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Spectra Energy Transmission December 21, 2010 Fifth Avenue Place, East Tower Our File: 6053.008 Suite 2600, 425 - 1st Street S.W. Via: email Calgary, T2P 3L8

Attention: William Kerr Construction Environmental Permitting Specialist

Dear Mr. Kerr,

RE: Rare Surveys of the Proposed Fort Nelson North Processing Facility Sales Gas Pipeline

1.0 INTRODUCTION TERA Environmental Consultants (TERA) was commissioned by Westcoast Energy Inc., carrying on business as Spectra Energy Transmission (Westcoast), to conduct a rare plant survey for their proposed Fort Nelson North Processing Facility (FNNPF) in 2009. The rare plant survey of the FNNPF was conducted on July 12 and 13, 2009 (TERA 2009). Westcoast is proposing to construct a pipeline at b-47-I/ 94-P4 northeast of Fort Nelson, (BC). The proposed pipeline will transport processed sweet natural gas from the FNNPF, which is currently under construction, to the proposed NOVA Gas Transmission Limited (NGTL) Horn River Pipeline for distribution. The pipeline will be constructed within an 18 m wide right-of-way and will include a temporary workspace to the north of the proposed pipeline and to the west of the existing Westcoast Louise pipeline.

This report describes the methods and results of the rare plant survey conducted by TERA on July 7, 2010.

1.1 Objectives The main objectives of the survey were to:

• identify any rare plant species and rare ecological communities along the proposed route as defined by the federal Species at Risk Act (SARA), the Committee on the Status of Endangered Wildlife in (COSEWIC) and the BC Conservation Data Centre (CDC);

• identify any unique sites or habitat features along the proposed route with high potential to support rare plant species;

• record the abundance and distribution of non-native, invasive species; and

• provide mitigation recommendations in the event that rare , rare ecological communities or invasive species infestations are observed. Spectra Energy Transmission William Kerr Page 2

2.0 METHODS The rare plant survey methods were based on survey guidelines developed by the Alberta Native Plant Council (ANPC) (2000) and Penny and Klinkenberg (2007). Rare plant specialists traversed the proposed route, noted the dominant plant communities, recorded all identifiable species and searched for rare plants and unique habitat. A purposeful meander technique was used to survey the proposed right-of-way. At locations where potentially important microsites were observed, more detailed searches were performed.

Where rare plant species were observed, thorough searches were conducted to determine the extent of the populations. The populations were mapped and photographed, UTM co-ordinates were recorded and detailed reporting forms were completed for future submission to the BC CDC.

Tables of rare plant species and rare ecological communities with potential to occur in the project area were provided as appendices to the 2009 rare plant survey report (TERA 2009).

Weed control is of concern to stakeholders and local government agencies. In BC, provincial Noxious weeds are those that must be controlled in all regions, and regional Noxious weeds are those that must be controlled in the region(s) for which they are listed. Nuisance weeds in BC are identified (Cranston et al. 2002) but are not regulated by the BC Weed Control Act. There are many additional, non-listed species that are introduced to BC (i.e., non-native), including seeded agronomic species and horticulturally-used species, that can be invasive in certain land uses. The status of species as native or non-native is according to the BC Species and Ecosystem Explorer (BC Ministry of Environment [MOE] 2010). All listed weeds and non-listed, introduced species were recorded in all locations where they were observed during the survey. Spectra Energy Transmission William Kerr Page 3

3.0 RESULTS A rare plant survey was conducted for the proposed pipeline and associated workspace. The vegetation communities in the areas surveyed were mostly black spruce / Labrador tea - lingonberry / cloudberry - peat , communities (Plate 1). There was also a small island of trembling aspen / green alder - prickly rose / bunchberry community, at the far north-western corner of the Westcoast property (Plate 2).

A list of all species observed at the time of survey is provided in Appendix A. Species nomenclature is according to the BC Species and Ecosystems Explorer (BC MOE 2010) with more current taxonomic information drawn from NatureServe (2010), when necessary.

3.1 Rare Plants and Rare Ecological Communities No COSEWIC or SARA-listed species were found during the survey. No species designated under the BC Identified Wildlife Program were found during the survey. One BC CDC-listed rare plant species, western Jacob's-ladder, was observed during the rare plant survey. No rare ecological communities were observed along the proposed route.

3.1.1 Western Jacob's-ladder (S2S3) Western Jacob's-ladder (Polemonium occidentale ssp. occidentale Greene) is a leafy-stemmed, erect perennial (30-80 cm tall) that has clusters of blue bell-shaped flowers. The are compound with 11 to 27 opposite leaflets (Plate 3) (Douglas et al. 1998-2002). Western Jacob's-ladder is ranked S2S3 and is on the Blue list in BC, and is ranked G5?T5? globally (NatureServe 2010).

Western Jacob’s-ladder was observed at three locations during the rare plant survey (Figure 1). One cluster of plants was observed on the existing pipeline rights-of-way to the northeast of the proposed NGTL meter station (Plate 4). The other two occurrences were observed to the north of the area which has been cleared for construction of the FNNPF.

None of the populations observed during the survey are expected to be disturbed during the construction of the proposed pipeline. However, if additional workspace is required in these areas then grubbing and grading in the vicinity of the rare plant populations should be minimized.

3.2 Non-Native and Invasive Species No provincial or regional Noxious weeds were observed during the survey. The following non-native species were observed along the proposed route: red clover, white sweet-clover and yellow sweet-clover. The non-native species were observed primarily on the existing rights-of-way traversed by the proposed route. The abundance of the non-native species observed along the proposed pipeline route is currently low and consisted of only a few plants growing sporadically along the existing rights-of-way. D-057-I/094-P-04 C-056-I/094-P-04 D-059-I/094-P-04 C-058-I/094-P-04 D-058-I/094-P-04 C-057-I/094-P-04

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A-057-I/094-P-04 B-056-I/094-P-04 A-058-I/094-P-04 B-057-I/094-P-04 A-059-I/094-P-04 B-058-I/094-P-04

D-047-I/094-P-04 C-046-I/094-P-04 D-048-I/094-P-04 C-047-I/094-P-04 D-049-I/094-P-04 C-048-I/094-P-04 GF GF GF

47 48

A-047-I/094-P-04 B-046-I/094-P-04 A-048-I/094-P-04 B-047-I/094-P-04 A-049-I/094-P-04 B-048-I/094-P-04

D-037-I/094-P-04 D-038-I/094-P-04 C-037-I/094-P-04 D-039-I/094-P-04 C-038-I/094-P-04

37 38 A-038-I/094-P-04 B-037-I/094-P-04 A-037-I/094-P-04

Proposed Pipeline FIGURE 1 GF western Jacob's-ladder Proposed Right-of-Way RARE PLANT OBSERVATIONS Access Road Proposed NGTL Meter Station PROPOSED FORT NELSON Existing Pipeline NORTH PROCESSING FACILITY Westcoast Fort Nelson SALES GAS PIPELINE North Processing Facility

Date of Imagery: October, 2008 SCALE: 1: 8,250 December 2010 SPOT© 2009 CNES, Licensed by Iunctus Geomatics Corp, Lethbridge, Alberta, Canada; Proposed Facility & Access Road: TERA Environmental Consultants, 2009 (from T.J. Tryon Land Surveying Limited); m Existing Pipeline: IHS Inc. 2009; Road: GeoBase® 2008. 0 100 200 Although there is no reason to believe that there are any errors associated with the data used to generate this product or in the product itself, 6053 users of these data are advised that errors in the data may be present. (All Locations Approximate) 6053_Figure_01_Rare_Plant_Observations_REV _00.mxd Spectra Energy Transmission William Kerr Page 5

4.0 SUMMARY A rare plant survey of the proposed FNNPF sales gas pipeline was conducted on July 7, 2010. No COSEWIC or SARA-listed species, or species designated under the BC Identified Wildlife Program were found during the survey. No rare ecological communities were observed.

One BC CDC-listed rare plant species, western Jacob's-ladder, was observed during the rare plant survey. None of the populations of western Jacob's-ladder observed are within the areas expected to be disturbed by the proposed pipeline. Therefore, mitigation to address this species is not warranted unless additional workspaces (in the vicinity of the observed populations) are required.

No provincial or regional Noxious weeds were observed during the survey. A number of non-native species were observed primarily along the existing rights-of-way. Due to the low density and less invasive nature of the non-native species observed, no site-specific weed mitigation is warranted.

I hope this summary letter meets your needs at this time. Should you require any additional information, please do not hesitate to contact me at (403) 538-5653 or [email protected].

Sincerely,

TERA ENVIRONMENTAL CONSULTANTS

Amy Griffiths Vegetation Specialist / Environmental Planner

cc: Andrew Povey, TERA Environmental Consultants

Spectra Energy Transmission William Kerr Page 6

5.0 REFERENCES Alberta Native Plant Council. 2000. ANPC Guidelines for Rare Plant Surveys in Alberta. Website: http://www.anpc.ab.ca/assets/rareplant.pdf.

British Columbia Ministry of Environment. 2010. BC Species and Ecosystems Explorer. Website: http://www.env.gov.bc.ca/atrisk/toolintro.html.

Cranston, R., D. Ralph and B. Wikeem. 2002. Field Guide to Noxious and Other Selected Weeds of British Columbia. Fourth Edition. British Columbia Ministry of Agriculture and Lands.

Douglas, G., (G.B. Straley), D. Meidinger and J. Pojar. 1998-2002. Illustrated Flora of British Columbia. Volumes 1-8. Ministry of Sustainable Resource Management and Ministry of Forests. Province of British Columbia.

NatureServe. 2010. NatureServe Explorer - An Online Encyclopedia of Life. Website: http://www.natureserve.org/explorer/index.htm.

Penny, J. and R. Klinkenberg. 2007. Protocols for Rare Surveys. In: Klinkenberg, Brian. (Editor) 2009. E-Flora BC: Electronic Atlas of the Plants of British Columbia. Lab for Advanced Spatial Analysis, Department of Geography, University of British Columbia, Vancouver. Website: http://www.eflora.bc.ca/.

TERA Environmental Consultants. 2009. 2009 Rare Plant Survey for the Proposed Westcoast Energy Inc. Fort Nelson North Processing Facility. Calgary, Alberta. Spectra Energy Transmission William Kerr Page 7

APPENDIX A

OBSERVED PLANT SPECIES – BY TYPE AND COMMON NAME

Common Name Scientific Name TREES Alaska paper Betula neoalaskana balsam poplar Populus balsamifera ssp. balsamifera black spruce Picea mariana lodgepole pine Pinus contorta var. latifolia shore pine Pinus contorta var. contorta trembling aspen Populus tremuloides SHRUBS balsam willow Salix pyrifolia Bebb's willow Salix bebbiana green alder Alnus viridis ssp. crispa low birch Betula pumila var. glandulifera mountain alder Alnus incana ssp. tenuifolia prickly rose Rosa acicularis ssp. sayi sage willow Salix candida Scouler's willow Salix scouleriana FORBS, DWARF SHRUBS American vetch Vicia americana bog Vaccinium uliginosum bog cranberry Oxycoccus oxycoccos bog-rosemary Andromeda polifolia bunchberry cloudberry chamaemorus common horsetail Equisetum arvense crowberry Empetrum nigrum dwarf red raspberry Rubus pubescens var. pubescens dwarf scouring-rush Equisetum scirpoides false toad-flax Geocaulon lividum fireweed Epilobium angustifolium hooded ladies' tresses Spiranthes romanzoffiana Labrador tea Rhododendron groenlandicum leatherleaf Chamaedaphne calyculata Lindley's aster Symphyotrichum ciliolatum lingonberry Vaccinium vitis-idaea ssp. minus long-leaved starwort Stellaria longifolia meadow horsetail Equisetum pratense northern blackcurrant Ribes hudsonianum northern grass-of-Parnassus Parnassia palustris northern Labrador tea Rhododendron tomentosum ssp. subarcticum one-sided wintergreen Orthilia secunda round-leaved sundew Drosera rotundifolia var. rotundifolia swamp horsetail Equisetum fluviatile swamp willowherb Epilobium palustre twinflower Linnaea borealis Spectra Energy Transmission William Kerr Page 8

Common Name Scientific Name western Jacob's-ladder Polemonium occidentale ssp. occidentale wild lily-of-the-valley Maianthemum canadense wood horsetail Equisetum sylvaticum yarrow Achillea millefolium GRASSES, SEDGES, RUSHES bluejoint reedgrass Calamagrostis canadensis Chamisso's cotton-grass Eriophorum chamissonis few-flowered sedge Carex pauciflora Kentucky bluegrass Poa pratensis ryegrass sedge Carex loliacea short-anthered cotton-grass Eriophorum brachyantherum small-flowered wood-rush Luzula parviflora sparse-flowered sedge Carex tenuiflora tufted clubrush Trichophorum cespitosum water sedge Carex aquatilis WEEDS, AGRONOMICS red clover Trifolium pratense white sweet-clover Melilotus alba yellow sweet-clover Melilotus officinalis , LICHENS, LIVERWORTS aulacomnium Moss Aulacomnium palustre bog haircap moss strictum campylopus moss Campylopus sp. candy lichen Icmadophila ericetorum cetraria lichen Cetraria sp. ectomorphic reindeer Cladina mitis gray reindeer Cladina rangiferina liverwort Mylia anomala peat moss species angustifolium peat moss species Sphagnum capillifolium peat moss species Sphagnum fuscum peat moss species Sphagnum lindbergii peat moss species Sphagnum riparium peat moss species Sphagnum spp. pelt lichen species Peltigera sp. pohlia moss Pohlia sp. red-stemmed feathermoss Pleurozium schreberi reindeer lichen species Cladina sp. star-nosed reindeer Cladina stellaris step moss Hylocomium splendens tomentypnum Moss Tomentypnum nitens

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APPENDIX B

PHOTOPLATES Spectra Energy Transmission William Kerr Page 10

Plate 1 View of black spruce bog community looking north-northeast from the southwest corner of the proposed route (July 7, 2010).

Plate 2 View of the isolated pocket of trembling aspen-dominated forest (July 7, 2010).

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Plate 3 Close up of western Jacob's-ladder (July 7, 2010).

Plate 4 Habitat of western Jacob's-ladder observed northeast of the NGTL meter station (July 7, 2010).