Table of Contents

Information Request No. 1 ...... 2 Engineering Matters ...... 2 1.1 Pipeline Segments...... 2 1.2 Geohazards ...... 2 1.3 Pressure Control and Overpressure Protection ...... 3 1.4 Quality Management ...... 4 Environment Matters ...... 5 1.5 Potential effects of Operations and Maintenance Activities on Species listed in Schedule I of the Species at Risk Act ...... 5 1.6 Soil Survey ...... 6 1.7 Temporary Construction Camps ...... 7 1.8 Section 58 Environmental Protection Plan ...... 8 1.9 Yellow Rail Surveys ...... 9 1.10 Amphibian Surveys ...... 10 1.11 Songbird Surveys ...... 10 1.12 Common Nighthawk Surveys ...... 11 1.13 Wildlife Reconnaissance Surveys ...... 11 1.14 Site Access ...... 12 1.15 Watercourse Restricted Activity Period...... 12 1.16 Watercourse Numbers and Classifications ...... 12 1.17 Wetlands ...... 13 1.18 Vegetation Community Classification Data Issues...... 14 1.19 Old Seral Stage Forest Data Issues ...... 16 1.20 Rare Plant Survey for the Elmworth Section ...... 18 Land Matters ...... 18 1.21 Project Map ...... 18 1.22 Land Requirements ...... 19 1.23 Permanent Right of Way (ROW) Requirements ...... 19 1.24 Routing for Elmworth Section ...... 20 Market Matters ...... 21 1.25 NGTL Exports at East Gate ...... 21 1.26 The Role of the NGTL System and British Columbia LNG Exports ...... 21 Socio-economic Matters ...... 22 1.27 Erratum ...... 22 1.28 Cabin Location ...... 22 1.29 Historical Resources ...... 23

1 NOVA Gas Transmission Ltd. (NGTL) Sections 58 and 52 National Energy Board Act (NEB Act) – Application for 2020 Construction NGTL 2021 System Expansion Project (Project) File OF-Fac-Gas-N081-2018-03 02 Filed 20 June 2018 Hearing Order GH-003-2018

Information Request No. 1

Engineering Matters

1.1 Pipeline Segments Reference: i) NGTL, Application, Section 7.1.3 Project Component Tie-Ins and Routing, pages 7-2 to 7-6 (PDF pages 94 to 98 of 244), A92619-1

Preamble: The reference provides a description of the pipeline sections, however there is no specific location information regarding the start and end points of each section.

Request: For each pipeline section, provide the start and end locations.

1.2 Geohazards Reference: i) NGTL, Application, Section 7.1.1 Route Selection Criteria, pages 7-1 to 7-2 (PDF pages 93 to 94 of 244), A92619-1 ii) NGTL, Application, Section 7.6.1 Geohazards, page 7-29 (PDF page 121 of 244), A92619-1 iii) NGTL, Application, Section 7.4.2 Minimum Depth of Cover, page 7-17 (PDF page 109 of 244), A92619-1 iv) NGTL, Supplemental Report and Errata, Section 1.0 Introduction, page 1-1 (PDF page 2 of 111), A94156-1

Preamble: Reference i) specifies that terrain subject to geotechnical issues such as areas of unstable slopes, problem soils or known seismic activity would be avoided as part of the route selection criteria. Reference ii) states that terrain assessment is underway to identify key areas of concern along the route. Geological hazards evaluated in the assessment include potential landslides, debris flow, fluvial scour and significant slopes. According to reference iii), the minimum depth of cover for pipeline crossings of watercourses may be increased at locations of potential scour of the watercourse bed. As engineering design and construction planning progresses, the requirement for increased depth of cover will be evaluated.

2 Reference iv) notes that geotechnical reports were anticipated to be submitted in September 2018, however investigations are ongoing for the proposed trenchless crossings. The geotechnical reports for the trenchless crossings will be incorporated in the final feasibility reports and are anticipated to be submitted to the Board with Additional Written Evidence. The Board requires further information for areas that may be subject to geotechnical issues such as unstable slopes or watercourses where additional depth of cover may be required.

Request: a) Provide information on any slopes along the Project route where there may be potential instability, including, at a minimum, the following:

a.1) a map of the locations; and

a.2) a description of the mitigation measures, including slope stabilization and monitoring (e.g., Strain gauges, if applicable).

b) Provide additional information on each watercourse along the Project route where there is a potential for scour of the watercourse bed, including, at a minimum, the following:

b.1) a map of the watercourse location;

b.2) current watercourse bed depth below grade;

b.3) potential scour depth;

b.4) minimum proposed depth of cover when accounting for the scour depth; and

b.5) actions to be taken to mitigate the effect of scouring in these areas.

c) If any of the information requested in a) or b) is not yet available, provide a timeline for submission to the Board.

1.3 Pressure Control and Overpressure Protection Reference: i) NGTL, Application, Section 7.2.2 TransCanada Specifications and Standards, Table 7-2: Preliminary List of Company Specifications and Standards, pages 7-8 to 7-9 (PDF pages 100 to 101 of 244), A92619-1 ii) NGTL, Application, Section 7.5.4 Pressure Control and Overpressure Protection, page 7-20 (PDF page 112 of 244), A92619-1 iii) NEB Filing Manual, Chapter 4 Physical Projects, Guide A Facilities Applications, A.1.2 Engineering Design Principles, pages 4A-13 to 4A-14 (PDF pages 71 to 72 of 285)

3 Preamble: Reference i) does not include any company specifications or standards related to Pressure Control (PC) and Overpressure Protection (OPP). Reference ii) states that PC and OPP at the NGTL facilities meet CSA Z662-15 design standards and design, operation and maintenance philosophy for regular inspection, assessment and testing at the required intervals to ensure the facilities are adequate to meet capacity and reliability requirements. Reference iii) outlines the requirement to file a listing of all primary codes and standards, including the version and date of issue that will be followed in the design, material selection, construction, operation and maintenance for each element of the applied-for facility, including (among other components) pressure control and overpressure protection. Although NGTL has stated that PC and OPP meet CSA Z662-15 design standards, the Board requires confirmation that this is reflected in the company standards and specifications to be followed for the design construction and operation of the Project.

Request: Provide a list of the company specifications and standards relating to pressure control and overpressure protection for the Project, as required by reference iii).

1.4 Quality Management Reference: i) NGTL, Application, Section 7.2.3, Quality Management Program, page 7-10 (PDF page 102 of 244), A92619-1 ii) NGTL, Application, Section 7.2.4, Pipe Procurement, page 7-11 (PDF page 103 of 244), A92619-1 iii) NEB Filing Manual, Chapter 4 Physical Projects, Guide A Facilities Applications, A.1.2 Engineering Design Principles, page 4A-14 (PDF page 72 of 285) iv) CSA Z662-15, Clause 6.2.2

Preamble: Reference i) indicates that TransCanada PipeLines Limited (TransCanada) has a Quality Management System where all purchased items and contracted services will be obtained from suppliers and contractors of assessed capabilities who have been pre-qualified in accordance with TransCanada’s internal supplier management and pre-qualification procedures or have been pre-qualified by a prime contractor to TransCanada. According to reference ii), TransCanada has an established line pipe supply base with more than 20 pre-qualified mills in North America and overseas, and TransCanada has pre-qualified the pipe mills and coating plants based on technical merit. Reference iii) states as a filing requirement that if a proposed project requires new materials, a proponent must provide, in tabular format,

4 material supply chain information (e.g., forming and manufacturing locations) and the associated Quality Assurance verification activity. Reference iv) requires that care shall be taken in the selection of equipment and methods used in handling, transporting, stockpiling, and placing of pipe and components to prevent damage to the pipe, coating, and any lining. The Board seeks additional information regarding quality management for the materials to be used in the Project.

Request: Provide the following:

a) the date(s) that the pipe mills and quenching and tempering fitting manufacturers were last qualified by TransCanada personnel;

b) as per reference iii), material supply chain information for the materials used in the Project with the associated Quality Assurance verification activity; and

c) a description of how NGTL will implement the requirements of reference iv) in regards to the procured pipe to be used in the Project.

Environment Matters

1.5 Potential effects of Operations and Maintenance Activities on Species listed in Schedule I of the Species at Risk Act Reference: i) NGTL, Application, page i (PDF page 5 of 244), A92619-1 ii) NEB Onshore Pipeline Regulations, Section 48, page 21 (PDF page 27 of 33) iii) NEB, Guidance Notes for the National Energy Board Onshore Pipeline Regulations, Section 48 Environmental Protection Program, updated October 2016

Preamble: In reference i), NGTL has requested an authorization pursuant to sections 52 and 58 of Part III, and Part IV of the NEB Act, for a Certificate of Public Convenience and Necessity and related approvals for the 2021 NGTL System Expansion Project.

Should such an authorization be granted, then as part of the authorization, NGTL would be able to conduct necessary operations and maintenance (O&M) activities for the life of the proposed pipeline subject to the notification requirements of the Board.

With respect to the potential impact of future O&M activities on species listed on Schedule 1 of the Species at Risk Act (SARA-listed), the Board notes that it is uncertain: (1) where and when future O&M activities may be needed, and what land or environmental setting could be affected, and

5 (2) what SARA-listed species may be present at any particular site in the future and what their SARA-listed status may be at that time.

Reference ii) requires that companies protect the environment by developing, implementing and maintaining a systematic environmental protection program. The Onshore Pipeline Regulation Guidance Notes (Reference iii) further add that an environmental protection program should (among other aspects):

• proactively manage environmental hazards and effects; • manage environmental risks throughout the lifecycle of the pipeline; and • include processes to manage documentation and continually improve performance (including how the documentation illustrates continual improvement).

The Board expects that NGTL’s management system will adequately protect SARA-listed species and their habitat on future O&M sites. The Board seeks certainty and evidence to demonstrate that this is the case.

Request: Provide the relevant excerpts from NGTL’s management systems documentation setting out the procedural steps to be taken, and the accountable chain of command, that describes how NGTL:

a) identifies the potential for SARA-listed species at risk or their habitat to occur at O&M sites; b) identifies when to consult with appropriate expert federal and provincial government departments and with Indigenous peoples; c) determines the mitigation necessary (including consideration of alternatives) to protect SARA-listed species and their habitat at O&M sites; d) communicates this information to its Field Operations/construction program staff to ensure implementation at its O&M sites; and e) ensures this procedure (or these steps) is kept up to date.

1.6 Soil Survey Reference: i) NGTL, Application, Environmental and Socio-economic Assessment (ESA), Appendices C to K, Appendix C Soil and Soil Productivity (PDF pages 1 to 49 of 559), A92619-19

Preamble: Reference i) is the technical report Soil Survey for the Proposed NOVA Gas Transmission Ltd. Clearwater West Project – GPML Loop No. 3 (Elmworth Section) Project completed by Paragon Soil and Environmental

6 Consulting Inc. (Paragon). The Exova Laboratory Report (Appendix G (PDF page 49 of 559) of the Paragon report), was not included with this report.

Request: Provide a copy of the Exova Laboratory Report (Appendix G) from the above noted report.

1.7 Temporary Construction Camps Reference: i) NGTL, Application, Section 9.5.8 Construction Camps and Accommodations, page 9-12 (PDF page 154 of 244), A92619-1 ii) NGTL, Application, ESA, Sections 1 to 4, Section 2.4.1.5 Temporary Infrastructure and Construction Camps, page 2-15 (PDF page 42 of 112), and Section 4.2.1 Temporal and Spatial Boundaries, page 4-9 (PDF page 67 of 112), A92619-10 iii) NGTL, Application, ESA, Sections 5 to 8, Section 7.3 Potential Effects, page 7-61 (PDF page 227 of 321), and Section 8.3 Potential Effects, page 8-34 (PDF Page 292 of 321), A92619-11 iv) NGTL, Application, ESA, Sections 9 to 10, Section 9.3 Potential Effects, page 9-20 (PDF page 22 of 114) and Section 10.3 Potential Effects, page 10-41 (PDF page 93 of 114), A92619-12 v) NGTL, Application, ESA, Sections 12 to 16, Section 12.3 Potential Effects, pages 12-145 to 12-146 (PDF pages 149-150 of 362), A92619-14

Preamble: Reference i) states that construction of the Nordegg compressor station unit addition will require a temporary construction camp, located nearby the existing Nordegg Compressor Station within an area previously used as a camp. Reference ii) (PDF page 67) defines the local study area for most of the biophysical Valued Components (VCs) as a 1.1 km wide corridor centered over the proposed centreline and expanded to an approximate 2 km square at the Wapiti River, Smoky River, Latornell River, Simonette River, Deep Valley Creek, Little Smoky River, McLeod River, Pembina River and North Saskatchewan River crossings. The local study area for each of the three compressor stations includes an approximate 50 m radius from the proposed fence line of each compressor station unit addition. Reference ii) (PDF page 42) states that based on preliminary construction planning, temporary construction camps are not expected to be required for construction of the pipeline component of the Project. Reference ii) further states that should the need for temporary construction camps be identified for pipeline construction, the camps will be assessed with the development of the Section 58 environmental protection plan (EPP). References iii) through v) state that the locations of the temporary construction camps and infrastructure have not been finalized. References iii) through v) also state that the siting, development, use and reclamation of temporary construction camps and infrastructure will reflect current

7 industry standards and comply with applicable regulations; therefore, temporary construction camps and infrastructure are not evaluated further for several environmental VCs, including fish and fish habitat, wetlands, vegetation, water quality and quantity and fish species at risk. The Board requires clarification on the status of the location of the temporary construction camp proposed for the Nordegg Compressor Unit addition and clarification on how any additional temporary construction camps will be assessed.

Request: Provide the following: a) confirmation whether the location for the temporary construction camp at the Nordegg Compressor Station site has been identified; b) confirmation that the above location is within the local study area for the Project. If yes, provide an aerial photo with the location. If no, indicate when the location will be identified and how the Board will receive the environmental assessment information for the site; c) confirmation that the location of any additional temporary construction camps and infrastructure would be sited within the local study area. If this is not the case, identify how the Board will be made aware of the location(s) and the environmental assessment information for these locations; d) clarification of the statement in reference iii) that should the need for temporary construction camps be identified for pipeline construction, the camps will be assessed with the development of the Section 58 EPP; and e) a copy of the NGTL Code of Conduct that will apply to the workers housed in the temporary construction camp(s) for the Project.

1.8 Section 58 Environmental Protection Plan Reference: i) NGTL, Application, Section 1.5 Section 58 Activities, page 1-4 (PDF page 44 of 244), A92619-1

Preamble: Reference i) states that a stand-alone EPP is planned to support the activities proposed under section 58 of the NEB Act and would be submitted to the Board in advance of the activities. The Board requires clarification on whether a stand-alone EPP will be submitted for activities proposed under Section 58.

Request: Confirm that a stand-alone EPP for section 58 activities will be submitted to the Board, and the expected timeline for submission.

8 1.9 Yellow Rail Surveys Reference: i) NGTL, Environment and Socio-economic Assessment (ESA) Update, Appendix G, Wildlife and Wildlife Habitat, and Wildlife Species at Risk Technical Data Report, Section 2.1.4 Rail Call Playback Surveys, Page 2-4 (PDF page 15 of 98), A94156-9 ii) NGTL, ESA Update, Appendix G, Wildlife and Wildlife Habitat, and Wildlife Species at Risk Technical Data Report, Sections 3.4.2.3 and 3.4.3.2, Page 3-16 (PDF page 33 of 98), A94156-9

Preamble: Reference i) states that yellow rail surveys were conducted on the Elmworth section by Stantec Consulting Ltd. (Stantec) and the surveys on the remaining sections were conducted by Wood Environment and Infrastructure Solutions (Wood). The surveys conducted for the Elmworth section followed the yellow rail survey guidelines outlined in the Alberta Sensitive Species Inventory Guidelines (ESRD 2013), where applicable, whereas the surveys conducted for the remainder of the Project sections followed Environment and Climate Change Canada’s recommended guidelines, and the BC Resource Information Standards Committee. Reference i) indicates that surveys in the Elmworth section used a different timing of calls as well as a mixture of species calls during the survey. Reference ii) states that yellow rail surveys were not conducted on the McLeod River Connection and Dismal Creek sections due to lack of land access. The Board is not clear why Wood and Stantec did not apply the same survey methodology across all sections of the Project or whether additional surveys will be conducted where there was no land access.

Request: Provide the following: a) the rationale for not using the same survey guidelines and methodologies for the Elmworth section and the remainder of the Project sections, and how these different methods may have affected the survey results; and b) a statement indicating whether any yellow rail surveys are planned within the McLeod River Connection and Dismal Creek sections prior to construction, and b.1) if yes, provide a description of when the surveys will be conducted, and the methodology to be used; or b.2) if no, provide the rationale for not conducting surveys.

9 1.10 Amphibian Surveys Reference: i) NGTL, ESA Update, Appendix G, Wildlife and Wildlife Habitat, and Wildlife Species at Risk Technical Data Report, Section 2.1.1 Amphibians, Pages 2-1 to 2-2 (PDF pages 12 to 13 of 98), A94156-9 ii) NGTL, ESA Update, Appendix G, Wildlife and Wildlife Habitat, and Wildlife Species at Risk Technical Data Report, Sections 3.1.2.2 and 3.1.2.3, Page 3-2 (PDF page 19 of 98), A94156-9

Preamble: Reference i) indicates that a visual search survey was conducted for amphibians within the Elmworth section, and that auditory surveys were conducted for the remaining sections of the Project. Reference ii) states that supplemental amphibian surveys within the Deep Valley and McLeod River Connection sections were not conducted due to the lack of land access. The Board is not clear why Wood and Stantec did not apply the same survey methodology across all sections of the Project, and whether additional surveys will be conducted where there was no land access.

Request: Provide the following: a) the rationale for using different amphibian survey types for different sections of the Project, and how that may have impacted the results; and b) a statement indicating whether any amphibian surveys are planned within the Deep Valley and McLeod River Connection sections prior to construction, and b.1) if yes, provide a description of when the surveys will be conducted, and the methodology to be used; or b.2) if no, provide the rationale for not conducting surveys.

1.11 Songbird Surveys Reference: i) NGTL, ESA Update, Appendix G, Wildlife and Wildlife Habitat, and Wildlife Species at Risk Technical Data Report, Section 3.2.1.2, Page 3-9 (PDF page 26 of 98), A94156-9

Preamble: Reference i) states that supplemental songbird surveys were not conducted in the Elmworth section of the Project.

Request: Please provide: a) the reason for not conducting supplemental songbird surveys in the Elmworth section; and b) a statement indicating whether these surveys will be conducted prior to

10 construction, and b.1) if yes, provide a description of when the surveys will be conducted, and the methodology to be used; or b.2) if no, provide the rationale for not conducting surveys.

1.12 Common Nighthawk Surveys Reference: i) NGTL, ESA Update, Appendix G, Wildlife and Wildlife Habitat, and Wildlife Species at Risk Technical Data Report, Section 3.3.1.2, Page 3-12 (PDF page 29 of 98), A94156-9 ii) NGTL, ESA Update, Appendix G, Wildlife and Wildlife Habitat, and Wildlife Species at Risk Technical Data Report, Sections 3.3.2.3 and 3.3.3.2, Page 3-13 (PDF page 30 of 98), A94156-9

Preamble: Reference i) states that common nighthawk surveys were not conducted in the Elmworth section of the Project. Reference ii) states that common nighthawk surveys were not completed in the McLeod River Connection and the Dismal Creek sections of the Project due to lack of land access.

Request: Please provide: a) the reason for not conducting common nighthawk surveys in the Elmworth section; and b) a statement indicating whether a common nighthawk survey will be conducted in the Elmworth, Dismal Creek, and McLeod River Connection sections prior to construction, and b.1) if yes, provide a description of when the surveys will be conducted, and the methodology to be used; or b.2) if no, provide the rationale for not conducting surveys.

1.13 Wildlife Reconnaissance Surveys Reference: ii) NGTL, ESA Update, Appendix G, Wildlife and Wildlife Habitat, and Wildlife Species at Risk Technical Data Report, Section 3.6 Reconnaissance Survey, Page 3-19 (PDF page 36 of 98), A94156-9

Preamble: Reference i) states that a wildlife reconnaissance survey was conducted for the Elmworth section.

Request: Please provide a rationale for why a wildlife reconnaissance survey was conducted on the Elmworth section, but no other section of the Project.

11

1.14 Site Access Reference: i) NGTL, ESA Update, Appendix C, Aquatics Technical Data Report, Table 3.2-1, Page 3-9 (PDF page 22 of 405), A94156-5

Preamble: Reference i) indicates that there was no access to sites V-WC06 and V- WC08 during the field surveys. Reference i) also indicates that these two sites were determined to be drainages, and that no measurements were taken. The Board requires more information to understand how the drainage determination was made, when as noted, there was no access to the two sites identified above in reference i).

Request: Provide an explanation of how the determination was made that sites V- WC06 and V-WC08 were determined to be drainages.

1.15 Watercourse Restricted Activity Period Reference: i) NGTL, ESA Update, Appendix C, Aquatics Technical Data Report, Section 3.2.2., Page 3-11 (PDF page 24 of 405), A94156-5 ii) NGTL, ESA Update, Appendix C, Aquatics Technical Data Report, Table 3.2-4, Page 3-13 (PDF page 26 of 405), A94156-5

Preamble: Reference i) states that each watercourse in the Elmworth Section is a Class C with a restricted activity period from August 1 to July 15. Reference ii) states that the restricted activity period for the Beaverlodge River located at Site E-WC02 is from April 16 to July 15.

Request: Please clarify the restricted activity period for the Beaverlodge River crossing located at site E-WC02.

1.16 Watercourse Numbers and Classifications Reference: i) NGTL, ESA Update, Appendix C, Aquatics Technical Data Report, Section 3.3.2, Page 3-23 (PDF page 36 of 405) and Section 3.3.2.4, Page 3-33 (PDF page 46 of 405), A94156-5 ii) NGTL, ESA Update, Appendix C, Aquatics Technical Data Report, Table 3.3-4, Pages 3-26 to 3-32 (PDF pages 39 to 45 of 405), A94156-5

Preamble: Section 3.3.2 of reference i) states that there are 37 watercourses and 15 drainage crossings in the Deep Valley section of the Project. It also indicates that 31 of these watercourses are categorized as Class C.

12 Section 3.3.2.4 of reference i) states that of the 45 watercourses identified in the ESA, 31 were confirmed as watercourses and 14 were drainages. It further states that an additional five watercourses and three drainages were identified during the field surveys in the Deep Valley section. Reference ii) lists a total of 37 watercourses, with 29 of these categorized as a Class C watercourse and eight as Class B. The Board notes that the numbers of drainages, watercourses and classifications of watercourses are not consistently reported within the descriptions for the Deep Valley section of the Project, and are contradictory between report sections.

Request: a) Please provide the following for the Deep Valley Section: a.1) total number of watercourse crossings; a.2) breakdown of the number of Class C and Class B watercourses; and a.3) total number of drainages. b) Please verify that the watercourses and drainage numbers for the remaining pipeline sections are correct. Should the numbers be incorrect, provide the revised numbers as per a.1) through a.3) of this request.

1.17 Wetlands Reference: i) NGTL, ESA Update, Appendix F, Wetlands Technical Data Report, Section 2.2 Field Data Collection, Page 2-1 (PDF page 10 of 63), A94156-8

Preamble: Reference i) states that ground truthing surveys of representative wetlands were conducted and that site specific details for representative wetlands crossed by the Project footprint were collected and documented.

Request: Please provide the following: a) a description of what is meant by the term “representative wetland”; and b) a description of the methodology and criteria used to choose the representative wetlands.

13 1.18 Vegetation Community Classification Data Issues Reference: i) NGTL, ESA Update, Appendix E, Vegetation Technical Data Report, Section 3.3.1.1 and Table 3.3-1, Pages 3-1 to 3-2 (PDF pages 16 to 18 of 174), A94156-7 ii) NGTL, ESA Update, Appendix E, Vegetation Technical Data Report, Section 3.3.2.1 and Table 3.3-3, Pages 3-8 to 3-13 (PDF pages 24 to 29 of 174), A94156-7 iii) NGTL, ESA Update, Appendix E, Vegetation Technical Data Report, Section 3.3.2.2 and Table 3.3-4, Pages 3-14 to 3-18 (PDF pages 30 to 34 of 174), A94156-7 iv) NGTL, ESA Update, Appendix E, Vegetation Technical Data Report, Section 3.3.3.1 and Table 3.3-6, Pages 3-21 to 3-24 (PDF pages 37 to 40 of 174), A94156-7 v) NGTL, ESA Update, Appendix E, Vegetation Technical Data Report, Section 3.3.3.2 and Table 3.3-7, Pages 3-25 to 3-29 (PDF pages 41 to 45 of 174), A94156-7 vi) NGTL, ESA Update, Appendix E, Vegetation Technical Data Report, Section 3.3.3.3 and Table 3.3-8, Pages 3-30 to 3-33 (PDF pages 46 to 49 of 174), A94156-7 vii) NGTL, ESA Update, Appendix E, Vegetation Technical Data Report, Section 3.3.4.1 and Table 3.3-9, Pages 3-34 to 3-35 (PDF pages 50 to 51 of 174), A94156-7

Preamble: The Board notes that there are a number of sections within the Vegetation Community Classification section of the Vegetation Technical Data Report where the numbers in the analysis do not match the numbers in the associated Tables. 1. In reference i), Section 3.3.1.1 states that supplemental field studies showed natural vegetation is dominated by the Dogwood balsam poplar- aspen (e1) Ecological Land Class (ELC) occupying 288 ha (7%) of the Valhalla Section LSA. However Table 3.3-1 in reference i) shows that the Dogwood balsam poplar-aspen (e1) ELC occupies 9 ha (<1%) of the Valhalla Section LSA. 2. In reference ii), Section 3.3.2.1 indicates that the majority of the natural vegetation alteration in the Karr section will be within the dogwood balsam poplar-white spruce ELC with approximately 37 ha being altered, or less than 1% of the LSA. Table 3.3-3 in reference ii) identifies the dogwood balsam poplar-white spruce ELC in both the Central Mixedwood Natural sub-region at 37 ha of alteration due to the Project Footprint and an additional 3 ha of alteration of the dogwood balsam poplar-white spruce in the Dry Mixedwood Natural sub-region, for a total of 40 ha in the Karr section. 3. In reference iii), Section 3.3.2.2 states that field studies showed that natural revegetation occupies approximately 1793 ha (22%) in the Lower

14 Foothills Natural sub-region of the Deep Valley section of the Project. It also indicates that this is an 11 ha (less than 1%) decrease in area of natural vegetation compared to the prediction in the ESA. Table 3.3-4 in reference iii) shows the ESA prediction of natural vegetation in the Lower Foothills Natural sub-region to be 1782 ha (22%), and the results from the field studies show an increase in 11 ha to 1793 ha (22%). 4. Section 3.3.2.2 of reference iii) states that rivers are dominant within the naturally non-vegetated class of the Deep Valley LSA. It further states that the result is the same as the ESA prediction. Table 3.3-4 of reference iii) indicates that the ESA identified that Open sand would be dominant within the naturally non-vegetated class of the Deep Valley LSA. 5. Section 3.3.3.1 of reference iv) states that after field studies, a total of 144 ha (3% of the LSA) of natural vegetation will potentially be altered by the Project Footprint. Table 3.3-6 in reference iv) indicates that field studies identified that a total of 167 ha of natural vegetation (4% of the LSA) will potentially be altered due to the Project Footprint. 6. Reference v), Section 3.3.3.2, states that the supplemental field studies showed an increase of 3 ha of the natural vegetation within the Tall bilberry/arnica lodgepole pine ELC in the Upper Foothills Natural sub- region from the prediction in the ESA. Table 3.3-7 in reference v) identifies the ESA prediction for the natural vegetation in the Tall bilberry/arnica lodgepole pine ELC in the Upper Foothills natural region to be 509 ha and the field studies work resulted in 506 ha, a decrease of 3 ha. 7. Section 3.3.3.3 in reference vi) states that fieldwork indicated there is a 27 ha decrease in the low bush cranberry aspen-white spruce-lodgepole pine ELC in the Lower Foothills Natural sub-region when compared to the ESA prediction. However, Table 3.3-8 in reference vi) shows a 22 ha decrease in the field studies data (1007 ha) for the Lower Foothills Natural sub-region compared to the ESA prediction (1029 ha). 8. Section 3.3.3.3. in reference vi) further states that the field studies identified that the majority of the natural vegetation to be altered in the Brewster section belongs to the Labrador tea-mesic lodgepole pine-black spruce ELC (23 ha) and the tall bilberry/arnica lodgepole pine ELC (21 ha) (<1 % respectively). However, the data provided in Table 3.3-8 for the Brewster section in reference vi) identifies the Labrador tea-mesic lodgepole pine-black spruce ELC as having 10 ha of vegetation alteration, and the tall bilberry/arnica lodgepole pine ELC as having less than 1 ha of alteration. 9. Reference vii), Section 3.3.4.1 states that wetlands within the LSA for the Nordegg Compressor Station Unit addition are treed bogs and occupy 2 ha (9%) of the land base. The data shown in Table 3.3-9 of reference vii) do not support this statement, and indicate that Treed bogs occupy less than 1 ha of land. The Board requires clarification of these data errors and inconsistencies in order to conduct a proper review of the Vegetation Technical Data Report.

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Request: Please review and correct both the Table data and the analysis for each of the issues noted above in numbers 1 through 9, and provide the following: a) revised Tables indicating the correct numbers for all Project sections where there were discrepancies; b) revised analysis for each Project section where there were errors and/or inconsistencies between the analysis and tables; c) revised Section 4.0 Summary with updated summary points and conclusions based on the revisions completed in parts a) and b) of this request.

1.19 Old Seral Stage Forest Data Issues Reference: i) NGTL, ESA Update, Appendix E, Vegetation Technical Data Report, Table 3.6-1, Pages 3-45 (PDF page 61 of 174), A94156-7 ii) NGTL, ESA Update, Appendix E, Vegetation Technical Data Report, Section 3.6 and Table 3.6-2, Pages 3-45 to 3-46 (PDF pages 61 to 62 of 174), A94156-7 iii) NGTL, ESA Update, Appendix E, Vegetation Technical Data Report, Section 3.6 and Table 3.6-3, Page 3-47 (PDF page 63 of 174), A94156-7 iv) NGTL, ESA Update, Appendix E, Vegetation Technical Data Report, Section 3.6 and Table 3.6-4, Page 3-48 (PDF page 64 of 174), A94156-7 v) NGTL, ESA Update, Appendix E, Vegetation Technical Data Report, Section 3.6 and Table 3.3-5, Pages 3-48 to 3-49 (PDF pages 64 to 65 of 174), A94156-7 vi) NGTL, ESA Update, Appendix E, Vegetation Technical Data Report, Section 3.6 and Table 3.3-6, Page 3-50 (PDF page 66 of 174), A94156-7 vii) NGTL, ESA Update, Appendix E, Vegetation Technical Data Report, Section 3.6 and Table 3.6-7, Pages 3-50 to 3-51 (PDF pages 66 to 67 of 174), A94156-7

Preamble: The Board notes that there are a number of sections within the Vegetation Community Classification section of the Vegetation Technical Data Report where the numbers in the analysis do not match the numbers in the associated Tables. 1. In reference i), footnote 1, set out below Table 3.6-1 states that the Project Footprint may alter approximately 5% of old seral stage forest, however the Table indicates that alteration due to the Project Footprint is <1%. 2. Reference ii) (PDF page 61) states that based on field surveys in the

16 Karr section of the Project, there are approximately 1255 ha of old seral stage forest within the LSA. However, Table 3.6-2 shows that field surveys resulted in the identification of 1260 ha of old seral stage forest. 3a). Reference iii) states that a total of 63 ha of old seral stage forest in the Deep Valley section of the Project will be potentially altered by the Project Footprint. Table 3.6-3 however, indicates that 56 ha will be potentially altered, based on field studies. 3b). Further, footnote 1 set out below Table 3.6-3 states that the Project Footprint may alter approximately 3% of old seral stage forests, whereas the Table indicates 1%. 4a). Reference iv) states that the ESA indicated a total of 751 ha of old seral stage forest is present within the LSA for the McLeod River Connection section of the Project, however Table 3.6-4 indicates 752 ha. 4b).Further, Table 3.6-4 in Reference iv) states that a total of 2% of old seral stage forest will be potentially altered by the Project Footprint, while footnote 1 set out below Table 3.6-4 indicates 5% will be altered. 5a). In reference v), Table 3.6-5 shows that the ESA estimated 12% of old seral stage forest in the Robb section, verses 14% identified in the text. As well, Table 3.6-5 shows that the 2018 studies in the Robb section identified 13% of the LSA consisted of old seral stage forest, while the text indicates 14%. Table 3.6-5 also shows that 31 ha old seral stage forest in the Robb section will be altered, while the text states that 33 ha will be altered. 5b).Further, footnote 1, set out below Table 3.6-5 states that the Project Footprint may alter approximately 5% of old seral stage forest while Table 3.6-5 indicates only 1% will be altered. 6. In reference vi), the numbers provided in Table 3.6-6 and the Table footnote for the amount of old seral stage forest to be altered by the Project Footprint, being less than 1% and 3% respectively, are not the same. 7a). Reference vii) states that the field surveys indicated 1414 ha of old seral stage forest are present within the LSA for the Brewster section of the Project, however Table 3.6-7 indicates 1415 ha based on field studies. 7b). Further, Table 3.6-7 states that less than 1% of old seral stage forest will be potentially altered by the Project Footprint, while footnote 1 set out below Table 3.6-7te indicates 3% will be altered. The Board requires clarification of these data errors and inconsistencies in order to conduct a proper review of the Vegetation Technical Data Report.

Request: Please review and correct both the Table data and the analysis for each of the issues noted above and provide the following: a) revised Tables indicating the correct numbers for all Project sections where there were discrepancies;

17 b) revised analysis for each Project section where there were errors and/or inconsistencies between the analysis and tables; and c) revised Section 4.0 Summary with updated summary points and conclusions based on the revisions completed in parts a) and b) above.

1.20 Rare Plant Survey for the Elmworth Section Reference: i) NGTL, ESA Update, Appendix E, Vegetation Technical Data Report, Section 2.3 Field Data Collection, Page 2-4 (PDF page 14 of 174), A94156-7

Preamble: Reference i) states that Wood conducted a combined wetlands and spring rare plant survey from 10 to 22 June 2018 (spring) and a summer rare plant survey from 07 to 17 July 2018 for all sections of the Project except the Elmworth section. Reference i) further states that a separate wetland and rare plant survey was completed within the Elmworth section by Stantec and was conducted from 26 to 30 June 2018. The Board is not clear why Wood and Stantec did not apply the same survey methodology and timing across all sections of the Project.

Request: Provide the rationale for not conducting both early and late season rare plant surveys in the Elmworth section of the Project.

Land Matters

1.21 Project Map Reference: i) NGTL, Application, Appendix 15-2 Detailed Route Maps, pages 3 to 10 of 10 (PDF pages 3 to 10 of 10), A92619-9

Preamble: Reference i) contains the maps of the different sections of the Project. Additional information is required on these maps.

Request: a) Provide detailed route maps for each section of the Project, which include a clear depiction of where the proposed pipeline route is not contiguous with existing NGTL pipeline or other existing linear infrastructure. b) On the same maps requested in a), identify: b.1) the other existing linear infrastructures that run parallel with the proposed pipeline route; and b.2) all utility crossings.

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1.22 Land Requirements Reference: i) NGTL, Application, Section 11.3 Right-of-Way Requirements, Table 11-3, page 11-4 (PDF page 164 of 244), A92619-1 ii) NGTL, Application, Appendices 9 to 11, Appendix 11-1 Typical Right of Way Drawings, page 1 of 1 (PDF page 31 of 124), A92619-6

Preamble: Reference i) lists the approximate land required for permanent lands and temporary workspace (TWS). Additional information on NGTL proposed land requirements is needed. Reference ii) contains the typical sketches of the right of way (ROW) and TWS workspace configurations proposed for the pipeline components. Additional information is required to better understand NGTL’s proposed land requirements.

Request: a) Provide a table with the following information for each section of the Project, including but not limited to: a.1) length of pipeline loop; a.2) hectares of new ROW and TWS; a.3) percentage and length of pipeline located within existing NGTL land rights; a.4) percentage each of Crown lands and private lands; a.5) number of parcels each of Crown lands and private lands; a.6) percentage of utility crossings; and a.7) percentage and length of pipeline contiguous with existing linear disturbances. b) Provide the approximate length of new pipeline corresponding to each drawing in Appendix 11-1 (Reference ii), as applicable (e.g., R/W Detail 1A and 1B, R/W Detail 2A and 2B, and R/W Detail 3).

1.23 Permanent Right of Way (ROW) Requirements Reference: i) NGTL, Application, Section 11.3 Right-of-Way Requirements, pages 11-3 to 11-4 (PDF pages 163 to 164 of 244), A92619-1 ii) NGTL, Application, Appendix 8-1 to 8-2, Appendix 8-1 Wapiti River Crossing Preliminary Feasibility Report, pages 1 to 46 of 46 (PDF pages 1 to 48 of 72), A92619-4

Preamble: In Reference i), NGTL states that the proposed permanent ROW and preliminary temporary work space (TWS) requirements for the pipeline components are shown in Appendix 8-1.

19 Reference ii) is Appendix 8-1 (the Wapiti River Crossing Preliminary Feasibility Report); it does not provide the proposed permanent ROW and preliminary TWS requirements for the pipeline components as stated in Reference i).

Request: Provide an appendix containing the proposed permanent ROW and preliminary TWS requirements for the pipeline components.

1.24 Routing for Elmworth Section Reference: i) NGTL, Application, ESA, Sections 1 to 4, Section 2.3.2.1 Grand Prairie West Area, page 2-3 (PDF page 30 of 112), A92619-10 ii) NGTL, Application, Section 7.1.3 Project Component Tie-Ins and Routing, page 7-3 (PDF page 95 of 244), A92619-1 iii) NGTL, Application, Section 11.3 Right-of-Way Requirements, Table 11-2 Parallel ROW and Non-Parallel ROW, page 11-3 (PDF page 163 of 244), A92619-1

Preamble: Reference i) states that the Elmworth Section is approximately 46.4 km in length. Reference i) also states that for the Elmworth Section, the proposed route runs adjacent to other existing linear infrastructure, and not adjacent to the existing Grande Prairie Mainline (GPML) section that it is looping (for approximately 33 km of the total length). In reference ii) NGTL states that for the Elmworth Section, the proposed route runs parallel to the existing GPML for approximately 11 km, and parallel to other existing linear infrastructure for approximately 24 km. Reference iii) indicates that approximately 34 km of the Elmworth Section is parallel ROW and approximately 12 km is non-parallel ROW. The Board notes that the routing information is not consistently reported for the Elmworth Section of the Project.

Request: Clarify how much of the proposed route for the Elmworth Section: a) runs parallel to the existing GPML; b) runs parallel to other existing linear infrastructure; and, c) is non-parallel to the existing GPML or other existing linear infrastructure.

20 Market Matters

1.25 NGTL Exports at East Gate Reference: i) NGTL, Application, Section 5.2.1 Firm Transportation Delivery (FT- D) Commitments, page 5-4 (PDF page 82 of 244), A92619-1

Preamble: In reference i), NGTL states that the Expansion Capacity Open Season for FT-D1 Service at East Gate (EGAT) was fully subscribed by shippers, thus demonstrating the need and commercial support for the Project. The export Expansion Capacity offered in association with this Project totals 985,000 GJ/d with a commercially required in-service date of April 2021. The Board requires additional information about downstream capacity to accommodate the additional throughput.

Request: Provide responses to the following:

a) Is there enough capacity on the TCPL Mainline and Foothills Saskatchewan pipelines to accommodate this additional throughput at EGAT?

b) If not, what is required from the TCPL Mainline and Foothills Saskatchewan in order to accommodate this additional throughput?

1.26 The Role of the NGTL System and British Columbia LNG Exports Reference: i) NGTL, Application, Section 3.1.1 Export Demand, page 3-2 (PDF page 60 of 244), A92619-1

Preamble: In reference i), NGTL states that liquefied natural gas (LNG) exports to the British Columbia (BC) west coast, which are projected to start-up in mid-2024 and mid-2028, make up the remainder of the forecasted (system) export demand. The Board requires more information about how the NGTL system could serve LNG export demand.

Request: Provide responses to the following:

a) Does NGTL expect gas produced in Alberta to supply some of the forecasted LNG export demand?

b) If the answer to a) is yes:

b.1) Is the NGTL system currently configured so that gas from Alberta can be exported to BC to supply a west coast LNG project?;

21 b.2) If the answer to b.1) is no, will the 2021 NGTL System Expansion enable NGTL to export gas from Alberta into BC so that it can supply a west coast LNG project?;

b.3) If the answer to b.2) is no, what changes to the NGTL system will be required so that gas from Alberta can be exported into BC to supply a west coast LNG project? How will the 2021 NGTL System Expansion fit into that?

c) If the answer to a) is no, then discuss why NGTL would not use its system beyond British Columbia to help supply LNG export demand.

Socio-economic Matters

1.27 Erratum Reference: i) NGTL, Supplemental Report and Errata, Section 4.0 Errata, Table 4-1, page 4-2 (PDF page 97 of 111), A94156-1 ii) NGTL, Supplemental Report and Errata, Appendix 4-1 Errata (PDF pages 98 to 111 of 111), A94156-1

Preamble: In reference i), NGTL provides a summary of the Application and Environmental and Socio-Economic Assessment (ESA) errata. Reference ii) contains the replacement pages listed in Reference i). Reference i) identifies replacement page 19-4 for ESA Section 19.0. This replacement page is not included in Reference ii).

Request: Provide replacement page 19-4 for ESA Section 19.0.

1.28 Cabin Location Reference: i) NGTL, Application, ESA, Section 16.1.3.4 Human Habitation, Cabins, page 16-31 (PDF page 309 of 362), A92619-14 ii) NGTL, Application, ESA, Section 19.3.1.5, Habitation, Spiritual or Cultural Sites, Alteration of Habitation, Spiritual or Cultural Sites, page 19-25 (PDF page 80 of 255), A92619-15

Preamble: In reference i), NGTL states that a trapper’s cabin was identified approximately 175 metres outside of the Robb Section of the Local Study Area (LSA). In reference ii), NGTL states that the trapper’s cabin within the Robb Section of the LSA is located 741 metres southwest of the Project

22 footprint.

Request: Confirm whether the two cabins described in references i) and ii) are the same, and if so: a) whether the cabin is located within the Robb Section of the LSA; and b) provide a description of its location in relation to the Project footprint.

1.29 Historical Resources Reference: i) NGTL, ESA Update, Appendix H - Historical Resources (Archaeology) Technical Data Report, Section 1.1 Project Description, page 1-1 (PDF page 7 of 78), A94156-10 ii) NGTL, ESA Update, Appendix H - Historical Resources (Archaeology) Technical Data Report, Table 4.3-1, pages 4-4 and 4-5 (PDF pages 20 and 21 of 78), A94156-10

Preamble: In reference i), NGTL states that historic resource impact assessment (HRIA) field work was completed for all sections of the Project except for the Grande Prairie Mainline Loop No. 3 (Elmworth Section) during spring and summer 2018. NGTL also states that the HRIA for the Elmworth Section will be completed in 2019 prior to construction. Reference ii) identifies 13 historical resources sites where additional mitigation is recommended.

Request: a) Describe NGTL’s plan to involve Indigenous communities in the following: a.1) HRIAs not yet carried out for the Elmworth Section; and a.2) any further work, including additional mitigation, potentially required by Alberta Culture and Tourism for any of the identified sites. b) For both a.1) and a.2): b.1) list the Indigenous communities who have been identified as potentially affected for the relevant section of the Project; b.2) identify the Indigenous communities who have expressed interested / capacity to participate; b.3) describe the scope of anticipated work / involvement of interested Indigenous communities; and b.4) describe how the scope in b.3) was determined.

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