation screens instead of gates or rollback to manage access • Circulate May 2006 discussion on routing through Little Smoky Herd to D. Stepnisky and C. Stambaugh Attachment Federal Government IR 76b)
Table 1 Summary of consultation with ASRD on topics related to access management and wildlife-related re-routing
Topics Discussed Related to Access Date Agency Meeting Type Agency Attendees Management and Wildlife-Related Re-Routing 22 Dec 2009 ASRD e-mail D. Stepnisky • Key items requiring further work: exploration of new routing options (that closer parallel existing linear disturbances) for the portion of the line between the BC boarder and the Little Smoky River; and creation of a mitigation plan for the Little Smoky caribou range (which would include paralleling existing disturbance, reducing clearing width, rollback and planting along line, no new access, plan to revegetate other areas in the Little Smoky range possibly at a 4:1 ratio) 22 Feb 2010 ASRD Meeting E. Baranski, B. Bochon, D. • Routing adjustments through caribou range Heatherington, C. Johnson, D. Stepnisky 6 Jun 2011 ASRD (and Meeting D. Heatherington, J. Lefebvre, • Mitigation strategies for caribou discussed Environment C. Stambaugh, D. Stepnisky • ENGP will review access in grizzly bear and Canada, see caribou areas next table) • Review access management strategies at fall workshop to meet caribou objectives
Attachment Federal Government IR 76b)
Table 2 Summary of consultation with Environment Canada on topics related to access management and wildlife-related re-routing Topics Discussed Related to Access Date Agency Meeting Type Agency Attendees Management and Wildlife-Related Re-Routing 19 Nov 2009 Environment Meeting P. Wong, A. Murphy, A. • Edge effect on wildlife (from linear Canada Robinson, C. DeShield, B. developments Elner, P. Gregoire. L. Yasul, S. • Need for follow-up meeting on Little Smoky Boyd, M. Hipfner, J. Kirkby herd identified 11 May Environment Meeting P. Wong, G. Mullins, A. • CWS is responsible for SARA species and has 2011 Canada Robinson, P. Gregoire, C. specific concerns about the effects of pipeline Horne, A. Murphy RoW on boreal caribou (i.e. Little Smoky Herd) and caribou herds in B.C. • Asked whether meetings have been or would be held with ASRD and BC MOE in regard to the pipeline RoW, the access management plan and protection of caribou habitat 6 Jun 2011 Environment Meeting C. Horne • Mitigation strategies for caribou discussed Canada (and • ENGP will review access in grizzly bear and ASRD, see caribou areas previous • Review access management strategies at fall table) workshop to meet caribou objectives 9 Aug 2011 Environment Meeting A. Robinson, C. Horne, P. • Concern about opportunity for micro-routing Canada Gregoire. P. Wong. A. Murphy at time of clearing/construction • How is micro-routing for a winter clearing program adjusted if clearing extends into summer season? ENGP: • Committed to doing centerline survey 6 months prior to clearing to identify sensitive wildlife features that may require consideration for micro-routing • Will include in the EPMP a contingency plan for clearing activities if schedule is delayed or adjusted to occur outside the winter period
Attachment Federal Government IR 76b)
Table 3 Summary of consultation with BC Ministry of Forests on topics related to access management and wildlife-related re-routing
Topics Discussed Related to Access Date Agency Meeting Type Agency Attendees Management and Wildlife-Related Re-Routing 5 Jan 2005 BC MOF Telephone G. Halliday • Discussion on use of beetle-killed wood as rollback for access control • Policies/guidelines are in place 5 Feb 2005 BC MOF Meeting E. O'Donoghue • Burnie-Shea Park: recreation access to park is major concern; ENGP to include as much information as possible regarding access management and mitigation 5 Nov 2005 BC MOF Meeting E. O'Donoghue • Burnie-Shea Park: routing alternatives still being evaluated 21 Nov 2005 BC MOF Workshop J. Burck, M. Geertsema, G. • Concern over increased access in area [Prince Halliday, S. Henderson George], especially of resident hunters 23 Nov 2005 BC MOF Meeting E. O'Donoghue • Burnie-Shea Park: ENGP requests government to consider RoW across southern part of proposed protected area 7 Dec 2005 BC MOF Letter E. O'Donoghue • BC Minister of Agriculture and Lands Correspondence confirms commitment to ENGP to recommend to Cabinet a designation for a RoW in the lower portion of the Burnie-Shea proposed protected area • ENGP still advised to consider options that avoid Burnie-Shea 19 Nov 2008 BC MOF Open House G. Sarto • Concerns regarding habitat fragmentation • Access and wildlife conservation issues 22 Nov 2008 BC MOF Open House B. Thibeault • Information on linear ROW impacts to wildlife • Will there be access along pipeline corridor 3 Dec 2008 BC MOF Open House R. Meredith • Opening of land access to areas previously difficult to access 12 Dec 2008 BC MOF Telephone D. Seip • Caribou analysis • Avoid core habitat areas • Do not develop roads in upper elevations along east side of Rockies • Avoid wind-swept alpine ridges • Implement good access control (i.e., don’t facilitate snowmobile access) 19 Mar 2009 BC MOF e-mail P. Inden • Why not parallel PNG pipeline to minimize new access 26 Aug 2009 BC MOF e-mail D. Seip • Confirms route does not cross core windswept alpine habitat used by some Quintette caribou in winter; route will not destroy too much caribou winter range • Primary concern is increased winter access and summer predation risk
Attachment Federal Government IR 76b)
Table 4 Summary of consultation with BC Ministry of Environment on topics related to access management and wildlife-related re-routing
Topics Discussed Related to Access Date Agency Meeting Type Agency Attendees Management and Wildlife-Related Re-Routing 18 Nov 2005 BC MOE Workshop P. Johnstone • Concern about line of sight down RoW • Requested for list of best mitigation measures used for access management • Concern about snowmobile access into caribou wintering areas and potential mitigation measures to deter snowmobile access 23 Nov 2005 BC MOE Workshop T. Larden • Proposed route traverses prime grizzly bear habitat; a number of components associated with that, such as visual impacts 15 Dec 2005 BC MOE Meeting C. Broster, P. Giroux, T. • Critical habitat avoidance (pipeline Larden realignment) is more important than adhering to a timing window 10 July 2006 BC MOE Telephone D. Cadden • Stuart River Provincial Park; the two pipeline route alternatives (as of 10 July 2006) go through park; pipeline development not allowed. 5 Dec 2008 BC MOE Open House L. Vanderstar • Concern about public access to wildlife • Disruption of wildlife movement corridors • Concern about increased access to remote areas 31 Mar 2009 BC MOE Telephone Troy Larden • Disable short-term access points (e.g., pulling a bridge) • ENGP should identify short and long-term access points • Need creative strategy for managing long-term access points • Burnie Shea/Mt. Nimbus area is highly sensitive and currently has zero access • Examples of effective access control has only been demonstrated for short-term access points 8 Sep 2009 BC MOE e-mail T. Larden • With respect to tunneling portion, current identified risks are associated with permanent access development
Attachment Federal Government IR 89
Appendix: 3 – Wildlife Rescue and Rehabilitation Organization APPENDIX # 3: WILDLIFE RESCUE AND REHABILITATION ORGANIZATION
In British Columbia:
Critter Care Wildlife Society
Gibsons Widlife Rehabilitation Centre
Island Wildlife Natural Care Centre
Kamloops Wildlife Park Wildlife Rehabilitation Centre
Monika’s Wildlife Centre (Birds Only)
Mountainaire Avian Rescue Society
North Island Wildlife Association
Northern Wildlife Rehabilitation Shelter
The Northern Lights Wildlife Shelter
Orphaned Wildlife Rehabilitation Society (O.W.L)
Second Chance Wildlife Centre
South Okanagan Rehabilitation Centre for Owls
Vancouver Aquarium Marine Mammal Rescue and Rehabilitation
Wild Animal Rehabilitation Centre WildARC
In Canada and International :
International Wildlife Rehabilitation Centre
National Wildlife Rehabilitation Association
Wildlife International b
Canada
Ontario SPCA Wildlife Rehabilitation Centre
Rockview Wildlife Recovery, Alberta
Wild Care, Ontario
United States
California Bat Conservation Fund- Injured bats
The Wildlife Rehabilitation Information Directory Attachment Federal Government IR 89
Tri-State Bird Rescue
Wildlife Rehabilitation Today Magazine
Wildlife Rehabber
Wildlife Rehabilitators.com
Other Wildlife, Conservation, and animal Welfare Resources
Focus Wildlife
Avibase-Bird database
BC Conservation Foundation
BC Natural History Society
BC Society for the Prevention of Cruelty to Animals
Canadian Nature Federation
Canadian Wildlife Federation
Humane Society of the US
International fund of Animal Welfare
Royal Society for the Prevention of Cruelty to animals
The Fund for Animals
Tufts Center for Conservation Medicine
Union Nationale des Centres de Sauvegrade de la Faune Sauvage
Wildlife Trust
World Society for the Protection of Animals
World Wildlife Foundation- Canada
ZOOcheck Canada
Name Organization/ Facility Address Phone Number & Email Permits/Specialty Affiliation Website
1. Vancouver Island and Gulf Islands Facility BC SPCA CWS; MOE; Birds, 1020 Malloch Rd P: 250-478-9453 Animal mammals, all Spp. Victoria, BC v9C Rehabilitation 4G9 F: 250-478-6313 Centre (Wild www.wildarc.com ARC SPCA – 3150 [email protected] Napier Lane Victoria, BC V8T Attachment Federal Government IR 89
4V5
Birch, Maj Mountainaire CWS: MOE Birds; rescue 6817 P: 250-337-2021 Avian Rescue all species Headquarters Society (MARS) Road, F: 250-337-2099 www.wingtips.org Courtenay, BC V8J 1N2 [email protected]
Campbell, Robin & North island CWS; MOE; bears, all 1240 Lefter Road P: 250-248-8534 Sylvia Wildlife spp. Recovery Assn. P.O. Box 364 F: 250-248-1274 www.northislandwildlife recoverycenter.org Errington, BC [email protected] V0R 1E0
Ledeman,, Jeff Island Wildlife CWS; DFO; MOE Marine 322 Langs Road TP: 250-537-0777 natural Care mammals, Centre Salt spring [email protected] all Spp. Island, BC V8K 1N3 www.sealrescue.org
Mace-Harvey, Darlene Gabriola rescue Rescue and Transport all 1430 Harrison P: 250-247-7415 of Wildlife spp. Way Gabriola Society Island, BC [email protected] (GROWLS) V0R 1X2
Paterson, Aurora Roy’s Refuge CWS; MOE Birds P.O. Box 45 P: 250-725-3783
Tofino, BC [email protected] V0R 2Z0
2. Lower Mainland and Sunshine Coast Facility Critter, Care MOE, Mammals, 481 -216th P: 604-530-2064 Wildlife Society education Street., Langley, – Gail martin BC V2Z 1R5 [email protected] www.crittercarewildlife.org
Facility Grouse www.grousemountain.com 6400 Nancy P: 604-998-4229 Mountain Greene Way ‘refuge for North [email protected] Endangered Vancouver, BC Wildlife – Ken V7R 4K9 Macquisten
Facility Orphaned MOE; Raptors, education 3800 -72nd P: 604-946-3171 Wildlife Street, Rehabilitation Attachment Federal Government IR 89
society (OWL) www.owlcanada.ca Delta, BC V4K [email protected] 3N2
Facility Wildlife rescue CWS MOE, Birds, oil spill; 5216 Glencarin P: 604-526-7275 Association of rescue all spp. Drive BC (WRA) F: 604-524-2890 www.wildliferescue.ca Burnaby, BC V5B 3C1 [email protected]
Davey, Clint & Irene Gibsons Wildlife CWS: MWLAP Birds and RR 1211 Carmen P: 604-886-4989 Rehabilitation small mammals Road Centre F: 604-886-4989 www.gibsonswildlife Gibsons, BC V0N 1V4 [email protected] rehabcentre.org
Melnik, Elizabeth Elizabeth’s CWS, MOE , small 32508 Verdon Pager 604-855-3914 Wildlife Centre mammals and birds Way, Abbottsford, BC P: 604-852-9173 V2T 7Y3 [email protected]
Rudolph, Cindy Creature MOE; Raccoons, small 5171 Brooks P: 604-85-4697 Comfort Wildlife mammals, birds Road Care [email protected] Halfmoon Bay, BC
V0N 1Y2
Thompson
Facility BC Wildlife Park CWS; MWLAP , all spp. 9077 Dallas P: 250-573-3242 ext. 230 wildlife Drive, Rehabilitation www.bczoo.org Kamloops, BC F: 250-573-2406 Centre V2C 5L7 [email protected]
Beggs, Karen Knee-Two CWS; MWLAP Raptors 2061-70th Street P: 250-832-8200 Wildlife SE Salmon Arm, Rehabilitation Migratory birds, small BC. V1E 1X4 Centre mammals
3. Kootenay
Pettigrew, carol Beak Songbirds CWS Migratory 318 103rd Street P: 250-365-3701 permit only Castlegar, BC V1N 3G2 [email protected] Attachment Federal Government IR 89
4. Cariboo
Schupbach, Elizabeth Raptor CWS; MWLAP, Raptors, P.O. Box 3221 P: 250-989-8900 Rehabilitation waterfowl, migratory birds Cenrre rescue all spp. McLeese Lake, F: 250-989-8900 BC [email protected] V0L 1P0
5. Skeena
Gifford-Brown, Janet Birds, small mammals P.O. Box 57, P: 250-557-4253 Tlett Queen Charlotte F: 250-557-4253 Islands, BC [email protected] V0T 1Y0
Golinia, Nancy & Prince Rupert CWS, MWLAP Raptors, P.O. Box 26 P: 250-624-4143 Gunther wildlife all species Rehabilitation Prince Rupert, F: 624-4159 Shelter www.citytel.net/willife BC [email protected] V8J 3P4
Grundmann, Peter Raptors P.O. Box 438, P: 250-637-5499 Sandspit
Queen Charlotte Islands, BC V0T 1Y0
Langden, Angelika Northern Lights MWLAP, Large mammals, 17366 Telka Wildlife Society bears, moose, deer, High Road raptors Smithers, BC www.wildlifeshelter.com V0J 2N7
Attachment Federal Government IR 107
U.S.A
CANADA
Prince Rupert Kitimat Osland Port Edward Hunts Inlet Masset Onna River
Kitkatla
Port Clements Tlell Hartley Bay Lawnhill Anger Anchorage
Sandspit Butedale Queen Charlotte Surf Inlet
Klemtu
Bella Coola
Bella Bella
Shearwater
Port Hardy
Barge Response Base Port Alice Major Response Bases
River / Stream
International Border Port McNeil 40 nautical miles from major response base approximate 6 hour response limit 88 nautical miles from major response base approximate 12 hour response limit
0 306090
Kilometres 123110043-xx
Reference: Pipeline Route R
CONTRACTOR: FIGURE NUMBER: DATE: Stantec ENBRIDGE NORTHERN GATEWAY PROJECT x-x 20100609
PREPARED BY: PREPARED FOR: SCALE: AUTHOR: APPROVED BY: 1:3,200,000 NP CM
Area of focused Marine Response PROJECTION: DATUM: UTM 9 NAD 83 R:\2009Fiscal\1048334_NorthernGateway_OilSpillResponse\MXD Attachment Federal Government IR 114 Page 1 of 6
Compositions of Project relevant hydrocarbons with regard to Environmental Emergency Regulations SOR/2003-307 - Schedule 1
LIST OF SUBSTANCES Representative Liquid PART 1 Hydrocarbon Samples Column 1 Column 2 Column 3 Concentration (% w/w) CAS Minimum Diluted Registry Name of Substance UN Number Concentration Quantity Synthetic Oil Condensate Bitumen Number (tonnes) 60-29-7 ethyl ether (diethyl ether) 1155 1% 4.50 ------71-43-2 benzene 1114 1% 10.00 0.028% 0.11% 1.31% 74-82-8 methane 1971 and 1972 1% 4.50 ------74-84-0 ethane 1035 and 1961 1% 4.50 ------74-85-1 ethylene 1038 and 1962 1% 4.50 ------74-86-2 acetylene 1001 1% 4.50 ------74-89-5 methylamine 1061 1% 4.50 ------74-98-6 propane 1978 1% 4.50 ------74-99-7 methylacetylene (propyne) 1060 1% 4.50 ------75-00-3 ethyl chloride 1037 1% 4.50 ------75-01-4 vinyl chloride 1086 1% 4.50 <0.01% <0.01% <0.01% 75-02-5 vinyl fluoride 1860 1% 4.50 ------75-04-7 ethylamine 1036 and 2270 1% 4.50 ------75-07-0 acetaldehyde 1089 1% 4.50 ------75-08-1 ethyl mercaptan 2363 1% 4.50 ------75-18-3 dimethyl sulphide 1164 1% 150.00 ------75-19-4 cyclopropane 1027 1% 4.50 ------75-28-5 isobutane 1969 1% 4.50 ------75-29-6 2-chloropropane (isopropyl chloride) 2356 1% 4.50 ------75-31-0 isopropylamine 1221 1% 4.50 ------75-35-4 vinylidene chloride 1303 1% 4.50 ------75-37-6 difluoroethane (1,1-difluoroethane) 1030 1% 4.50 ------75-38-7 1,1-difluoroethylene (vinylidene fluoride) 1959 1% 4.50 ------75-50-3 trimethylamine 1083 and 1297 1% 4.50 ------75-64-9 tert-butylamine (2-amino-2-methylpropane) 1125 1% 150.00 ------75-76-3 tetramethylsilane 2749 1% 4.50 ------78-78-4 isopentane (2-methylbutane) 1265 1% 4.50 ------78-79-5 isoprene 1218 1% 4.50 ------79-38-9 trifluorochloroethylene (chlorotrifluoroethylene) 1082 1% 4.50 ------100-41-4 ethylbenzene 1175 1% 7000.00 0.036% 0.12% 0.29% 106-97-8 butane 1011 1% 4.50 ------106-98-9 1-butene (alpha-butylene) 1012 1% 4.50 ------106-99-0 1,3-butadiene 1010 1% 4.50 ------107-00-6 ethylacetylene 2452 1% 4.50 ------
Attachment Federal Government IR 114 Page 2 of 6
LIST OF SUBSTANCES Representative Liquid PART 1 Hydrocarbon Samples Column 1 Column 2 Column 3 Concentration (% w/w) CAS Minimum Diluted Registry Name of Substance UN Number Concentration Quantity Synthetic Oil Condensate Bitumen Number (tonnes) 107-01-7 2-butene 1055 1% 4.50 ------107-25-5 vinyl methyl ether 1087 1% 4.50 ------107-31-3 methyl formate 1243 1% 4.50 ------108-88-3 toluene 1294 1% 2500.00 0.10% 0.33% 2.53% 109-66-0 n-pentane (pentane) 1265 1% 4.50 ------109-67-1 1-pentene 1108 1% 4.50 ------109-92-2 vinyl ethyl ether (ethyl vinyl ether) 1302 1% 4.50 ------109-95-5 ethyl nitrite 1194 1% 4.50 ------110-82-7 cyclohexane 1145 1% 550.00 ------115-07-1 propylene 1077 1% 4.50 ------115-10-6 dimethyl ether (methyl ether) 1033 1% 4.50 ------115-11-7 isobutylene (2-methylpropene) 1055 1% 4.50 ------116-14-3 tetrafluoroethylene 1081 1% 4.50 ------124-40-3 dimethylamine 1032 and 1160 1% 4.50 ------460-19-5 cyanogen 1026 1% 4.50 ------463-49-0 propadiene 2200 1% 4.50 ------463-58-1 carbonyl sulphide (carbon oxysulfide) 2204 1% 4.50 ------463-82-1 2,2-dimethylpropane 2044 1% 4.50 ------504-60-9 1,3-pentadiene NA 0.01 4.50 ------557-98-2 2-chloropropene (2-chloropropylene) 2456 1% 4.50 ------563-45-1 3-methyl-1-butene 2561 1% 4.50 ------563-46-2 2-methyl-1-butene 2459 1% 4.50 ------590-18-1 cis-2-butene (2-butene-cis) 1055 1% 4.50 ------590-21-6 1-chloropropene (1-chloropropylene) NA 0.01 4.50 ------598-73-2 bromotrifluoroethylene 2419 1% 4.50 ------624-64-6 trans-2-butene (2-butene-trans) 1055 1% 4.50 ------627-20-3 cis-2-pentene (beta-cis-amylene) NA 0.01 4.50 ------646-04-8 trans-2-pentene (trans-beta-amylene) NA 0.01 4.50 ------689-97-4 1-buten-3-yne (vinyl acetylene) NA 0.01 4.50 ------1330-20-7 xylenes 1307 1% 8000.00 0.15% 0.42% 2.10% 1333-74-0 hydrogen 1049 1% 4.50 ------4109-96-0 dichlorosilane 2189 1% 4.50 ------7722-84-1 hydrogen peroxide 2015 52% 3.40 ------7775-09-9 sodium chlorate 1495 10% 10.00 ------7790-98-9 ammonium perchlorate 1442 1% 3.40 ------
Attachment Federal Government IR 114 Page 3 of 6
LIST OF SUBSTANCES Representative Liquid PART 1 Hydrocarbon Samples Column 1 Column 2 Column 3 Concentration (% w/w) CAS Minimum Diluted Registry Name of Substance UN Number Concentration Quantity Synthetic Oil Condensate Bitumen Number (tonnes) 7791-21-1 chlorine monoxide (dichlorine oxide) NA 0.01 4.50 ------7803-62-5 silane 2203 1% 4.50 ------8006-14-2 liquefied natural gas 1972 1% 4.50 ------8030-30-6 naphtha 1268 1% 50.00 ------10025-78- 2 trichlorosilane 1295 1% 4.50 ------25167-67- 3 butylene (butene) 1012 1% 4.50 ------86290-81- 5 gasoline (motor fuel) 1203 1% 150.00 ------
LIST OF SUBSTANCES Representative Liquid PART 2 Hydrocarbon Samples Column 1 Column 2 Column 3 Concentration (% w/w) CAS Minimum Diluted Registry Name of Substance UN Number Concentration Quantity Synthetic Oil Condensate Bitumen Number (tonnes) 50-00-0 formaldehyde, solution 1198 and 2209 10% 6.80 ------57-14-7 1,1-dimethylhydrazine 1163 10% 6.80 ------60-34-4 methylhydrazine (monomethyl hydrazine) 1244 10% 6.80 ------67-66-3 chloroform (trichloromethane) 1888 10% 9.10 <0.01% <0.01% <0.01% 74-83-9 methyl bromide 1062 10% 2.27 ------74-87-3 methyl chloride 1063 10% 4.50 ------74-88-4 methyl iodide 2644 10% 4.50 ------1051, 1613 and 74-90-8 hydrogen cyanide (hydrocyanic acid) 1614 10% 1.13 ------74-93-1 methyl mercaptan 1064 10% 4.50 ------75-15-0 carbon disulphide 1131 10% 9.10 ------75-21-8 ethylene oxide 1040 10% 4.50 ------75-44-5 phosgene 1076 1% 0.22 ------75-55-8 propyleneimine 1921 10% 4.50 ------75-56-9 propylene oxide 1280 10% 4.50 ------75-74-1 tetramethyl lead NA 10% 4.50 ------75-77-4 trimethylchlorosilane (chlorotrimethylsilane) 1298 10% 4.50 ------75-78-5 dimethyldichlorosilane (dichlorodimethylsilane) 1162 10% 2.27 ------
Attachment Federal Government IR 114 Page 4 of 6
LIST OF SUBSTANCES Representative Liquid PART 2 Hydrocarbon Samples Column 1 Column 2 Column 3 Concentration (% w/w) CAS Minimum Diluted Registry Name of Substance UN Number Concentration Quantity Synthetic Oil Condensate Bitumen Number (tonnes) 75-79-6 methyltrichlorosilane 1250 10% 2.27 ------76-06-2 chloropicrin (trichloronitromethane) 1580 10% 2.27 ------78-00-2 tetraethyl lead 1649 10% 2.27 ------78-82-0 isobutyronitrile 2284 10% 9.10 ------79-21-0 peroxyacetic acid (peracetic acid) 3107 10% 4.50 ------79-22-1 methyl chloroformate 1238 10% 2.27 ------91-08-7 toluene-2,6-diisocyanate 2078 10% 4.50 ------106-89-8 epichlorohydrin 2023 10% 9.10 ------107-02-8 acrolein 1092 10% 2.27 <0.04% <0.04% <0.04% 107-05-1 allyl chloride 1100 10% 9.10 ------107-06-2 1,2-dichloroethane (ethylene dichloride) 1184 10% 6.80 <0.01% <0.01% <0.01% 107-07-3 ethylene chlorohydrin (2-chloroethanol) 1135 10% 4.50 ------107-11-9 allylamine 2334 10% 4.50 ------107-12-0 propionitrile 2404 10% 4.50 ------107-13-1 acrylonitrile 1093 10% 9.10 ------107-15-3 ethylenediamine 1604 10% 9.10 ------107-18-6 allyl alcohol 1098 10% 6.80 ------chloromethyl methyl ether (methyl chloromethyl 107-30-2 ether) 1239 10% 2.27 ------108-05-4 vinyl acetate 1301 10% 6.80 ------108-23-6 isopropyl chloroformate 2407 10% 6.80 ------108-91-8 cyclohexylamine 2357 10% 6.80 ------1671, 2312 and 108-95-2 Phenol 2821 10% 9.10 <0.0001% <0.0001% 0.00024% 109-61-5 n-propyl chloroformate (propyl chloroformate) 2740 10% 6.80 ------110-00-9 furan 2389 10% 2.27 ------110-89-4 piperidine 2401 10% 6.80 ------123-73-9 trans-crotonaldehyde 1143 10% 9.10 ------126-98-7 methylacrylonitrile 3079 10% 4.50 ------151-56-4 ethyleneimine 1185 10% 4.50 ------302-01-2 hydrazine 2029 10% 6.80 ------353-42-4 boron trifluoride dimethyl etherate 2965 10% 6.80 ------463-51-4 ketene NA 0.01 0.22 ------506-68-3 cyanogen bromide 1889 10% 4.50 ------506-77-4 cyanogen chloride 1589 10% 4.50 ------
Attachment Federal Government IR 114 Page 5 of 6
LIST OF SUBSTANCES Representative Liquid PART 2 Hydrocarbon Samples Column 1 Column 2 Column 3 Concentration (% w/w) CAS Minimum Diluted Registry Name of Substance UN Number Concentration Quantity Synthetic Oil Condensate Bitumen Number (tonnes) 509-14-8 tetranitromethane 1510 10% 4.50 ------542-88-1 bis(chloromethyl) ether [dichlorodimethyl ether] 2249 1% 0.45 ------556-64-9 methyl thiocyanate NA 10% 9.10 ------584-84-9 toluene-2,4-diisocyanate 2078 10% 4.50 ------594-42-3 perchloromethyl mercaptan 1670 10% 4.50 ------624-83-9 methyl isocyanate 2480 10% 4.50 ------630-08-0 carbon monoxide 1016 10% 6.80 ------814-68-6 acryloyl chloride (acrylyl chloride) NA 10% 2.27 ------4170-30-3 crotonaldehyde 1143 10% 9.10 ------7439-97-6 mercury 2809 NA 1.00 <0.0000005% <0.0000005% <0.0000005% 7446-09-5 sulphur dioxide 1079 10% 2.27 ------7446-11-9 sulphur trioxide 1829 10% 4.50 ------7550-45-0 titanium tetrachloride 1838 10% 1.13 ------7616-94-6 perchloryl fluoride (trioxychlorofluoride) 3083 10% 6.80 ------7637-07-2 boron trifluoride 1008 10% 2.27 ------7647-01-0 hydrochloric acid 1789 30% 6.80 ------7647-01-0 hydrogen chloride, anhydrous 2186 and 1050 10% 2.27 ------7664-39-3 hydrofluoric acid 1790 50% 0.45 ------7664-39-3 hydrogen fluoride, anhydrous 1052 1% 0.45 ------7664-41-7 ammonia, anhydrous 1005 10% 4.50 ------7664-41-7 ammonia solution 2073 and 2672 20% 9.10 ------7697-37-2 nitric acid 2031 and 2032 80% 6.80 ------7719-09-7 thionyl chloride 1836 10% 6.80 ------7719-12-2 phosphorus trichloride 1809 10% 6.80 ------7723-14-0 phosphorus, white 2447 NA 1.00 ------7726-95-6 bromine 1744 10% 4.50 ------7782-41-4 fluorine 1045 1% 0.45 ------7782-50-5 chlorine 1017 10% 1.13 ------7783-06-4 hydrogen sulphide 1053 10% 4.50 ------7783-07-5 hydrogen selenide 2202 1% 0.22 ------7783-60-0 sulphur tetrafluoride 2418 10% 1.13 ------7784-34-1 arsenic trichloride (arsenous trichloride) 1560 10% 6.80 ------7784-42-1 arsine 2188 1% 0.45 ------7790-94-5 chlorosulphonic acid 1754 10% 2.27 ------7803-51-2 phosphine 2199 10% 2.27 ------
Attachment Federal Government IR 114 Page 6 of 6
LIST OF SUBSTANCES Representative Liquid PART 2 Hydrocarbon Samples Column 1 Column 2 Column 3 Concentration (% w/w) CAS Minimum Diluted Registry Name of Substance UN Number Concentration Quantity Synthetic Oil Condensate Bitumen Number (tonnes) 7803-52-3 stibine 2676 10% 2.27 ------8014-95-7 sulphuric acid, fuming (oleum) 1831 NA 4.50 ------10025-87- 3 phosphorus oxychloride 1810 10% 2.27 ------10035-10- 6 hydrogen bromide (hydrobromic acid) 1048 and 1788 10% 1.13 ------10049-04- 4 chlorine dioxide NA 0.01 0.45 ------10102-43- 9 nitric oxide (nitrogen monoxide) 1660 10% 4.50 ------10102-44- 0 nitrogen dioxide 1067 10% 1.13 ------10294-34- 5 boron trichloride 1741 10% 2.27 ------13463-39- 3 nickel carbonyl 1259 1% 0.45 ------13463-40- 6 iron pentacarbonyl 1994 10% 1.13 ------19287-45- 7 diborane 1911 10% 1.13 ------20816-12- 0 osmium tetroxide 2471 1% 0.22 ------26471-62- 5 toluene diisocyanate 2078 10% 4.50 ------
NOTE: The percentage concentration in column 2 is the percentage concentration based on the proportion of the weight of the substance to the weight of the mixture.