Ms. Sheri Young, Secretary to the Joint Review Panel Enbridge Northern Gateway Project

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1 (A42789) July 12, 2012 E-FILE Attention: Ms. Sheri Young, Secretary to the Joint Review Panel Enbridge Northern Gateway Project National Energy Board 444 Seventh Avenue SW Calgary, AB T2P 0X8 Dear Ms. Young, Re: Northern Gateway Pipelines Application to the National Energy Board Enbridge Northern Gateway Project OH NEB File No: OF-Fac-Oil-N Follow-up to Information Requests Northern Gateway is now providing reports that have been prepared which respond to various information requests as follows: Ecological and Human Health Risk Assessment for Pipeline Spills (refer to Northern Gateway s response to Federal Government IR 118; Conceptual Fish Habitat Mitigation and Compensation Plan (refer to Northern Gateway s response to Federal Government IR 2.8a); Conceptual Marine Fish Habitat Compensation Plan (refer to Northern Gateway s response to Federal Government IR 2.8a) and JRP IR 8.18a) and b); and (refer to Northern Gateway s response to Federal Government IR 1.69 and 2.54). 3000, st Street SW, Calgary, AB, T2P 3L8 (T) (F)

2 (A42789) These documents are being filed electronically with the Board and will be served upon all OH Parties. If the Board should require additional information, please contact the undersigned at (403) Yours truly, Ken MacDonald Vice President, Law and Regulatory Northern Gateway Pipelines Limited Partnership cc: CEAA Attention: Sarah Devin 3000, st Street SW, Calgary, AB, T2P 3L8 (T) (F)

3 ENBRIDGE NORTHERN GATEWAY PROJECT Prepared by David Reid and Carol Thompson AMEC Environment & Infrastructure Calgary, Alberta July 2012 CE04112/406

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5 Executive Summary Executive Summary The Enbridge Northern Gateway Project (the Project) will potentially affect 489 ha of wetlands made up mainly of swamps and fens located in the Southern Alberta Uplands and Interior Plateau. Power lines will potentially affect an additional 106 ha of wetlands, largely swamps in the Coast Mountains. Wetland functions that will be affected by the Project include hydrology, water quality, ecology and habitat. Following review of the Section 52 Application for the Project, Environment Canada (EC) requested that Northern Gateway provide a detailed assessment of wetland functions likely to be adversely affected and to provide more details on wetland compensation and monitoring plans. Following receipt of Environment Canada s written evidence submission in December 2011, this assessment was updated and replaces the earlier draft dated November The assessment of the potential effects of the pipelines and ancillary facilities was based on a pipeline right-of-way (RoW) width of 50 m and a power line RoW width of 40 m which make up the Project Development Area (PDA). The 1 km wide pipeline corridor described in the Application is intended only to aid in the planning of the pipelines and the completion of the environmental assessment. The centreline shown within the 1 km corridor is for illustrative purposes only. The final locations of the pipelines could occur anywhere within the 1 km corridor. Following approval of the Project, the exact location of the pipelines will be finalized within the 1 km wide corridor during detailed engineering. The final pipeline route will be selected based upon the route selection criteria described in the Application (Volume 3, Section 2). The phases associated with Project activities used in the assessment include the following: baseline existing conditions prior to development; construction - includes RoW and infrastructure clearing, pipe installation, cleanup and reclamation; operations - includes normal activities with stable surface conditions and reclaimed vegetation cover; and decommissioning - includes removal of above ground structures, recontouring and reclamation. Environmental protection measures are described in detail in the Construction Environmental Protection and Management Plan in the Application Volume 7A. These include measures to protect wildlife, fisheries, hydrology, water quality and vegetation along with emergency response approaches and capabilities. The residual effect of the Project on wetlands is assessed as adverse, low to moderate magnitude, local extent, long-term, reversible and not significant. A plan to monitor the effects of the Project on wetlands will be developed prior to commencement of construction. This plan will be prepared in consultation with federal and provincial regulatory agencies, landowners, participating First Nations and other stakeholders. The plan will include goals, site selection, monitoring parameters, standards, schedule and adaptive management. July 2012 Page i

6 Executive Summary A wetland compensation plan will be developed prior to construction in consultation with federal and provincial regulatory agencies, landowners, participating First Nations and other stakeholders. The plan will include goals, Project wetland interactions, compensation ratios, implementation, monitoring and maintenance. Page ii July 2012

7 Table of Contents Table of Contents 1 Introduction Spatial Boundaries Project Development Area Project Effects Assessment Area Regional Effects Assessment Area Temporal Boundaries Project Description Facilities Pipelines Ancillary Facilities Kitimat Terminal Centreline Surveys Construction Construction Spreads, Camps and Stockpile Sites Scheduling and Timing Right-of-Way Access Clearing Soil Salvage Grading and Trenching Lowering In and Backfilling Watercourse Crossings RoW Cleanup Pipeline Testing Reclamation Enhanced Reclamation Pipeline Operations RoW Inspection and Monitoring Containment Management Decommissioning Environmental Protection and Management Plan Methods Wetland Classification and Function Wetland Types Bog Wetland Fen Wetland Marsh Wetland Swamp Wetland Shallow-water (Aquatic) Wetland Wetland Function Hydrological Function Biogeochemical Function July 2012 Page iii

8 Table of Contents Ecological Function Habitat Function Results Wetland Extent Wetland Function Mitigation Measures Project Design Measures General Practices Wildlife Protection Measures Fisheries Protection Measures Vegetation Protection Measures Assessment Identifications Timbered Land Rare Plants Wetlands Emergency Response Approaches and Capabilities Residual Effects Cumulative Effects Proposed Wetland Monitoring Plan Introduction Wetland Type Site Selection Methods Sample Plot Design Water Depth and Water Quality Vegetation Schedule Data Entry Data Analysis and Reporting Proposed Wetland Compensation Plan Goals Project Wetland Interactions Summary of Baseline Information of Affected Wetlands Compensation Wetland Areas Implementation Work Plan Monitoring and Maintenance Plan Literature Cited Page iv July 2012

9 Table of Contents List of Tables Table 5-1 Wetlands Affected in Each Physiographic Region Table 5-2 Wildlife Species at Risk and Species of Interest in Wetlands Table 5-3 Rare Plant Species in Wetlands in the PEAA in Alberta Table 5-4 Rare Plant Species in Wetlands in the PEAA in British Columbia Table 5-5 Potential Effects on Wetland Function Table 7-1 Residual Effects on Wetlands List of Figures Figure 1: Physiographic Regions Along the Pipeline Route... 4 Figure 2: Wetland Monitoring Plot July 2012 Page v

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11 Section 1: Introduction 1 Introduction Following review of the Section 52 Application for the Project, EC requested that Northern Gateway provide a detailed assessment of wetland functions likely to be adversely affected by the Project and to provide more details on wetland compensation and monitoring plans. A meeting was held between EC and Northern Gateway on 9 August 2011 to clarify various items. This document provides a response to the Information Requests (IR) from EC included in Federal Government IR 1.69, 1.70 and 1.71, and Federal Government IR 2.54 and Following receipt of Environment Canada s written evidence submission in December 2011, this assessment was updated and replaces the earlier draft dated November The assessment is based on the following information sources: Northern Gateway Project Section 52 Application, Vol. 1 Overview and General Information Section, May 2010; Northern Gateway Project Section 52 Application, Vol. 3 Engineering Construction and Operations, May 2010; Northern Gateway Project Section 52 Application, Vol. 6A Environmental and Socio-economic Assessment (ESA) - Pipelines and Tank Terminal, May 2010; Northern Gateway Project Section 52 Application, Vol. 7A Construction Environmental Protection and Management Plan, May 2010; Northern Gateway Project Section 52 Application, Vol. 7B Risk Assessment and Management of Spills - Pipelines, May 2010; and Northern Gateway Project Section 52 Application, Terrestrial Technical Data Reports, October Spatial Boundaries Project Development Area The Project development area (PDA) is the disturbed area of the pipeline route, including the RoW, the Kitimat Terminal and associated infrastructure (e.g., power lines, permanent and temporary access roads, pump stations, staging areas, construction camps, stockpile sites and excess cut disposal areas for the tunnels). The PDA includes a permanent 25 m wide RoW and 25 m of temporary workspace. Power lines will require a 40 m wide RoW Project Effects Assessment Area The Project effects assessment area (PEAA) is a 1 km wide linear area that includes the terrestrial PDA and a defined area around the centreline of the terrestrial PDA (500 m). The potential effects on wetlands are evaluated within the boundaries of the PEAA. July 2012 Page 1

12 Section 1: Introduction Regional Effects Assessment Area The regional effects assessment area (REAA) is an area approximately 30 km wide that contains the PEAA. Within the REAA, cumulative environmental effects could occur depending on physical and biological conditions (e.g., air sheds, watersheds, and seasonal range of wildlife movements) and the type and location of other past, present or reasonably foreseeable projects or activities. 1.2 Temporal Boundaries The following phases of Project activities are used to assess Project effects: baseline includes the biophysical characteristics of the environment at the time of the assessment, and all existing disturbances of past and present projects; construction includes RoW and infrastructure site clearing and grading, RoW ditching, backfilling and reclamation; operations includes normal activities with stable surface conditions and reclaimed vegetation cover in temporary disturbance areas and modified vegetation cover within long-term disturbed areas; and decommissioning includes removal of all above ground structures, recontouring surfaces to stable conditions and reclaiming the site according to a reclamation plan Page 2 July 2012

13 Section 2: Project Description 2 Project Description A brief Project description is presented in this section to focus on those components likely to have effects on wetlands. 2.1 Facilities The Project includes constructing, operating, and decommissioning two pipelines, associated facilities and the Kitimat Terminal Pipelines Northern Gateway is applying for approval to install the oil export and condensate pipelines within a 1 km wide corridor, which is approximately 1,172 km long (Figure 1). The pipelines will be located in a common, permanent 25 m wide RoW, extending from the initiating station near Bruderheim to the Kitimat Terminal. Following approval of the Project, the exact location of the two pipelines will be finalized within the 1 km wide corridor during detailed engineering (see section 2.2) The final pipeline route will be selected based upon the route selection criteria described in the Application (Volume 3, Section 2) Ancillary Facilities Ten electrically powered pump stations on the RoW will be required to operate the pipelines including the initiating stations at Bruderheim (for oil) and Kitimat (for condensate). Permanent roads and power lines will be required for the construction and operations of the pump stations. Information on the power line locations, lengths and widths is preliminary and will be confirmed during detailed design. Construction of the power lines will involve clearing of the easement, installation of standard wooden poles and stringing of the electric cables. A temporary road will be required along some parts of the power line easement during construction Kitimat Terminal The Kitimat Terminal is on the west side of Kitimat Arm and refers to the tank terminal (the area inside the security fence) and the marine terminal, as well as the undeveloped area outside the security fence that also includes the excess cut disposal area. The total area is 478 ha: 220 ha inside the security fence (the area of infrastructure development is discussed in detail in Application Volume 3, Section 9) and 258 ha outside the security fence. July 2012 Page 3

14 Section 2: Project Description Figure 1: Physiographic Regions Along the Pipeline Route Page 4 July 2012

15 Section 2: Project Description 2.2 Centreline Surveys Following approval of the Project, the exact location of the two pipelines will be finalized within the 1- km wide corridor during detailed design. The determination of the final route will incorporate: detailed engineering construction, and operational considerations further site-specific constraint mapping results of Aboriginal Traditional Knowledge studies further biophysical investigations (e.g., identification of site-specific habitat features such as wildlife trees, wetlands, rare plants), archaeological surveys; and input from participating Aboriginal groups and communities, landowners, the public, other interested parties and government agencies. The intent of these various surveys and undertakings will be to obtain finer-scale information to aid in the final routing for the two pipelines. The location of the probable centreline will be surveyed and marked. Centreline surveys will then be conducted by teams typically consisting of an engineer, a botanist, a wildlife ecologist and an archaeologist. A fisheries biologist will be included to assist in finalizing water crossing locations. Representatives of First Nations for the traditional territories that overlap that part of the pipeline will also be included in the team. Each biophysical specialist, the archaeologist and the First Nations representative will be responsible for identifying important design constraints, possible alternatives to avoid or minimize effects on sensitive features and requirements for specialized construction methods during pipeline installation. Where a feature cannot be avoided, mitigation measures will be identified including details on seasonal restrictions for certain activities, habitat compensation, reclamation methods, etc. If there are conflicts among engineering, biophysical, archaeological, fisheries or First Nations, the team will work to select the route best suited for pipeline safety while also avoiding or minimizing effects on as many sensitive features as possible. Detailed environmental alignment sheets will be developed. A separate set of alignment sheets will be developed for preparation of the pipeline RoW (i.e., clearing, grubbing) and another set for the trenching and construction of the pipeline. Within each set, the alignment sheets will identify the specific location (i.e., kilometre post start and finish) of environmental-sensitive or cultural-sensitive features characteristics and detail the mitigation measures to be employed during construction in order to minimize project effects. Details on access management during clearing and construction, and removal of access not needed for permanent operations will also be included. The construction alignment sheets will be completed and provided to the NEB for review and comment at least 60 days prior to the start of clearing. The construction alignment sheets will also be completed and provided to the NEB at least 60 days prior to the start of construction. July 2012 Page 5

16 Section 2: Project Description Additional detail will be provided in an updated Construction Environmental Protection and Management Plan (EPMP). The Construction EPMP will describe the approach and commitment by construction and project personnel so that the Project is carried out in a manner that protects the environment during construction. It will outline the general and specific methods that will be applied for the Project and will be used as a guidance document for construction and project personnel. The updated Construction EPMP will document the requirements to be followed to ensure that the Project is constructed under applicable regulations, internal policies and procedures and will meet project requirements. The Construction EPMP will be completed and provided to the NEB at least 60 days prior to the start of clearing. Clearing of the pipeline RoW and preparation for pipeline construction will not begin until the alignment sheets for the RoW preparation have been completed and provided to the NEB. Clearing will proceed in spreads during the approved timing windows determined by government agencies such as Canadian Wildlife Service (to minimize effects on migratory birds) and Fisheries and Oceans Canada. 2.3 Construction Construction Spreads, Camps and Stockpile Sites Construction of the pipelines and associated facilities will require the temporary use of land for construction camps and stockpile sites. Where possible, these facilities will be located on previously disturbed sites Scheduling and Timing Construction of the Project is scheduled for a 42 month period to achieve the planned in-service date, and to provide for a safe and efficient work progression while limiting adverse environmental and socioeconomic effects. An additional six months might be required to complete construction of the Kitimat Terminal. Clearing activities for the first construction season will begin the year before pipeline construction Right-of-Way Access Existing access to the RoW (e.g., forestry roads) will be used during construction wherever practical. Temporary access is assessed in a qualitative manner Clearing Clearing of work areas will be carried out to reduce the potential for erosion, limit the removal of vegetation outside the development area and optimize the reclamation effort. Merchantable timber will be salvaged as determined in the Timber Salvage Plan. In some areas, timber will be retained on the RoW to be rolled back onto disturbed areas to assist in the control of soil erosion, for watercourse reclamation or for control of access onto the RoW. Tree stumps and roots over the ditchline will be grubbed (removed) and, in other areas of the construction workspace, stumps will be grubbed or cut flush with the soil surface. Vegetation that is not merchantable will be burned or chipped and spread over the RoW. Page 6 July 2012

17 Section 2: Project Description Additional details are provided in the Construction Environmental Protection and Management Plan (EPMP) (Application Volume 7A) Soil Salvage Topsoil and other organic material will be conserved, as directed by provincial regulatory authorities or stockpiled if the material is required for reclamation efforts for Project infrastructure. These areas will be noted on the construction drawings and environmental alignment sheets. Efforts will be taken so that compaction and rutting are limited. Where soil salvage is required, soils will be recovered to limit the loss of organic matter and mixing of different soil horizons Grading and Trenching Grading on slopes will be limited to the extent practical. Trenches will be dug to depths and widths that can accept the pipe dimensions, pipeline separation requirements, tie-ins and watercourse crossings, while reducing the environmental effects of erosion, slope instability and potential for sediment effects on watercourses. For most of the RoW, trenches will be dug to a minimum of 8 m separation (centre to centre of each pipeline). The minimum distance from the outside of the pipelines to the edge of the maintained RoW will be 4 m. The minimum depth of cover to construction grade will be 0.9 m. The minimum depth of cover at watercourse crossings will be 1.2 m Lowering In and Backfilling Pipes will be brought to the RoW and will be bent and welded on-site before being joint-coated, inspected and lowered into the trench Watercourse Crossings The pipelines will cross 773 watercourses, of which 669 are fish-bearing. At some crossing locations, fisheries protection, as well as engineering constraints, has played a key role in selection of the crossing method. Where a backup crossing method is required (trenchless and some isolated crossings), the location of the crossing has been selected to accommodate both the primary and back-up crossing method. Watercourse crossing methods will include isolation, directional drilling, and aerial and open-trench methods. The method chosen will depend on a variety of environmental, engineering and societal issues (e.g., other uses of the watercourse, seasonal fisheries or wildlife limitations, terrain or geotechnical limitations) RoW Cleanup Cleanup of the RoW and other construction activities will be carried out as quickly as practical to prepare the areas for reclamation. July 2012 Page 7

18 Section 2: Project Description Pipeline Testing Before commissioning, the pipelines will be cleaned, pressure tested and inspected. Any damaged or defective portions of the pipelines will be repaired. The majority of the testing will be done with water (i.e., hydrostatic testing); however, some portions will be tested with air. Details on testing (e.g., water sources, discharge methods and locations, use of air) will be determined during detailed design Reclamation Reclamation refers to standard measures taken during construction to limit adverse environmental effects and return affected lands to a stable condition and equivalent land capability. During reclamation, areas will be regraded as required (e.g., areas having erosion gullies, vehicle ruts or trench settlement). The RoW will be recontoured as close to the pre-construction profile as feasible or to a stable angle of repose. RoW drainage patterns will also be returned to as close to pre-construction contours as practical and final erosion control structures will be installed. Topsoil will be prepared for revegetation and, ultimately, the RoW will be reclaimed as per landowner agreements and regulatory requirements Enhanced Reclamation Enhanced reclamation refers to activities that will be implemented to enhance the ecological integrity of affected lands. Site-specific reclamation issues will be identified and documented in specific plans. Examples of these techniques may include weed control, reseeding with native seed mixes, enhancement of wildlife habitat, wetland and watercourses, and sensitive soils reclamation. The plan will be developed in consultation with regulatory agencies and stakeholders. A post-construction monitoring and follow-up program will also be implemented. 2.4 Pipeline Operations The following provides a summary of some of the key activities that will be carried out during pipeline operations to protect the integrity of the pipelines and allow for successful reclamation of the areas affected by pipeline construction through to final abandonment RoW Inspection and Monitoring Once the pipelines have been commissioned, Northern Gateway will initiate regular RoW inspection programs. The pipelines will be monitored to identify anomalies that may occur and initiate appropriate remedial action as required. This monitoring program will include regularly scheduled aerial reconnaissance of the entire RoW to help detect any anomalies along the RoW, such as third party encroachments, construction activity near the pipelines, failure of erosion control and any natural events (e.g., rock or snow slides). This aerial reconnaissance will provide an overview of the state of the RoW and monitor the success of the revegetation program. Page 8 July 2012

19 Section 2: Project Description As part of an ongoing monitoring program, the RoW will be frequently assessed to evaluate the success of revegetation. Any structural or aesthetic defects will be identified and corrected (e.g., recontouring of slumped or mounded areas to prevent water impoundment, removal of weeds, reseeding of areas along the RoW). In addition, vegetation control will be ongoing so that areas of the pipeline RoW that must remain visible from the air at all times are kept clear of large vegetation Containment Management An assessment of the potential for spills for the pipelines and related measures is in Application Volume 7B. The information contained there will be used to help develop emergency response plans and to identify personnel and equipment needs (e.g., response trailers) to be able to best respond, if required. 2.5 Decommissioning Above ground infrastructure will be removed. Underground pipelines and structures will be abandoned in place according to regulations and standards at the time of decommissioning. Unless government or local authorities decide to retain them, it is assumed that all Kitimat Terminal infrastructure will be removed to the top of the substrate and reclaimed according to the regulations and standards at the time of decommissioning. 2.6 Environmental Protection and Management Plan The Construction EPMP (Application Volume 7A) describes the environmental management aspects that will be applied to the Project during construction of the pipelines and associated facilities. The Construction EPMP gives a provisional description of the general and specific methods that will be applied for the Project and Northern Gateway s commitment to conduct the Project in a manner that protects the environment. Once detailed engineering and route selection have been completed, a final Construction EPMP will be produced as a guidance document for construction purposes and Project personnel. July 2012 Page 9

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21 Section 3: Methods 3 Methods Existing data sources for wetlands in the PEAA within Alberta included: Alberta Vegetation Inventory (AVI) (ASRD 2009a, Internet site); and aerial photographs of the PEAA (ASRD 2009b, Internet site). Existing data sources for wetlands in the PEAA within British Columbia included: aerial photographs (Integrated Land Management Bureau, Crown Registry and Geographic Base [CRGB] 2009a, Internet site); Vegetation Resource Inventory (VRI) data; scale 1:20,000 (BC MoF 2009b, Internet site); Terrain Resource Information Management (TRIM) mapping (CRGB 2009b, Internet site); biogeoclimatic subzone/variant mapping Version 7.0 (BC MoF 2009c, Internet site); and 2006 SPOT imagery (5 m resolution) (Lunctus Geomatics Corp. 2006). Wetlands were delineated from the above information and confirmed by field surveys. Details of the methods are presented in Application Volume 6A, Section Assessment Methods for Vegetation Diversity and Technical Data Report Vegetation, Section 2.6 Wetlands. A footprint analysis was conducted to identify the total area of wetlands that would be crossed by the 50 m wide RoW (both permanent and temporary) including ancillary facilities. Power line easements were assessed on a 40 m wide RoW and other facilities outside of the RoW were assessed on the size of their footprint. July 2012 Page 11

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23 Section 4: Wetland Classification and Function 4 Wetland Classification and Function 4.1 Wetland Types Wetlands are areas where the vegetation and soil development are largely dependent on the saturation of the soils with water for extended periods of time, resulting in generally low soil oxygen levels. Within wetlands, the vegetation community will be dominated by hydrophytes and the soil will feature hydric characteristics (National Wetlands Working Group 1988 and 1997, Beckingham and Archibald 1996, Beckingham, Corns and Archibald 1996, MacKenzie and Moran 2004). There are five wetland classes identified in the Project area. A description of the essential characteristics of the wetland classes are provided in the following sections Bog Wetland Wetlands classified as bogs are shrubby or treed, nutrient-poor peatlands with distinctive communities of ericaceous shrubs and hummock-forming Sphagnum species adapted to highly acid and oxygen-poor soil conditions. Bogs develop in basins where peat accumulation has raised the wetland surface above groundwater flow or where groundwater is very low in dissolved nutrients Fen Wetland Fens are peatlands where groundwater inflow maintains relatively high mineral content within the rooting zone. Non-ericaceous shrubs, sedges, grasses, reeds, and brown mosses are common. Fens develop in basins, lake margins, river floodplains, and seepage slopes. The water table is usually at or just below the peat surface for most of the growing season Marsh Wetland A marsh is a shallowly flooded mineral wetland. Typically, a marsh is dominated by emergent grass-like vegetation. A fluctuating water table is typical in marshes with the highest water table during the early growing season. Exposure of the substrate in late season or dry years is common. Nutrient availability is high due to near-neutral ph, water movement, and aeration of the substrate Swamp Wetland A swamp is a forested, treed, or tall-shrub, mineral wetland. A swamp wetland is dominated by trees and broadleaf shrubs on sites with a flowing or fluctuating, semi-permanent, near-surface water table. Tallshrub swamps are dense thickets, whereas forested swamps have large trees occurring on elevated microsites and lower cover of tall deciduous shrubs. Both types of swamps have abundant available nutrients from groundwater and often have surface standing water. Swamps may be underlain with peat, but it is well decomposed, woody, and dark. July 2012 Page 13