Coastal GasLink Pipeline Ltd. NEB 1.1 Jurisdiction over the Coastal GasLink Pipeline Response to Information Request Project MH-053-2018
IR Number: NEB 1.1
Category: Economic Matters
Topic: Corporate Structure
Reference: i) A97628-1, Coastal GasLink Pipeline Ltd., Additional Written Evidence, PDF Page 8 of 18 ii) A97628-1, Coastal GasLink Pipeline Ltd., Additional Written Evidence, PDF Page 11 of 18 iii) A93296-1, Sawyer Application, PDF Pages 16-17 of 19 iv) A97628-1, Coastal GasLink Pipeline Ltd., Additional Written Evidence, PDF Page 5 of 18
Preamble: In reference i), Coastal GasLink Pipeline Ltd. (CGL) states that it is directed separately from other TransCanada Corporation (TCC) subsidiaries.
Reference ii) states that CGL is a wholly-owned subsidiary of TCC. CGL is the general partner of the Coastal GasLink Pipeline Limited Partnership (CGL LP). CGL LP is the partnership through which the Coastal GasLink Pipeline (CGL Pipeline) is being constructed.
Reference iii) is a table filed by Mr. Sawyer entitled "Directors and Officers of Coastal GasLink Ltd. and Positions with TransCanada.” Reference iii) also includes a table entitled “Coastal GasLink Ltd. Senior Staff and TCPL Positions.”
Reference iv) states that CGL is a wholly-owned subsidiary of TransCanada PipeLines Limited (TCPL), which in turn is a wholly- owned subsidiary of TCC.
Request: a) Provide a chart reflecting the corporate structure of each of TCC, TCPL, NOVA Gas Transmission Ltd. (NGTL), as well as CGL, CGL LP and all other corporate entities that own or may operate CGL Pipeline. Include a description summarizing the ownership of each entity and the operating relationships with each other. This description and the chart must show, but not be restricted to: a.1) the ownership of each entity and the jurisdiction(s) in which each entity is registered; and a.2) the respective roles and responsibilities of each entity. b) Based on the information in a), describe what entity owns the physical assets of the Coastal GasLink Pipeline Project.
March 12, 2019 Page 1 of 4
Coastal GasLink Pipeline Ltd. NEB 1.1 Jurisdiction over the Coastal GasLink Pipeline Response to Information Request Project MH-053-2018
c) Provide a list of the Board of Directors and officers (or equivalents) for TCC, TCPL, NGTL, CGL LP and CGL, including all titles. Identify any overlapping individuals and their roles in each corporate entity.
c.1) Are there any individuals who overlap, and hold a role in the management teams of TCC, TCPL, NGTL, CGL LP and CGL? If yes, list the overlapping individuals and their roles in each corporate entity.
Response: a) The requested chart is provided as Figure NEB 1.1-1.
TCC
TCPL
CGL NGTL
0.02 99.98
C GL LP
Note: 1. TCC is a Canada corporation and is extra-provincially registered in BC, AB, SK, MB, ON, QC, NB, NS, NL, PEI, NT, NU and YT. It is the parent corporation. 2. TCPL is a Canada corporation and is extra-provincially registered in BC, AB, SK, MB, ON, QC, NB, NS and YT. It holds Canadian assets, both provincial and federal, including NGTL, Foothills, the Mainline, PRGT, Ventures, Keystone, Grand Rapids, Northern Courier, Heartland, TransCanada Energy, midstream and marketing assets, and CGL (as shown). It is the sole limited partner of CGL LP. 3. CGL is a BC corporation and the sole general partner of CGL LP. 4. CGL LP is a limited partnership formed in Alberta and is extra-provincially registered in BC. 5. NGTL is an Alberta corporation, extra-provincially registered in BC, and owns the NGTL System. 6. Ownership in the chart is 100 percent unless otherwise indicated.
Figure NEB 1.1-1: Corporate Structure
March 12, 2019 Page 2 of 4
Coastal GasLink Pipeline Ltd. NEB 1.1 Jurisdiction over the Coastal GasLink Pipeline Response to Information Request Project MH-053-2018
b) Coastal GasLink Pipeline Ltd. (which is CGL in the chart above), on behalf of CGL LP, is the owner of the physical project assets. c) TCC is a publicly traded company. See Attachment NEB 1.1-1 for a report listing TCC directors and officers as of March 8, 2019.
TCPL is a reporting issuer in the jurisdictions of Canada. TCPL’s shares are 100% held by TCC. Its directors and officers are identical in identity and number, and substantively the same in title, as the directors and officers of TCC. A report listing its directors and officers as of March 8, 2019 is attached as Attachment NEB 1.1-2.
CGL LP is a limited partnership and does not have directors or officers, or equivalents. CGL is the general partner of CGL LP. A report listing CGL’s directors and officers as of March 8, 2019 is attached as Attachment NEB 1.1-3.
A report listing NGTL’s directors and officers as of March 8, 2019 is attached as Attachment NEB 1.1-4.
A table listing the directors and officers of CGL, NGTL, TCC and TCPL and illustrating the overlapping individuals between the corporations is attached as Attachment NEB 1.1-5. The positions have been further categorized into: (1) Executive Vice-President (2) Business Unit Vice-President (3) Shared/Corporate Vice-President and Secretary (4) External Directors
(1) The Executive Vice-President category lists TCC’s leadership team and shows the overlap of the Executive Vice-President and President, Canadian Natural Gas Pipelines who has overall accountability for the growth, operation and profitability of TCC’s federally and provincially regulated natural gas pipeline assets in Canada. She currently holds a director or officer position on each of TCC, TCPL, NGTL, and CGL.
(2) The Business Unit Vice-President category lists the persons within the Canadian Natural Gas Pipelines organization who have specific roles on TCC’s subsidiaries. There is one overlapping individual between CGL and NGTL.
The president of CGL is not a director or corporate officer of NGTL, TCPL or TCC. He is primarily responsible for management of CGL, together with the internal reporting structure below him, which does not include any officer or director of NGTL, TCPL, or TCC.
March 12, 2019 Page 3 of 4
Coastal GasLink Pipeline Ltd. NEB 1.1 Jurisdiction over the Coastal GasLink Pipeline Response to Information Request Project MH-053-2018
(3) The Shared/Corporate Vice-President and Secretary category lists the persons who hold special expertise but do not necessarily take part in the management of the business units owned by TCC (risk, treasurer, tax, secretary, finance, controller, law and corporate secretary, etc.). Their function is shared across all of TCC’s organization and the majority of them hold analogous officer positions on most of TCC’s subsidiaries.
(4) The External Director category lists the independent directors elected to TCC and TCPL. There are no overlapping individuals.
March 12, 2019 Page 4 of 4
Coastal GasLink Pipeline Ltd. Jurisdiction over the Coastal GasLink Pipeline Project Attachment NEB 1.1 TCC Officers Directors/Officers Report As of March 08, 2019
TransCanada Corporation Directors
Kevin E. Benson Director
Stephan Cretier Director
Russell K. Girling Director
S. Barry Jackson Director
Randy Limbacher Director
John E. Lowe Director
Paula Rosput Reynolds Director
Mary Pat Salomone Director
Indira V. Samarasekera Director
D. Michael G. Stewart Director
Siim A. Vanaselja Director
Thierry Vandal Director
Officers Russell K. Girling President
Chief Executive Officer
Siim A. Vanaselja Chair of the Board
Stanley G. Chapman III Executive Vice-President and President, U.S. Natural Gas Pipelines
Kristine L. Delkus Executive Vice-President, Stakeholder Relations and General Counsel
Wendy L. Hanrahan Executive Vice-President, Corporate Services
Donald R. Marchand Executive Vice-President and Chief Financial Officer
Paul E. Miller Executive Vice-President, Technical Centre and President, Liquids Pipelines
Francois L. Poirier Executive Vice-President, Corporate Development and Strategy and President, Mexico Natural Gas Pipelines and Energy
Tracy A. Robinson Executive Vice-President and President, Canadian Natural Gas Pipelines
Gloria L. Hartl Vice-President, Risk Management
Dennis P. Hebert Vice-President, Taxation
Directors/Officers Report - v.3 Generated 03/08/2019 8:39:26 AM Page1of2
March 2019 Coastal GasLink Pipeline Ltd. Jurisdiction over the Coastal GasLink Pipeline Project Attachment NEB 1.1 TCC Officers Directors/Officers Report As of March 08, 2019
TransCanada Corporation
R. Ian Hendy Vice-President and Treasurer
Joel E. Hunter Senior Vice-President, Capital Markets
Christine R. Johnston Vice-President, Law and Corporate Secretary
G. Glenn Menuz Vice-President
Controller
Directors/Officers Report - v.3 Generated 03/08/2019 8:39:26 AM Page2of2
March 2019 Coastal GasLink Pipeline Ltd. Attachment NEB 1.1-2 Jurisdiction over the Coastal GasLink Pipeline Project TCPL Officers Directors/Officers Report As of March 08, 2019
TransCanada PipeLines Limited Directors
Kevin E. Benson Director
Stephan Cretier Director
Russell K. Girling Director
S. Barry Jackson Director
Randy Limbacher Director
John E. Lowe Director
Paula Rosput Reynolds Director
Mary Pat Salomone Director
Indira V. Samarasekera Director
D. Michael G. Stewart Director
Siim A. Vanaselja Director
Thierry Vandal Director
Officers Russell K. Girling Chief Executive Officer
President
Siim A. Vanaselja Chair of the Board
Stanley G. Chapman III Executive Vice-President and President, U.S. Natural Gas Pipelines
Kristine L. Delkus Executive Vice-President, Stakeholder Relations and General Counsel
Wendy L. Hanrahan Executive Vice-President, Corporate Services
Donald R. Marchand Executive Vice-President and Chief Financial Officer
Paul E. Miller Executive Vice-President, Technical Centre and President, Liquids Pipelines
Francois L. Poirier Executive Vice-President, Corporate Development and Strategy and President, Mexico Natural Gas Pipelines and Energy
Tracy A. Robinson Executive Vice-President and President, Canadian Natural Gas Pipelines
Gloria L. Hartl Vice-President, Risk Management
Dennis P. Hebert Vice-President, Taxation
Directors/Officers Report - v.3 Generated 03/08/2019 8:42:12 AM Page1of2 March 2019 Coastal GasLink Pipeline Ltd. Attachment NEB 1.1-2 Jurisdiction over the Coastal GasLink Pipeline Project TCPL Officers Directors/Officers Report As of March 08, 2019
TransCanada PipeLines Limited
R. Ian Hendy Vice-President and Treasurer
Joel E. Hunter Senior Vice-President, Capital Markets
Christine R. Johnston Vice-President, Law and Corporate Secretary
G. Glenn Menuz Controller
Vice-President
Directors/Officers Report - v.3 Generated 03/08/2019 8:42:12 AM Page2of2 March 2019 Coastal GasLink Pipeline Ltd. Attachment NEB 1.1-3 Jurisdiction over the Coastal GasLink Pipeline Project CGL Officers
Directors/Officers Report As of March 08, 2019
Coastal GasLink Pipeline Ltd. Directors
David Joel Pfeiffer Director
Tracy A. Robinson Director
Terri L. Steeves Director
Officers David Joel Pfeiffer President
Penny E. Favel Vice-President
Gloria L. Hartl Vice-President, Risk Management
Dennis P. Hebert Vice-President, Taxation
R. Ian Hendy Vice-President and Treasurer
Joel E. Hunter Vice-President, Finance
Andrea E. Jalbert Vice-President
Nancy A. Johnson Vice-President
G. Glenn Menuz Vice-President and Controller
Tracy A. Robinson Vice-President
Terri L. Steeves Vice-President
Christine R. Johnston Vice-President, Law and Corporate Secretary
Norrie C. Ramsay Vice President
Jane M. Brindle Assistant Secretary
Directors/Officers Report - v.3 Generated 03/08/2019 8:44:30 AM Page1of1
March 2019 Coastal GasLink Pipeline Ltd. Jurisdiction over the Coastal GasLink Pipeline Project Attachment NEB 1.1-4
Directors/Officers Report As of March 08, 2019
NOVA Gas Transmission Ltd. Directors
Kristine L. Delkus Director
Tracy A. Robinson Director
Officers Tracy A. Robinson President
Kristine L. Delkus Executive Vice-President
General Counsel
Donald R. Marchand Executive Vice President
Chief Financial Officer
M. Catharine Davis Chief Compliance Officer
Penny E. Favel Vice-President
Gloria L. Hartl Vice-President, Risk Management
Dennis P. Hebert Vice-President, Taxation
R. Ian Hendy Vice-President and Treasurer
Joel E. Hunter Vice-President, Finance
Andrea E. Jalbert Vice-President, Supply Chain
Christine R. Johnston Vice-President, Law and Corporate Secretary
Jawad A. Masud Vice-President
G. Glenn Menuz Vice President
Controller
Norrie C. Ramsay Vice-President
John F. Soini Vice-President
Terri L. Steeves Vice-President
Jimmie J. White Vice-President
Jane M. Brindle Assistant Secretary
Directors/Officers Report - v.3 Generated 03/08/2019 8:53:26 AM Page1of1
March 2019 Coastal GasLink Pipeline Ltd. Jurisdiction over the Coastal GasLink Pipeline Project Attachment NEB 1.1-5 REQUEST NEB 1.1 c.1): OVERLAPPING INDIVIDUALS DIRECTORS AND CORPORATE OFFICERS OF TCC, TCPL, CGL AND NGTL CATEGORY/FUNCTION CGL NGTL TCC TCPL
Executive Vice-President Russell K. Girling, Russell K. Girling, Director and Director and President and Chief Executive Officer President and Chief Executive Officer Stanley G. Chapman III Stanley G. Chapman III Executive Vice-President and Executive Vice-President and President, US Natural Gas Pipelines President, US Natural Gas Pipelines Kristine L. Delkus, Kristine L. Delkus, Kristine L. Delkus, Director and Executive Vice-President and Executive Vice-President and Executive Vice-President and General Counsel General Counsel General Counsel Wendy Hanrahan, Wendy Hanrahan, Executive Vice-President, Executive Vice-President, Corporate Services Corporate Services Donald R. Marchand, Donald R. Marchand, Donald R. Marchand, Executive Vice-President and Executive Vice-President and Executive Vice-President and Chief Financial Officer Chief Financial Officer Chief Financial Officer Paul E. Miller, Paul E. Miller, Executive Vice-President, Executive Vice-President, Technical Centre and President, Technical Centre and President, Liquids Pipelines Liquids Pipelines Francois L. Poirier, Francois L. Poirier, Executive Vice-President, Executive Vice-President, Corporate Development and Strategy and Corporate Development and Strategy and President, Mexico Natural Gas Pipelines President, Mexico Natural Gas Pipelines and Energy and Energy Tracy A. Robinson, Tracy A. Robinson, Tracy A. Robinson, Tracy A. Robinson, Director and Vice-President Director and President Executive Vice-President and Executive Vice-President and President, Canadian Natural Gas Pipelines President, Canadian Natural Gas Pipelines
Business Unit David Pfeiffer, Vice-President Director and President M. Catharine Davis, Chief Compliance Officer Nancy A. Johnson, Vice-President Jawad A. Masud, Vice-President John F. Soini, Vice-President Terri L. Steeves, Terri L. Steeves, Director and Vice-President Vice-President Jimmie J. White, Vice-President
March 2019 Page 1 of 2 Coastal GasLink Pipeline Ltd. Jurisdiction over the Coastal GasLink Pipeline Project Attachment NEB 1.1-5
CATEGORY/FUNCTION CGL NGTL TCC TCPL
Shared/Corporate Penny E. Favel, Penny E. Favel, Vice-President Vice-President Vice-President and Secretary Gloria L. Hartl, Gloria L. Hartl, Gloria L. Hartl, Gloria L. Hartl, Vice-President, Risk Management Vice-President, Risk Management Vice-President, Risk Management Vice-President, Risk Management Dennis P. Hebert, Dennis P. Hebert, Dennis P. Hebert, Dennis P. Hebert, Vice-President, Taxation Vice-President, Taxation Vice-President, Taxation Vice-President, Taxation R. Ian Hendy, R. Ian Hendy, R. Ian Hendy, R. Ian Hendy, Vice-President and Treasurer Vice-President and Treasurer Vice-President and Treasurer Vice-President and Treasurer Joel E. Hunter Joel E. Hunter Joel E. Hunter Joel E. Hunter Vice-President, Finance Vice-President, Finance Senior Vice-President, Capital Markets Senior Vice-President, Capital Markets Andrea E. Jalbert, Andrea E. Jalbert, Vice-President Vice-President, Supply Chain Christine R. Johnston, Christine R. Johnston, Christine R. Johnston, Christine R. Johnston, Vice-President, Law and Vice-President, Law and Vice-President, Law and Vice-President, Law and Corporate Secretary Corporate Secretary Corporate Secretary Corporate Secretary G. Glenn Menuz, G. Glenn Menuz, G. Glenn Menuz, G. Glenn Menuz, Vice-President and Controller Vice-President and Controller Vice-President and Controller Vice-President and Controller Norrie C. Ramsay, Norrie C. Ramsay, Vice-President Vice-President Jane M. Brindle, Jane M. Brindle, Assistant Secretary Assistant Secretary External Directors Siim A. Vanaselja, Siim A. Vanaselja, Director and Chair of the Board Director and Chair of the Board Kevin E. Benson, Kevin E. Benson, Director Director Stephan Cretier, Stephan Cretier, Director Director S. Barry Jackson, S. Barry Jackson, Director Director Randy Limbacher, Randy Limbacher, Director Director John E. Lowe, John E. Lowe, Director Director Paula Rosput Reynolds, Paula Rosput Reynolds, Director Director Mary Pat Salomone, Mary Pat Salomone, Director Director Indira V. Samarasekera, Indira V. Samarasekera, Director Director D. Michael G. Stewart, D. Michael G. Stewart, Director Director Thierry Vandal, Thierry Vandal, Director Director
March 2019 Page 2 of 2 Coastal GasLink Pipeline Ltd. NEB 1.2 Jurisdiction over the Coastal GasLink Pipeline Response to Information Request Project MH-053-2018
|IR Number: NEB 1.2
Category: Economic Matters
Topic: NOVA Inventory Transfer
Reference: i) A97628-1, CGL, Additional Written Evidence, PDF Page 13 of 18 ii) A97947-1, NGTL Written Evidence in CGL Jurisdiction, PDF Page 4 of 11 iii) A97948-2, Sawyer Additional Written Evidence, PDF Page 14 of 26 iv) A97628-1, CGL, Additional Written Evidence - A6R5I9, PDF Page 16 of 18
Preamble: In reference i), CGL states that during operations, Shell Canada Energy, North Montney LNG Limited Partnership, PetroChina Kitmat LNG Partnership, Diamond LNG Canada Partnership and Kogas Canada LNG Ltd. (the Participants) will contact CGL gas scheduling (Gas Control) daily to advise CGL of the volume of gas each Participant intends to deliver to the Coastal GasLink inlet meter dedicated to that Participant (Daily Nomination). Gas Control is in effect a staffed computer terminal dedicated to the CGL Pipeline. It will be connected to CGL Pipeline and the Participants by telecommunications and a signal sharing agreement. The terminal may be located in Calgary in proximity to gas control for other TCC-owned entities.
In reference ii), NGTL states that the NGTL System provides a unique commercial service for its customers referred to as the NOVA Inventory Transfer (NIT). The NIT construct aggregates all natural gas supplies, storage, intra-basin markets and interconnected pipelines to the NGTL System at a single, integrated transaction hub by contracting receipt and delivery functions separately with a balancing account situated between the functions. The NIT is in effect a pool in which natural gas can be traded.
In reference iii) Mr. Sawyer states that third party purchases are expected to be transacted at market hubs that may include, but are not limited to, the NIT virtual trading point through access to the NGTL System. This system provides the Participants with integrated access to gas production throughout the Western Canadian Sedimentary Basin (WCSB).
In reference iv), CGL states that it will construct five separate receipt meter facilities at the Coastal GasLink inlet, with each meter facility dedicated to a single Participant.
Request: a) Will Gas Control staff for CGL and any other TCC affiliated entities overlap (e.g. NGTL)?
March 12, 2019 Page 1 of 3
Coastal GasLink Pipeline Ltd. NEB 1.2 Jurisdiction over the Coastal GasLink Pipeline Response to Information Request Project MH-053-2018
b) Can shippers on the NGTL System who are not Participants nominate to:
b.1) the LNG Canada export facility; b.2) any other point along the CGL Pipeline?
c) If there is capacity available on the CGL Pipeline after each Participant submits their Daily Nomination, how will the available capacity be allocated?
c.1) Will other Participants have the opportunity to nominate additional capacity? c.2) Will other shippers who are not Participants be able to nominate volumes?
d) How will gas nominated for NIT then be nominated to CGL Gas Control?
Response:
a) See the response to NEB-CGL 1.10.
b) No. c) Under the governing transportation service agreements (TSAs) and the Pipeline Rules which form a part of those agreements, excess capacity is allocated pro-rata among the Participants and is not assignable. If not all of the excess capacity is taken up in this first round, excess capacity is again offered to the Participants pro-rata.
The answer to (c.1) is: yes, in accordance with the excess capacity rules under the TSA as summarized here.
The answer to (c.2) is no; only the current Participants may nominate for excess capacity. d) Gas cannot be nominated for NIT on or through the CGL Pipeline.
As noted in Reference ii), NIT is exclusive to the NGTL System and can only be accessed through a nomination by an NGTL customer using NGTL service.
A nomination on the CGL Pipeline is separate from any nomination on NGTL. Only a person who has contracted with Coastal GasLink can nominate on the CGL Pipeline. Currently, the only parties with transportation contracts with Coastal GasLink are the Participants.
A contract with NGTL, for any of its services, in no event provides any right to use the single service that Coastal GasLink provides.
March 12, 2019 Page 2 of 3
Coastal GasLink Pipeline Ltd. NEB 1.2 Jurisdiction over the Coastal GasLink Pipeline Response to Information Request Project MH-053-2018
In the event there is a connection established between the CGL Pipeline and NGTL, that connection point would be a delivery point for NGTL, with delivery from NGTL for a Participant to supply its gas to the in-let of the CGL Pipeline. The nomination process for transportation on the CGL pipeline would remain separate and governed by the TSAs.
March 12, 2019 Page 3 of 3
Coastal GasLink Pipeline Ltd. NEB 1.3 Jurisdiction over the Coastal GasLink Pipeline Response to Information Request Project MH-053-2018
IR Number: NEB 1.3
Category: Economic Matters
Topic: Allocation of additional capacity
Reference: i) A97628-1, CGL, Additional Written Evidence, PDF Page 9 of 18 ii) A97628-1, CGL, Additional Written Evidence, PDF Page 14 of 18
Preamble: Reference i) states that CGL has received approval to add compressors along its single line, which would enable CGL to expand pipeline capacity from 2.1 billion cubic feet per day (Bcf/d) to approximately 5 Bcf/d.
Reference ii) states that any significant capital addition (e.g. the addition of compression) in the future is under the control of the Participants.
Request: a) If the Participants elected to add compression to the CGL Pipeline, how would the additional capacity be allocated? To whom could the additional capacity be allocated (e.g. only Participants? Any other parties?)
b) Who would determine which parties would receive capacity and on what basis?
Response: a) and b)
If the Participants elect to add compression to the CGL Pipeline, they are required to advise Coastal GasLink regarding the allocation of the additional capacity among them. This could be the same or different than the allocation of the base capacity.
The allocation of expansion capacity would be reflected in the Participants’ participating interest shares in the expansion. Each Participant’s total share of the CGL Pipeline capacity (by percentage) is required to align with the Participants’ (or their affiliates’) participating interest shares in the LNG Canada Facility, subject to capacity taken up by a new entrant.
Any allocation among the existing Participants is wholly within their discretion. The existing Participants can also elect to add a new “participant”, but such new participant (or that participant’s affiliate) would have to have acquired a participating interest share in the LNG Canada Facility that is equivalent to their percentage allocation of the CGL Pipeline capacity (as expanded).
March 12, 2019 Page 1 of 2
Coastal GasLink Pipeline Ltd. NEB 1.3 Jurisdiction over the Coastal GasLink Pipeline Response to Information Request Project MH-053-2018
As part of an expansion, the addition of a new entrant that does not have a participating interest share in the LNG Canada Facility would require the agreement of LNGC (on behalf of the Participants) and Coastal GasLink, and would require the negotiation of separate transportation terms.
March 12, 2019 Page 2 of 2
Coastal GasLink Pipeline Ltd. NEB 1.4 Jurisdiction over the Coastal GasLink Pipeline Response to Information Request Project MH-053-2018
IR Number: NEB 1.4
Category: Economic Matters
Topic: CGL Pipeline Location
Reference: i) A97628-1, CGL, Additional Written Evidence, PDF Page 6 of 18 ii) A97628-1, CGL, Additional Written Evidence, PDF Page 8 of 18 iii) A97628-1, CGL, Additional Written Evidence, PDF Page 6 of 18
Preamble: Reference i) states that the CGL Pipeline is a single-line natural gas pipeline located entirely within British Columbia. It starts near Groundbirch, British Columbia, approximately 40 km inside the province’s eastern border, and runs west to a point near Kitimat, British Columbia.
Reference ii) lists the five arm’s length counter-parties that collectively underwrite 100 per cent of the CGL Pipeline and own 100 per cent of its capacity (the Participants).
Reference iii) states that the purpose and activity of the CGL Pipeline is to transport natural gas within British Columbia for arm’s length third- parties, who will supply their own gas to the inlet of the CGL Pipeline.
Request: a) Provide a detailed map of the CGL Pipeline. The map must include: all provincially-regulated natural gas gathering and transmission pipelines in northeastern British Columbia and northwestern Alberta; NEB-regulated natural gas gathering and transmission pipelines located in northeastern British Columbia and northwestern Alberta; and any interconnections between provincially and federally- regulated pipelines.
Response: a) A detailed map of the entire pipeline route is given in the Environmental Assessment Office Certified Project Description (CPD) in 135 map sheets (Map Sheets), available at the link in the footnote.1 This map is current.
The only area where Coastal GasLink is planning for connections is at the CGL Pipeline in-let.
The area for Coastal GasLink’s permitted work that it has received direction to proceed with is shown at Map Sheet 1 of the CPD. Coastal GasLink does not have
1 CPD Map Sheets, on-line: < https://projects.eao.gov.bc.ca/p/coastal-gaslink-pipeline/docs?folder=164 >
March 12, 2019 Page 1 of 2
Coastal GasLink Pipeline Ltd. NEB 1.4 Jurisdiction over the Coastal GasLink Pipeline Response to Information Request Project MH-053-2018
mapping information of pipelines that may connect to the CGL Pipeline in-let, but notes that both NGTL and Westcoast (not owned by TCC or TCPL) have facilities in the vicinity, as does Shell. Upstream arrangements are within the discretion of the Participants and Coastal GasLink understands they remain in the process of making those arrangements.
Although Coastal GasLink does not have its own mapping data of the upstream, in an effort to be responsive to the mapping request, Coastal GasLink had the maps at Attachment NEB 1.4-1 and 1.4-2 to this response prepared by a third-party mapping company. Attachment NEB 1.4-2 breaks out federally regulated pipelines. Coastal GasLink understands that the third-party company draws on public information. Coastal GasLink cannot speak to the accuracy of the data from which the attachments were generated, but does consider the attachments to be indicative of the extent of pipelines in the area.
Coastal GasLink’s review of the Attachments indicates they contain gaps in the extent of federally regulated pipelines north and west of the in-let to the CGL Pipeline.
In that area, Westcoast has a continuous part of its federally regulated system. The gaps may be a result of the Attachments being generated from the same data source used by the National Energy Board. An NEB mapping tool shows what appear to be the same gaps.2
However, an NEB profile of Westcoast’s system appears to correctly show the continuous nature of that system.3
In addition, the Attachments appear to show the CGL Pipeline connecting to the NGTL System. This is due to the scale of the maps relative to the width of the lines representing pipelines and to the proximity of various pipelines and pipeline systems. As explained in Coastal GasLink’s additional written evidence, there is currently no such connection.
Coastal GasLink does not have data on connection points among all provincially and federally regulated pipelines and is not aware of a source from which it could acquire that data.
2 National Energy Board, on-line: < http://www.neb-one.gc.ca/sftnvrnmnt/sft/dshbrd/mp/index-eng.html >. 3 National Energy Board, on-line: < http://www.neb- one.gc.ca/nrg/ntgrtd/pplnprtl/pplnprfls/ntrlgs/wstcsttrnsmssn-eng.html >.
March 12, 2019 Page 2 of 2
Coastal GasLink Pipeline Ltd. Jurisdiction over the Coastal GasLink Pipeline Project Attachment NEB 1.4-1
Legend NEB Regulated Pipeline (non-TransCanada) Provincial Pipeline Coastal Gas Link NGTL City/Town ¯
RAINBOW HIGH LAKE LEVEL
MANNING
FORT ST. JOHN HUDSON'S HOPE TAYLOR PEACE RIVER GRIMSHAW FAIRVIEW
CHETWYND DAWSON SPIRIT FALHER CREEK RIVER MCLENNAN
MACKENZIE
SEXSMITH TUMBLER RIDGE
BEAVERLODGE WEMBLEY
GRANDE VALLEYVIEW PRAIRIE
PRINCE GEORGE Coastal GasLink Pipeline
Alberta - British Columbia 0 12.5 25 50 75 100
Kilometres
Date: March 6 2019 Willis TC Mapping T_0190_0000_01 Rev 0 GRANDE CACHE March 2019 Page 1 of 1 Coastal GasLink Pipeline Ltd. Jurisdiction over the Coastal GasLink Pipeline Project Attachment NEB 1.4-2
Legend NEB Regulated Pipeline City/Town ¯
RAINBOW HIGH LAKE LEVEL
MANNING
FORT ST. JOHN HUDSON'S HOPE TAYLOR PEACE RIVER GRIMSHAW
FAIRVIEW
DAWSON CREEK SPIRIT RIVER CHETWYND FALHER MCLENNAN
MACKENZIE
SEXSMITH TUMBLER RIDGE BEAVERLODGE WEMBLEY GRANDE PRAIRIE VALLEYVIEW
PRINCE GEORGE Coastal GasLink Pipeline
Alberta - British Columbia 0 12.5 25 50 75 100
Kilometres GRANDE Date: March 6 2019 Willis TC Mapping T_0190_0000_02 Rev 0 CACHE
March 2019 Page 1 of 1 Coastal GasLink Pipeline Ltd. NEB 1.5 Jurisdiction over the Coastal GasLink Pipeline Response to Information Request Project MH-053-2018
IR Number: NEB 1.5
Category: Economic Matters
Topic: Physical Connection
Reference: i) A97628-1, CGL, Additional Written Evidence, PDF Page 9 of 18 ii) A97948-3, Coastal GasLink Pipeline Project, Project Description, submitted to Canadian Environmental Assessment Agency, 30 October 2012, PDF Page 6 of 14 iii) A97948-2, Sawyer Additional Written Evidence, PDF Page 14 of 26 iv) A93738-1, CGL Comments on Threshold Question, 24 August 2018, PDF Page 10 of 12 v) A97628-1, CGL, Additional Written Evidence, PDF Page 17 of 18 vi) A97628-1, CGL, Additional Written Evidence, PDF Page 16 of 18 vii) A97628-1, CGL, Additional Written Evidence, PDF Page 7 of 18
Preamble: Reference i) states that the CGL Pipeline will receive and aggregate gas owned by the Participants at the Coastal GasLink inlet near Groundbirch, British Columbia.
Reference ii) states that the CGL Pipeline will connect natural gas producing areas in northeast British Columbia with the proposed LNG Canada export facility in Kitimat. In addition, CGL will have an interconnection with the existing NGTL System at Groundbirch, which will provide access to other western Canadian natural gas supply.
Reference iii) states that natural gas supply for the LNG Canada export facility is expected to be sourced primarily in the WCSB, which is composed principally of resources in British Columbia and Alberta.
Natural gas supply for the LNG Canada project may be accessed in a number of ways, including proprietary natural gas holdings of the LNG Canada participants, and third party agreements with gas producers, marketers, and aggregators. Third party purchases are expected to be transacted at market hubs that may include, but are not limited to, the NIT virtual trading point through access to the NGTL System.
Reference iv) states that the CGL Pipeline may connect to upstream provincial sources of supply, including direct connections to provincially- regulated producer facilities.
Reference v) states that none of the Participants has advised CGL that
March 12, 2019 Page 1 of 6
Coastal GasLink Pipeline Ltd. NEB 1.5 Jurisdiction over the Coastal GasLink Pipeline Response to Information Request Project MH-053-2018
they have a contract with NGTL for service on the NGTL System for a connection to the CGL Pipeline and CGL’s understanding is that there is no contract in place. CGL is party to an information sharing agreement with LNG Canada and NGTL, which facilitates the parties sharing information about potential future connection to the CGL Pipeline and related applications, if any. Any commercial arrangements between a Participant and NGTL that may occur in the future would have no bearing on the CGL Pipeline’s separate transportation function, standalone operation, or the application of the NGTL Code of Conduct to CGL. The CGL Pipeline’s function would remain as a merchant pipeline for dedicated use of the Participants, transporting gas within British Columbia.
Reference vi) states that CGL’s information on Participant plans for upstream supply is limited and is informed by Participant requests to CGL for inlet facilities to connect their supply to the CGL Pipeline. CGL has received requests from the Participants to construct five separate receipt meter facilities at the CGL inlet, with each meter facility dedicated to a single Participant.
Reference vii) states that CGL Pipeline does not cross an inter-provincial boundary and cannot be used to transport gas across a border.
Request: a) Is the CGL Pipeline designed to have any receipt meter facilities, other than the CGL Pipeline inlet near Groundbirch, British Columbia, as referenced in i)?
b) Provide a detailed description of all physical connection(s) being considered for the inlet of the CGL Pipeline. In your answer, discuss natural gas design capability of each pipeline connection option, as well as the regulatory authority responsible for each option’s authorization for construction and operation.
c) Describe the criteria for selecting the final design for a physical connection(s) at the inlet of the CGL Pipeline.
d) When does CGL anticipate a decision to be made on the final design for physical connection(s) at the inlet of the Coastal GasLink pipeline?
e) If the CGL Pipeline will connect to upstream provincial sources of supply as referenced in ii), confirm whether the CGL Pipeline will have the ability to deliver gas to NGTL:
e.1) in the event supply is not required at the LNG Canada export
March 12, 2019 Page 2 of 6
Coastal GasLink Pipeline Ltd. NEB 1.5 Jurisdiction over the Coastal GasLink Pipeline Response to Information Request Project MH-053-2018
terminal in Kitimat; e.2) in the event that the economics are more favourable to deliver gas into another market in Canada or the United States rather than to LNG Canada’s export terminal in Kitimat.
f) Confirm whether the NGTL System will have the ability to deliver gas to the CGL Pipeline.
Response: a) No. While the original Certified Project Description (CPD) from the Environmental Assessment Office (EAO) includes approval for metering facilities at both the in-let and at Vanderhoof in BC, Coastal Gaslink is undertaking receipt meter design work only for the in-let, which is near Groundbirch, BC. Coastal GasLink has received no requests for connection at any other point other than an outlet near Kitimat. If Coastal GasLink received direction through its governing committees, it would undertake design work for another connection or different set of connections. b) Potential Upstream Pipelines
Regarding upstream pipelines, upstream arrangements are at the discretion of the Participants and Coastal GasLink understands their work on these arrangements is ongoing. Coastal GasLink is not aware of any upstream pipeline applied for or permitted that could be expected to connect to the CGL Pipeline in-let other than as disclosed in the LNG Canada evidence.
The CGL Pipeline will necessarily connect to at least one upstream pipeline. One or more other companies could construct a pipeline to the CGL Pipeline in-let, or Coastal GasLink could construct a pipeline upstream of its in-let to others’ facilities that are nearby.
The PDA provides: that at the direction of the Executive Committee, Coastal GasLink will acquire land rights in BC upstream of the Coastal GasLink in-let, for construction of a connecting pipeline as directed by LNG Canada.
The Participants, as represented by LNG Canada, have and continue to contemplate a connection to NGTL. As per LNG Canada’s evidence on the Participants’ upstream arrangements, this connection is still being considered. In 2016, the Executive Committee directed Coastal GasLink to acquire approximately three kilometers of right-of-way and land to prepare for a connection with NGTL. Coastal GasLink then acquired land rights (e.g., an easement) as directed.
However, no design work has occurred for a pipeline for these lands, construction is currently not permitted, no application has been made to construct a pipeline within these lands, and LNG Canada has provided no further direction.
March 12, 2019 Page 3 of 6
Coastal GasLink Pipeline Ltd. NEB 1.5 Jurisdiction over the Coastal GasLink Pipeline Response to Information Request Project MH-053-2018
Coastal GasLink expects that if the Participants conclude an agreement with NGTL then Coastal GasLink will apply for a permit from British Columbia for a pipeline for these lands, design it, and, if approved, construct it.
Connection Work Coastal GasLink is Undertaking
Coastal GasLink prepares for connections as through the Engineering Design & Constructability Committee (ED&C). That direction is not final until approved by the Executive Committee (EC). The current request of the Participants through the ED&C is for one meter station at the CGL Pipeline in-let with a dedicated meter for each Participant (i.e. one meter station with multiple meters, plus redundancy to meet contractual requirements).
To meet volume requirements, an individual meter may in turn contain more than one “meter run” to measure volume. Any one of the five meters being designed for could connect to NGTL, or to an alternative source of supply.
The Participants tell Coastal GasLink what volumes the meters need to accommodate. They have not yet communicated final requirements to Coastal GasLink. When they do, the metering design work will be finalized, which Coastal GasLink expects will occur later this year, subject to the schedule of the Participants.
Coastal GasLink’s metering facilities are permitted under the CPD and Oil and Gas Commission permits. c) As with previous requests on engineering and design from LNG Canada, Coastal GasLink expects the Participants will advance their criteria to LNG Canada, LNG Canada will bring it to the ED&C, at which the connection plans may be adopted and then advanced to the EC for final approval. Based on adoption of the scope by Coastal GasLink, connection designs will be advanced through detailed engineering. d) Regarding the connection points and meter facilities, Coastal GasLink anticipates completing an issued for construction design in Q3 2019 or later, with construction of those facilities to start no earlier than 2020, to meet any final requirements communicated to Coastal GasLink. Depending on what upstream arrangements the Participants choose to make and when they choose to communicate those requirements to Coastal GasLink, the final decision could move back or up. e) If the Participants decide that the CGL Pipeline will connect to NGTL in the Groundbirch area, Coastal GasLink anticipates transporting gas one-way from its in- let to the LNG Canada Facility.
Coastal GasLink has not received any request for bi-directional capability from the Participants, and is not designing for it.
March 12, 2019 Page 4 of 6
Coastal GasLink Pipeline Ltd. NEB 1.5 Jurisdiction over the Coastal GasLink Pipeline Response to Information Request Project MH-053-2018
Coastal GasLink is only permitted by the OGC for flow in one direction. Coastal GasLink addressed the OGC “Section Permits” in paragraphs 14 and 15 of its additional written evidence.1 As an example, Condition 1(a) of the OGC permit for section 1 of the pipeline includes the following:
Coastal GasLink could undertake design to facilitate e.1) or e.2) but has not.
In addition, Coastal GasLink considers the e.2) scenario particularly unlikely as the payment it receives for transport service is not dependent on either the price of gas or the rate of utilization of capacity on the CGL Pipeline. Currently, 100 percent of the CGL Pipeline’s capacity is contracted for on a 25-year primary term under take-or- pay. f) Coastal GasLink does not know. What the Participants’ arrangements are for supply upstream of the in-let to the CGL Pipeline are in the discretion of the Participants and are not yet finalized.
Coastal GasLink’s understanding is that the ability of NGTL to deliver gas to the in- let of the CGL Pipeline is contingent on matters including the following events, none of which has occurred: • NGTL securing a commercial agreement to underpin a project for a delivery point connecting to the CGL Pipeline; • NGTL filing the necessary application(s) with its regulator, the National Energy Board (NEB); • A public process before the NEB during which all issues could be aired, including any concerns of an NGTL shipper;
1 As noted in Coastal GasLink’s AWE, the Section Permits are available on line: https://www.bcogc.ca/public- zone/major-projects-centre/coastal-gaslink
March 12, 2019 Page 5 of 6
Coastal GasLink Pipeline Ltd. NEB 1.5 Jurisdiction over the Coastal GasLink Pipeline Response to Information Request Project MH-053-2018
• The NEB making one or more decision(s) in relation to those application(s) (e.g. facilities, tolls); • The decision(s) being to approve, rather than to deny, NGTL’s application(s); • In the event of approval, NGTL and its customer(s) deciding to proceed; and, • Physical construction of interconnection facilities including a meter station allowing custody transfer measurement of natural gas and a pipeline to connect the NGTL System to the CGL Pipeline.
If a connection is established, custody transfer from NGTL to the CGL Pipeline would occur at the custody transfer point and gas would be transmitted point-to-point in BC on the CGL Pipeline under a contract and nomination separate from any nomination made with NGTL.
March 12, 2019 Page 6 of 6
Coastal GasLink Pipeline Ltd. NEB 1.6 Jurisdiction over the Coastal GasLink Pipeline Response to Information Request Project MH-053-2018
IR Number: NEB 1.6
Category: Economic Matters
Topic: Functional Integration – Canada LNG demand
Reference: A97628-1, CGL, Additional Written Evidence, PDF Page 7 of 18
Preamble: The reference states that on completion of construction and commissioning, CGL will be responsible for operation of the pipeline. The customers underwriting the pipeline will direct CGL, as operator, to transport their gas within BC through a volume nomination process in accordance with the needs of their downstream LNG Canada export facility.
Request: a) Provide an overview of the LNG market that the LNG Canada export facility will serve and the expected utilization rate of the CGL Pipeline.
Response: a) Coastal GasLink does not have an overview of the LNG markets to be served through the LNG Canada Facility and does not analyze markets. LNG Canada and the other Participants may have analyses of the market(s) they expect to serve. Coastal GasLink does not serve these market(s). Coastal GasLink serves the Participants, who market their gas. Coastal GasLink does not need to conduct this market analysis for its business because the Participants have agreed to take all of their gas back at the outlet of the CGL Pipeline.
Coastal GasLink expects the utilization rate of the CGL Pipeline to be high. This is based on Coastal GasLink’s expectation that the Participants will seek to maximize the use of their downstream LNG facility, and on the fact that the CGL Pipeline capacity aligns with the capacity of that facility. Coastal GasLink’s business does not depend on utilization rate, as the Participants have contracted for all of the capacity on the CGL Pipeline on a take-or-pay basis for a primary term of 25 years.
March 12, 2019 Page 1 of 1
Coastal GasLink Pipeline Ltd. NEB 1.7 Jurisdiction over the Coastal GasLink Pipeline Response to Information Request Project MH-053-2018
|IR Number: NEB 1.7
Category: Economic Matters
Topic: Physical Connection
Reference: i) A97628-1, CGL, Additional Written Evidence, PDF Page 8 of 18 ii) A97628-1, CGL, Additional Written Evidence, PDF Page 17 of 18 iii) A97945-2, DLC Partnership Additional Written Evidence, PDF Page 27 of 33 iv) A97945-2, North Montney LNG Limited Partnership and Petronas Energy Canada Ltd. Additional Written Evidence, PDF Page 21 of 33
Preamble: Reference i) states that gas transported on the CGL Pipeline will be received at the inlet of the pipeline from the five underwriters and delivered to the inlet of the LNG Canada Facility.
Reference ii) states that the only service available on the CGL Pipeline is transportation within BC.
Reference iii) states that possible future connection to NGTL will be explored for the purposes of allowing Diamond LNG Canada Ltd. (DLC) to optimize its supply strategy over the life of the LNG Terminal, and provide DLC with the flexibility to have an additional source of supply or sell to other market in cases of equity gas interruption or LNG Terminal shut-down from time to time.
Reference iv) states that PETRONAS Canada will continue to optimize its gas supply solution, including but not limited to the use of NGTL System, to ensure it has operational flexibility and market optionality to support its future business requirements.
Request: a) Confirm that the CGL Pipeline will not be able to deliver gas to the NGTL System.
b) Provide a description of how the CGL Pipeline will provide optionality to sell to other markets referenced in iii) and iv), given that service available to the CGL Pipeline is for transportation within BC.
Response: a) As set out in more detail in Coastal GasLink’s response to NEB-CGL 1.5 e) and f), the CGL Pipeline is neither designed nor approved to flow gas towards the NGTL System. The direction it is designed for is from its in-let in eastern BC to its outlet in western BC.
March 12, 2019 Page 1 of 2
Coastal GasLink Pipeline Ltd. NEB 1.7 Jurisdiction over the Coastal GasLink Pipeline Response to Information Request Project MH-053-2018
b) The CGL Pipeline does not provide that optionality. The Participants may obtain optionality through their own upstream arrangements. Once the Participants’ gas reaches the in-let of the CGL Pipeline at Wilde Lake, Coastal GasLink provides its service: point-to-point transport within BC, east to west, for the Participants.
To receive service on the CGL Pipeline, a Participant will have to nominate a volume through Coastal GasLink, separate from any nomination it makes with an upstream company to get gas to the in-let of the CGL Pipeline.
March 12, 2019 Page 2 of 2
Coastal GasLink Pipeline Ltd. NEB 1.8 Jurisdiction over the Coastal GasLink Pipeline Response to Information Request Project MH-053-2018
||IR Number: NEB 1.8
Category: Economic Matters
Topic: Mr. Sawyer’s Additional Written Evidence
Reference: i) A97948-2, Mr. Sawyer, Additional Written Evidence, PDF Page 22 of 26 ii) A97628-1, CGL, Additional Written Evidence -, PDF Page 16 of 18 iii) A97948-2, Mr. Sawyer, Additional Written Evidence, PDF Page 10 of 26 iv) A97948-2, Mr. Sawyer, Additional Written Evidence, PDF Page12 of 26
Preamble: In reference i), Mr. Sawyer states that “The most recent EA Certificate amendment for CGL on the BC EAO website is dated May 15, 2018. The Unofficial Consolidated Version of the CGL EA Certificate indicates only one receipt meter station at Wilde Lake the CGL inlet.”
In reference ii), CGL states that it will construct five separate receipt meter facilities at the CGL inlet, with each meter facility dedicated to a single Participant.
In reference iii), Mr. Sawyer submitted a slide entitled “The Opportunity for NGTL Shippers.” Mr. Sawyer states that it has a diagram showing gas supply “From NIT” flowing into the CGL pipeline at the “Groundbirch Area” and proceeding either straight through to the “Kitimat Area” or exiting the CGL Pipeline at “NGTL Delivery Point, Vanderhoof Area.”
In reference iv), Mr. Sawyer states that “Every Trans Canada PipeLines Limited (TCPL) Annual Report from 2013 to 2017 inclusive describes the CGL Pipeline as “To deliver natural gas from the Montney gas producing region at an expected interconnect on NGTL near Dawson Creek, BC to LNG Canada’s proposed LNG facility near Kitimat, BC.”
Request: a) Does CGL have authorization to construct five meter stations? Explain the discrepancy between Mr. Sawyer’s references in i) and CGL’s statements in ii). Include all relevant authorizations obtained or required for meter stations.
b) Is CGL aware of NGTL’s plans for an NGTL Delivery Point in the Vanderhoof Area?
c) In CGL’s view, is the description in reference iv) an accurate
March 12, 2019 Page 1 of 2
Coastal GasLink Pipeline Ltd. NEB 1.8 Jurisdiction over the Coastal GasLink Pipeline Response to Information Request Project MH-053-2018
description of the CGL Pipeline? Provide details as to why or why not this is the case.
d) Provide a detailed map of the location(s) of the meter stations referenced in ii) and the inlet of the CGL Pipeline.
Response: a) Coastal GasLink has authorization to construct one meter station up to 4 ha in area at its inlet and this meter station may include multiple meters.
Coastal GasLink’s Certified Project Description (CPD) from the Environmental Assessment Office (EAO) also includes a meter station at Vanderhoof BC, which Coastal GasLink has no requests to develop and for which Coastal GasLink does not have a permit to construct from the Oil and Gas Commission (OGC), which would be required. For delivery, Coastal GasLink has one meter station, near the LNG Canada Facility. b) Yes. Coastal GasLink’s understanding is NGTL offered it, but that it did not proceed, and it is no longer considered an option by NGTL and the Participants. c) Yes. Coastal GasLink expects that the Participants will obtain supply from production in the Montney gas producing region. In addition, parties to this proceeding have stated their expectation that there will be a connection between the NGTL System and the CGL Pipeline.
The realization and if realized the extent of that connection are unknown. Open questions remain: whether this expectation will be realized; if realized, what use of the connection (e.g. regular, intermittent, back-up) would be made; and, what percentage of gas to be transported by the CGL Pipeline on an annual basis would be delivered to the CGL Pipeline through such a connection. d) The location of the one meter station (one station, multiple meters) referred to in Reference ii) is shown on Map Sheet 1 of the CPD. For ease of reference this is attached as Attachment 1.08-1. Within the yard at its in-let Coastal GasLink is permitted to use 4 ha for metering facilities. Design work is ongoing and Coastal GasLink does not yet have a final plot plan or survey of the metering facility at the in-let.
March 12, 2019 Page 2 of 2
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
! !
!
!
!
!
!
!
!
!
!
!
!
!
!
!
! Coastal GasLink Pipeline Ltd.
! Jurisdiction over the Coastal GasLink Pipeline Project Attachment NEB 1.8-1 Sec 19, TP 78, Rge 19
Groundbirch ! Day Creek
Sec 18, TP 78, Rge 19 ! .
!
!
Sec 32, TP 78, Rge 19
!
!
!
!
! PLAN H819
!
!
Sec 29, TP 78, Rge 19
!
BC RAILWAY PLAN A2000
!
93P.086
Sec 17, TP 78, Rge 19
!
Sec 20, TP 78, Rge 19
!
Corridor Widening PEACE RIVER
!
DISTRICT KP 3+000 -
!
Lake C/S
!
Wilde
!
93P15
93P.076
KP 1 !
!. !
KP 3
!.
! KP 2
KP 0 !. !.
!. !
KP 4 !.
!.
! !.
!
!
!
Lake M/S
!
Wilde
!
!
Sec 28, TP 78, Rge 19
!
Sec 33, TP 78, Rge 19 ! JOHN HART HWY No 97 1TU541
Sec 21, TP 78, Rge 19
!
! Y ! WA 5 Sec 16, TP 78, Rge 19 AIL BC R R Y
! 2 3 9
!
!
BC RAILWAY 5RY239
! Legend
! !. Kilometre Post Highway Park/Protected Area
! Compressor Road Regional District Station Location Railway
! Cadastral Boundary Meter Existing Pipeline Station Location ! Transmission Line Old Growth ! Managment Area Certified Pipeline Corridor Contour Line Ungulate Winter Range ! Alternate Corridor Watercourse Coastal GasLink Pipeline Project
Waterbody Wildlife Habitat Area J 0 Corridor Widening O 0
! H City/Town 7 No Construction Wildlife Habitat Area - N Sheet 1 of 135
Footprint Indian Reserve Proposed H U
ART T
! Certified Pipeline Corridor 5
0 0.25 0.5 0.75 1 H 1 1:20,000 Km October 2014 Rev 1 ! W Y 7 No 9 ! March 2019 Page 1 of 1
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
!
! Coastal GasLink Pipeline Ltd. NEB 1.9 Jurisdiction over the Coastal GasLink Pipeline Response to Information Request Project MH-053-2018
IR Number: NEB 1.9
Category: Economic Matters
Topic: Governance Structure
Reference: A97628-1, CGL, Additional Written Evidence, PDF Page 12 of 18
Preamble: The reference describes the governance structure of the CGL Pipeline during construction, including that construction during this phase will be controlled by consensus between CGL and LNG Canada.
Request: a) Provide copies of all governance documents which underpin the structures referred to in paragraphs 53 to 57 of reference i), including documents establishing the roles and responsibilities of the various committees described in paragraph 54.
b) Describe, and provide copies of any governance documents that support, what would happen in a situation where consensus could not be reached at the Executive Committee level, as described in the reference. Such documents should describe which senior executives at the parent companies are responsible for resolution of any disagreements.
c) During operations, will the governance structure described in the reference remain the same?
c.1) If not, describe, in detail, what will replace it. In the response, include details as to how LNG Canada will be involved in decision making during operations, as well as all supporting documents.
Response: a) Article 7 of the Project Development Agreement (PDA) sets out governance for the construction phase, during which the consensus-based committee structure is used, including the roles and responsibilities of the various committees.
Article 7 is set out as Attachment 1.9-1 to this information request response, with personal information and other confidential information not necessary to setting out the mechanics of governance redacted. b) As noted in the response to a) above, per Section 7.2 of the PDA, TCPL is required to cause Coastal GasLink to implement all decisions of the Executive Committee unless it determines that the implementation would breach the performance standard.
Per Section 7.7(c), TCPL shall cause Coastal GasLink to not proceed with the matter for which consensus was not achieved.
March 12, 2019 Page 1 of 2
Coastal GasLink Pipeline Ltd. NEB 1.9 Jurisdiction over the Coastal GasLink Pipeline Response to Information Request Project MH-053-2018
If an Executive Committee deadlock is declared by a party to be a dispute, then it would go to senior executives for resolution. A “Senior Executive” is defined as “any individual who has the authority to negotiate a settlement of the Dispute for that Party.” For TCPL, this depends on the subject matter and quantum of the dispute and would be someone with the appropriate portfolio or business knowledge and signing authority. If the Senior Executives are not able to resolve the dispute, then, depending on the subject matter of the dispute, it would either go to arbitration or litigation. c) During operations, the transportation service agreements (TSAs) will govern and Coastal GasLink is contractually responsible for operatorship.
The TSAs provide for an operating committee comprised of Coastal GasLink, LNG Canada, and each of the Participants. The operating committee is for information- sharing, the coordination of planned outages, review and consultation on expansion proposals, and review of proposed changes to the Pipeline Rules. There is no voting on the operating committee, except in regard to changes to the Pipeline Rules. (The Pipeline Rules govern day-to-day operational matters for the CGL Pipeline, and include subject matter such as gas specifications, nominations, measurement, pressure and temperature, curtailment, imbalance resolution, etc.)
Voting on changes to the Pipeline Rules is based on approval by percentage of capacity, with one category of amendments requiring 51% approval and the other requiring 75% approval. Coastal GasLink can veto or impose changes if required to meet governmental requirements or to satisfy its obligation to operate the CGL Pipeline as a reasonable and prudent operator.
During operations LNG Canada will act as agent for the Participants on items that are the subject of collective decision-making by the Participants, such as expansions.
With respect to expansions, Coastal GasLink is required to carry out expansions requested by the Participants up to a maximum scope. Expansions beyond that require the agreement of both Coastal GasLink and the Participants and the negotiation of separate commercial terms.
For clarity, TCPL is not a party to the TSAs. The only TCC party to any of the TSAs is CGL LP by its general partner Coastal GasLink Pipeline Ltd.
March 12, 2019 Page 2 of 2
Coastal GasLink Pipeline Ltd. NEB 1.10 Jurisdiction over the Coastal GasLink Pipeline Response to Information Request Project MH-053-2018
IR Number: NEB 1.10
Category: Engineering Matters
Topic: SCADA Integration of Coastal Gaslink Pipeline Project (Project) and TransCanada Corporation (TCC)
Reference: A97628-1, CGL, Additional Written Evidence, PDF Pages 13-17 of 18
Preamble: SCADA (Supervisory Control and Data Acquisition) systems are the means by which pipeline systems are controlled and operated. They enable the remote operation and monitoring of a pipeline system, and the control of flow and line pack within the system. As stated in the reference, the actual control of pipeline system can be located (nearly) anywhere.
Paragraph 65 of the reference states that CGL was considering locating the controls for the Project in Calgary to be in proximity to gas control for other TCC-owned companies.
Request: Provide the following:
a) Explain how operational control, the SCADA system, will be connected to the other TCC control systems. In your response, include an explanation of the extent and nature of the connection.
b) Would the existence of the connection between CGL and TCC systems be unique as compared to the connection between:
b.1) TCC and non-TCC pipelines?
b.2) TCC and its other subsidiaries?
If yes, describe why and how.
c) Would the connection between CGL control systems and TCC control systems create a risk to the control and response for the two systems? If not, explain why. If the connection could create some risk, explain how and by whom that risk would be managed.
d) What would be the differences be between the TCC control system and the CGL control systems? In the answer, include:
d.1) How many resources would they share.
March 12, 2019 Page 1 of 2
Coastal GasLink Pipeline Ltd. NEB 1.10 Jurisdiction over the Coastal GasLink Pipeline Response to Information Request Project MH-053-2018
d.2) Whether the systems share equipment and resources in the control room, for example, i. Screens; ii. Terminals; iii. Communications systems; iv. Personnel; v. Qualifications for personnel; and vi. Any other equipment or resource that is shared between the systems.
Response: a) through d)
Given the length of time before the in-service date, design work for gas control is at an early stage.
Coastal GasLink expects that the technical aspects of design, and hardware, will be similar to other TCC pipelines. As noted in its additional written evidence, Coastal GasLink plans to have the terminals to be used for SCADA and operational control of the CGL Pipeline co-located with terminals for other TCC pipeline assets, whether oil or gas, federal or provincial, as it views this as the best choice for efficiency and safety.
Coastal GasLink expects that personnel staffing terminals used for the CGL Pipeline will meet the same standards and qualifications as other personnel performing substantively the same technical role.
Location, design and staffing (and whether staff will be shared, and if so with what other TCC companies) have not been determined.
March 12, 2019 Page 2 of 2
Coastal GasLink Pipeline Ltd. NEB 1.11 Jurisdiction over the Coastal GasLink Pipeline Response to Information Request Project MH-053-2018
IR Number: NEB 1.11
Category: Engineering Matters
Topic: Manuals, Specifications and Procedures Integration of the Project and TCC
Reference: A97628-1, CGL, Additional Written Evidence, PDF Pages 13-17 of 18
Preamble: CGL has described, in paragraph 69 of the reference that it plans to use standard TransCanada PipeLines Limited (TCPL) engineering and operational procedures customized for CGL’s requirements.
Request: Provide the following:
a) Explain whether CGL’s engineering and operational procedures would remain consistent with TCC’s over time. If so, explain how.
b) Would TCPL retain authority over the engineering and operational procedures and/or be required to provide approval of any changes or deviations to the documents?
Response: a) TCC engineering and operational procedures already vary by subject matter or by line of business (e.g. gas pipelines, oil pipelines, storage, generation) and by jurisdiction (by country for federally regulated entities, and within a country by province or state for non-federally regulated entities).
Within the natural gas transport space in Canada, Costal GasLink anticipates starting from a place of consistency and to vary existing procedures only as required by the context and requirements of Coastal GasLink’s business. Coastal GasLink would make use of its parent’s procedures and leverage its experience developing engineering and operations procedures. These would be customized to meet contractual requirements (including regarding reliability, which drives maintenance and operation work unique to Coastal GasLink) and provincial requirements.
For example, the TCC subsidiary TCPL develops standardized designs referencing CSA Z662-15 and the National Building Code for use on Canadian federally regulated assets. The CSA Z662-15 standard is also a legal requirement for a pipeline regulated by British Columbia, but engineering and operational procedures in British Columbia may need to be customized or varied to account for provincial building codes, WorkSafeBC requirements, municipal or regional district permitting and inspection, provincial employment standards, and requirements under other British Columbia legislation, such as the Local Government Act, RSBC 2015, c 1.
March 12, 2019 Page 1 of 2
Coastal GasLink Pipeline Ltd. NEB 1.11 Jurisdiction over the Coastal GasLink Pipeline Response to Information Request Project MH-053-2018
b) During construction, the Engineering, Design, and Constructability Committee is responsible for engineering, construction, operating and commissioning procedures. During this phase TCPL is responsible for directing Coastal GasLink to comply with the Project Development Agreement (PDA) requirements, including to comply with committee direction from the Participants.
During operations, Coastal GasLink is contractually responsible for operatorship and transportation service. As described in the response to (a), the starting point for the engineering and operational procedures is TCPL procedures, which by default apply to all TCC gas assets in Canada. As the party contractually responsible for operations, and the party to the transportation service agreements, Coastal GasLink may select procedures to meet the requirements of its business, or contract with parties to meet its requirements.
March 12, 2019 Page 2 of 2
Coastal GasLink Pipeline Ltd. NEB 1.12 Jurisdiction over the Coastal GasLink Pipeline Response to Information Request Project MH-053-2018
IR Number: NEB 1.12
Category: Engineering Matters
Topic: Training and Oversight of Field Personnel
Reference: A97628-1, CGL, Additional Written Evidence, PDF Page 14 of 18
Preamble: CGL states in paragraph 66 of the reference that CGL’s field personnel and equipment would be located in British Columbia.
Request: Provide the following:
a) Explain whether CGL’s field personnel would be trained and qualified by TCPL. If so, to what extent and how.
b) Would CGL’s field personnel and equipment be available for use by TCPL? If so, to what extent and how.
c) Would TCPL’s field personnel and equipment be available for use by CGL? If so, to what extent and how?
Response: a) Coastal GasLink expects to leverage the mature training programs and training requirements that are in place for all TCPL operating assets regardless of jurisdiction. These training programs apply to resources in all provinces, and would be drawn on or transferred to British Columbia, and adapted to local requirements on a case-by-case basis.
Any agreement made with an affiliate (TCPL or otherwise) to train Coastal GasLink personnel would comply with principles against cross-subsidization, including those embodied in applicable inter-affiliate code of conduct requirements as between rate-regulated and non-rate-regulated affiliates, which are described in Coastal GasLink’s additional written evidence. b) and c)
It is anticipated that Coastal GasLink field personnel and equipment will be exclusively dedicated to Coastal GasLink during operations.
Coastal GasLink is subject to contractual reliability and field response time requirements, under its agreements with the Participants, for facilities that are both remote and distant from other TCC owned assets. This militates in favor of Coastal
March 12, 2019 Page 1 of 2
Coastal GasLink Pipeline Ltd. NEB 1.12 Jurisdiction over the Coastal GasLink Pipeline Response to Information Request Project MH-053-2018
GasLink relying on its own field personnel and equipment, stationed proximate to its facilities.
However, if Coastal GasLink resources were to be used by an affiliate, or vice versa, these services will be paid for as appropriate in order to avoid cross-subsidization and comply with applicable inter-affiliate codes of conduct.
March 12, 2019 Page 2 of 2
Coastal GasLink Pipeline Ltd. NEB 1.13 Jurisdiction over the Coastal GasLink Pipeline Response to Information Request Project MH-053-2018
IR Number: NEB 1.13
Category: Engineering Matters
Topic: Integrity Management System Integration
Reference: A97628-1, CGL, Additional Written Evidence, PDF Pages 13 to 17 of 18
Preamble: In paragraph 65 to 69 of the reference, CGL describes some aspects of its integrity management system.
Integrity Management Systems are dynamic systems for anticipating and maintaining the integrity of a pipeline system. These systems, and the documents that they’re comprised of, evolve to suit the needs and demands of an operating company.
Request: Provide the following:
a) Is the integrity management system anticipated for CGL independent of the integrity management systems used by TCC? If so, discuss how.
b) Would inline inspections be coordinated between TCC and CGL? If yes, describe how.
c) Would other integrity management activities be coordinated between TCC and CGL? If yes, describe how.
Response: a) Coastal GasLink is contractually responsible for operatorship and integrity management of the CGL Pipeline. For integrity management (e.g. aerial survey, inline inspection, digs), Coastal GasLink could use one or more of its own personnel, third party vendors, or contract with another TCC subsidiary for services. What option or mix of options it will choose is yet to be determined. b) and c)
It is expected that in-line inspection and other integrity work will be driven by Coastal GasLink’s inspection needs, terrain, and the Participants’ unique requirements independently of the needs or budgets of other TCC owned companies, with the costs passed through to the Participants. Coastal GasLink may share services as described in its response to NEB-CGL 1.11 and would draw on the experience of its parent.
March 12, 2019 Page 1 of 1