Fish and Fish Habitat Assessment of Westslope Cutthroat Trout
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LLG 1.1 Response to Livingstone Landowners Groups NOVA Gas Transmission Ltd. (LLG) Information Request No. 1 NGTL West Path Delivery 2023 Project GH-002-2020 IR Number: LLG 1.1 Category: Environmental Matters – Fish and fish habitat Topic: Assessment of Westslope Cutthroat Trout population abundance in Rock Creek. Reference: i) CER Filing Manual Guide A - Facilities Applications Table A-2: Filing Requirements for Biophysical Elements, Fish and Fish Habitat Filing Requirements page 77 (PDF page 97 of 286) ii) Applicant’s Guide Supporting the “Authorizations Concerning Fish and Fish Habitat Protection Regulations”, Section 4.0 Application requirements for non-emergency situations. iii) NGTL, West Path Delivery 2023 Application, ESA Part 2, Section 8.1 Scope of Assessment, 8.1.5 Residual Effects Description Criteria, Table 8.2, page 8.8 (PDF page 146 of 612), C09063-11 iv) NGTL, West Path Delivery 2023 Application, ESA Part 2, Section 8.2 Existing Conditions for Aquatic Resources, 8.2.1.1 Fish and Fish Habitat, pages 8.10-8.13 (PDF pages 148-150 of 612), C09063-11 v) NGTL, West Path Delivery 2023 Application, ESA Part 2, Section 8.6 Assessment of Cumulative Effects on Aquatic Resources, 8.6.3 Summary of Residual Cumulative Effects on Aquatic Resources, Table 8.21, page 8.120 (PDF page 258 of 612), C09063-11 vi) NGTL, West Path Delivery 2023 Application, ESA Part 2, Section 8.7 Determination of Significance, page 8.122 (PDF page 260 of 612), C09063-11 Preamble: Reference i) requires identifying fish species and their life stages in the study area, as well as their contribution to local fisheries or to ecological importance and requires describing the general population status of the fish species identified. Reference ii) includes fish abundance as a prescribed information requirement in the application for an Authorization under Paragraph 35(2)(b) of the Fisheries Act Regulations. Reference iii) in Table 8.2 states that residual effects on aquatic resources will be characterized as low where the measurable change to fish and fish habitat is within applicable guidelines, legislated June 10, 2021 Page 1 of 6 LLG 1.1 Response to Livingstone Landowners Groups NOVA Gas Transmission Ltd. (LLG) Information Request No. 1 NGTL West Path Delivery 2023 Project GH-002-2020 requirements and/or federal and provincial management objectives, or that does not affect sustainability and productivity of fish populations and characterized as moderate where the measurable change in fish and fish habitat is not within applicable guidelines, legislated requirements and/or federal and provincial management objectives but does not affect sustainability and productivity of fish populations. Reference iv) in Section 8.2.1.1 Fish and Fish Habitat states that Alberta FWMIS data were reviewed to identify species documented within the LAA. Reference v) in Table 8.21 states the Residual Cumulative Effects Characterization for a Change in fish habitat and fish mortality risk for the Lundbreck Section is low to moderate. Reference vi) in 8.7 Determination of Significance states project-related residual effects are unlikely to affect the sustainability of fisheries and that by obtaining the required permits under SARA for fish handling and for watercourse crossings in critical habitat, where applicable and if approved, the Project will be consistent with the goals and objectives of the recovery strategies for species at risk. Furthermore, it is stated the level of confidence in this prediction is high based on the quality of baseline information. Request: As requested in i) and ii), please identify the ecological importance, general population status, and abundance of the Rock Creek isolated headwater population of Westslope Cutthroat Trout by providing: a) A summary of current relative abundance data in FWMIS for adult and juvenile Westslope Cutthroat Trout, reporting the data in the context of the Alberta Fish Sustainability Index (FSI) ranking scale (0-5) ranging from high to low risk populations in terms of backpack electrofishing catch rates (fish/300 m). Data are documented as being reviewed in iv) but the review missed key information from surveys in 2010, 2011, and 2016 that are included in FWMIS; b) A summary map produced using FSI data available in FWMIS that highlights current and historical adult and juvenile densities in Rock Creek compared to all other Westslope Cutthroat Trout populations in Alberta; c) Quantitative assessment of whether abundance of fish in the population is stable at levels reflected by existing data available in June 10, 2021 Page 2 of 6 LLG 1.1 Response to Livingstone Landowners Groups NOVA Gas Transmission Ltd. (LLG) Information Request No. 1 NGTL West Path Delivery 2023 Project GH-002-2020 FWMIS, whether an updated assessment of abundance is required, and whether Project effects on abundance are expected; d) A detailed description of the scientific literature reviewed, population assessment methods followed, and data supporting NGTL’s assessment in iii), v), and vi) that quantifies the Project- related residual effects on fish mortality as low to moderate and the sustainability of the Rock Creek Westslope Cutthroat Trout population are unlikely. Response: NGTL notes that although several unnamed tributaries to Rock Creek will be crossed by the Lundbreck Section, Rock Creek is not crossed. It is within the fish and fish habitat regional assessment area (RAA) of the Lundbreck Section. With some exceptions, the responses below are focused on the unnamed tributaries to Rock Creek crossed by the Lundbreck Section, as identified in Section 8.2.2.3 of the ESA.1 a) and b) Current adult westslope cutthroat trout density is ranked as 1 – very low (backpack electrofishing average capture of adult westslope cutthroat trout /300 m is 1.6) (see Attachment LLG 1.1-1; AEP 2021a,b). Historic adult westslope cutthroat trout density is ranked as 5 – very high (see Attachment LLG 1.1-2; Miller and MacDonald 1949; AEP 2021a,b). Current juvenile westslope cutthroat trout density is ranked as 1 – very low (backpack electrofishing average capture of immature westslope cutthroat trout /300 m is 2.6). (refer to Attachment LLG 1.1-3; AEP 2021a). No data is publicly available for historic juvenile density (AEP 2021a,b). c) It is NGTL’s understanding that Alberta Environment and Parks (AEP) determines the status of fish populations and whether an updated assessment of abundance is required; therefore, the information requested in c) has not been provided. Please refer also to NGTL’s response to d), below. d) For the assessment of potential effects on fish and fish habitat, two potential effects were examined that could influence or affect the local and regional abundance and distribution of fish species: change in fish habitat and change in fish mortality risk. These two potential effects were used as surrogates for assessing potential Project effects on fish abundance and distribution. 1 CER Filing ID: C09063-11. June 10, 2021 Page 3 of 6 LLG 1.1 Response to Livingstone Landowners Groups NOVA Gas Transmission Ltd. (LLG) Information Request No. 1 NGTL West Path Delivery 2023 Project GH-002-2020 NGTL reviewed information describing existing fish abundance and distribution, and habitat sensitivity in the Lundbreck Section RAA (Nelson and Paetz 1992; Scott and Crossman 1998; ASRD and ACA 2006; ESRD 2012; COSEWIC 2016; DFO 2019a,b; DFO 2020; GOA 2020; AEP 2021a; GOC 2021) and literature that has assessed similar project-related potential effects on fish and fish habitat (McKinnon and Hnytka 1988; Anderson et al. 1998; Reid and Anderson 1999; Reid and Anderson 2000; Reid et al. 2002, 2004; CAPP et al. 2005, 2012; Polvi et al. 2014; Cott et al. 2015). The Rock Creek westslope cutthroat trout population was not quantitatively assessed; however, the potential for the Project to affect the population was evaluated qualitatively based on the literature provided above. The assessment considered that all fish species and their life stages documented in the RAA could be present in the LAA if habitat was suitable, in the absence of barriers to fish movement (refer to Appendix G.1 of the ESA2 and NGTL West Path Delivery 2023 Project Fish and Fish Habitat Technical Data Report – 2020 Update, Attachment CER 2.17-13 ). Refer to CER 2.18 a.1) for an explanation of potential fish mortality from the Project and CER 2.18 a.2) for a discussion on localized effects on fish populations.4 As discussed in Section 8.5.2.3 of the ESA5, the residual effects on change in fish mortality risk are predicted to be low in magnitude for watercourse crossings along the Lundbreck Section with the implementation of NGTL’s proposed mitigation measures. As fish mortalities are either not anticipated or are predicted to be low, effects on the Rock Creek westslope cutthroat trout population are unlikely. Construction of the Lundbreck Section is predicted to have a low magnitude contribution to cumulative effects on fish mortality risk at the RAA scale, which is summarized in Section 8.6 of the ESA6. Reference: AEP (Alberta and Environment and Parks). 2021a. Fish & Wildlife Internet Mapping Tool. Accessed Jun 2021 from: https://maps.alberta.ca/FWIMT_Pub/Viewer/?Viewer=FWIMT_Pub AEP. 2021b. Westslope Cutthroat Trout FSI Accessed June 2021 from: https://www.alberta.ca/westslope-cutthroat-trout-fsi.aspx#jumplinks-0 2 CER Filing ID: C09063-13, PDF pages 91 to 238 of 524. 3 CER Filing ID: C12449-1, PDF pages 297 to 379 of 463. 4 CER Filing ID: C12449-1, PDF pages 381 to 382 of 463. 5 CER Filing ID: C09063-11, PDF pages 232 to 235 of 612. 6 CER Filing ID: C09063-11, PDF pages 254 to 255 of 612. June 10, 2021 Page 4 of 6 LLG 1.1 Response to Livingstone Landowners Groups NOVA Gas Transmission Ltd.