Coastal Gaslink Pipeline Project

Transcription

1 March 16, 2016 Robert Marcellin, Administrator Regional District of Kitimat-Stikine Lazelle Avenue Terrace, B.C. V8G 4E1 TransCanada Corporation Street S.W. Calgary, AB, Canada T2P 5H1 Tel: Fax: (403) Web: CGL4703-CGP-RDKS-PR-L TR-1804 Dear Mr. Marcellin, Thank you for taking the time to meet with members of the team on February 23, 2016 at the Regional District offices in Terrace. Gathering input from local governments is an essential part of our project planning. Please pass on best wishes to all members of RDKS staff who joined us at the meeting. As discussed, 's construction schedule is dependent on a Final Investment Decision {FID) by the joint venture partners of LNG Canada, who propose to construct a natural gas liquefaction and export facility at Kitimat. has been advised that the LNG Canada FID is now targeted for late The project team's plan is to begin construction after FID. The team is working to ensure that all necessary permits are in place to begin construction activities. No significant construction activities are anticipated before FID. 2016, therefore, is envisioned as a year of continued planning. We look forward to having further discussions with RDKS on the questions that are of interest to you. At our meeting, as in your letter of December 22, 2015, you expressed particular interest in the number and location of construction camps. Our proposed locations reflect the fact that Kitimat-Stikine presents challenging terrain and weather, making it advisable to locate the work force close to the right-of-way in order to maximize work time. With this principle in mind, the number and location of camps in RDKS is still under review. is working with qualified pipeline construction contractors who have been shortlisted as potential prime contractors to refine our plans for construction. We have noted that the Regional District would like to see the consolidation of construction camps as much as possible. You expressed concern that construction activity in the upper Kitimat River valley may interfere with access to recreation areas. As construction planners, we recognize the possibility for traffic conflicts between heavy trucks and smaller vehicles, and our Traffic Control Management Plan will include measures to minimize such conflicts. However, we also recognize that resource roads are public roads, and we will make efforts to anticipate recreational needs as well as communicating directly with recreation groups about our construction schedule. Page 1 of 6

2 In a separate meeting on the same day, members of our team discussed waste management plans with. RDKS representatives. This meeting was helpful in terms of informing us about the Regional District's plans and expectations, and your desire to arrange a waste management agreement with. For the record, I am providing detailed responses to your letter to Dave Kmet dated December 22, 2015, which you sent in response to a BC Oil & Gas Commission comment opportunity. Please let us know if you have further questions or comments on any oftnese subjects. We appreciate the interest shown in the by the RDKS. As discussed, we look forward to having an update meeting or call with staff toward the end of Q2. In the meantime, please feel free to contact on any matter through our Community Relations team at or coastalgaslink@transcanada.com Regards, Karen Etherington Director, Environment and Regulatory Permitting Page 2 of 6

3 TransCanada In business to deliver responses to Regional District of Kitimat-Stikine letter dated December 22, 2015, "Proposed Multi-Use Sites." RDKS Comment: Recommend that all tenure holders such as the BC Trappers Association, Guide Outfitters Association of BC and Steelhead Society of BC are given the opportunity to comment on the camp locations. response: By OGC regulation, all tenure holders directly affected by or adjacent to Coastal Gas link applications for camps, stockpiles, multi-use or other ancillary sites must be notified and provided with an opportunity to comment. This includes tenure holders who are members of the BC Trappers Association and the Guide Outfitters Association of British Columbia. In addition to this requirement for directly affected parties, has established contacts with the BC Trappers Association, the Guide Outfitters and the Steel head Society. Interested members of the public, recreation groups, and other stakeholders will be informed on camp, stockpile, multi-use and other ancillary site locations through future open houses and will have an opportunity to provide comments. RDKS Question 1: There are multiple industrial projects planned and taking place in our Regional District including other LNG pipelines. Have the cumulative impacts of multiple projects been addressed? For example, the PRGT and PTP pipeline projects will need similar sites to construct their projects. If there are opportunities to coordinate with other projects, such as reusing large cleared areas, it would lessen negative impacts. Coastal Gas link response: Coastal Gas link has completed a comprehensive assessment of the potential adverse effects of the Project, including the assessment of cumulative effects. Information is available online in the Coastal Gas link Application for an Environmental Assessment Certificate (EAC Application). We appreciate the participation of RDKS representative Ken Newman in the EAO's Working Group to review the Application. Included in our evaluation criteria for routing the pipeline and for selecting sites for ancillary facilities such as temporary storage sites, construction camps, and access is the use of previously disturbed lands. Coastal Gaslink seeks to engage with other project proponents and operators to share information and identify opportunities to work together. The corridor for the proposed Pacific Trail Pipeline runs close to the Coastal Gaslink corridor for some of its length. However, within the Kitimat-Stikine Regional District, the two projects are not in proximity to each other, which reduces the opportunity to utilize common sites. RDKS Question 2: How have the {facility] sites been selected? Were other regulators and stakeholders involved in the process? For example, the Department of Fisheries and Oceans, the Fish and Wildlife Branch of the Ministry of Forests, Lands, Natural Resource Operations or the Steel head Society would be helpful groups to consult with in order to determine the best and safest locations near fish bearing weather bodies. Page 3 of 6

4 response: included a detailed description of evaluation criteria in the EAC Application for the pipeline route (Section 1.4.4}, temporary workspace (Section }, compressor station and meter station sites (Section }, access roads (Section }. To develop potential routing and siting options, involves project team members from various disciplines including engineering, environment, land, construction, survey, and gathers information and input from Aboriginal groups and stakeholders such as landowners and land users. Throughout the project planning process, engages with federal, provincial and local government agencies. RDKS Question 3: What is the reasoning behind selecting two sites on the Kitimat River (P2 and loa)? Could these two sites be combined considering their relatively close proximity to each other? response: Proposed site P2 is not on the Kitimat River. It is located on the Clore River outside the Burnie Shea Protected Area, and is over 50 km from multi-use site loa. Site P2 supports construction crews working on the east side of Icy Pass. Proposed Site loa supports construction crews working on the west side of Icy Pass. Camp locations have been selected as per the evaluation criteria mentioned in the response to Question 2. As mentioned above, camp locations were selected to minimize travel time to work sites. Plans for proposed sites loa and P4 are under review. RDKS Question 4: There are environmental concerns with working near or on water bodies. River tributaries and wetland areas appear to be adjacent to and within the sites. response: Watercourse crossing locations and wetlands are important factors in the routing and siting process, the environmental assessment process, the permitting process, the construction process, post-construction monitoring, and pipeline operations and maintenance. tries to minimize the number of watercourse crossings that could be affected by the Project. Where a watercourse crossing is necessary, detailed planning seeks to select the most suitable and practical location, that is geotechnically stable and where construction will be feasible using more than one installation method. Section of the EAC Application provides further information about pipeline installation methods at watercourse crossings. 's Environmental Management Plan (Section 7, 8.4} and the Wetlands Management Plan as well as specific requirements set out in OGC permits provide direction on activities and mitigation at watercourse crossings and wetlands. In addition, the regulatory requirements for the Project include water quality monitoring and post-construction monitoring to ensure the mitigation is effective. RDKS Question 5: There is a concern with the sites' proximity to important fish bearing rivers (the Clore, Hirsch Creek and the Kitimat River). P2 falls within a short distance of the Clore River headwaters, a fish Page 4 of 6

5 ~ ~ Tn~~~~~~e?v~da bearing tributary of the Copper River (Zymoetz). Licenses or permitting may be required through the Department of Fisheries and Oceans or Environment Canada. response: has been engaging with DFO and Environment Canada as well as other relevant regulatory authorities since project planning commenced to ensure requirements are clear and our work is carried out in compliance with the applicable legislation. During our aquatics field program, appropriate permits were obtained from DFO and FLNRO. To construct the Project, authorizations under the Fisheries Act for specific watercourses may be required from DFO. Coastal Gas link will ensure it has all the required authorizations and permits to support construction. At this time, engagement with Environment Canada has not identified any requirements to pursue permits from Environment Canada. During the environmental assessment, potential adverse effects were identified for all project elements including temporary facilities such as storage sites or construction camps. The assessment also included mitigation to avoid or reduce these effects. Temporary facilities will be developed and operated in accordance with the requirements of our approvals and permits and all applicable legislation. RDKS Question 6: Have fishing or hunting policies for camp workers been established? No hunting or fishing policies should be adopted in order to ensure these resources are not adversely impacted. response: Condition #25 ofthe Environmental Assessment Certificate for the Project states "The Holder must develop and implement a No-Hunting, No-Trapping, No Fishing and No-Plant Gathering Policy for the Holder's employees and contractors during work hours. The Holder shall develop, implement and enforce a policy restricting employees from possessing or storing firearms, bows and crossbows in construction camps or in work vehicles, unless on the request ofthe Holder, EAO in consultation with MOE, determines that a designated wildlife monitor may carry a firearm for animal control safety purposes." cannot prevent workers from conducting legal activities on their days off, however, during working hours and while housed in Project construction camps, Project personnel will be prohibited from hunting or fishing on the work site. RDKS Question 7: Is the size of the sites necessary? Is the size typical for this type of project? response: Section of the EAC Application provides information about the components of the Project including approximate sizes. For example meter stations are about 3-4 ha, construction camps range in size from about 5 to 25 ha depending on the capacity required, stockpile sites are approximately 25, laydown areas to store equipment may be about 4 ha and borrow sites could be ha in size. The size of each type oftemporary footprint is based on the use, expected equipment and materials sizes as well as the safety of our workers. reduces its construction footprint to the extent Page 5 of 6

6 ~ ~ Tn~~~~~~.~.~da practical, ensuring adequate space for the safe operation of equipment and the safety of our workers, and in consideration of minimizing the potential for adverse environmental effects. RDKS Question 8: Is site P2 truly planned to have helicopter access only? The pipeline route is assumed to have road access. response: Site P2 is a multi-use site including camp that will be serviced by road, as is shown on the plan provided to the Regional District with our "Invite to Consult" package. In some areas along the route there currently is no road access, so temporary access for construction will need to be established. The callout stating 'Helicopter Access' shown on the 1:50,000 location map and Access Location map are to indicate that initially, the camp location may need to be accessed by helicopter, until road access.is established. RDKS Question 9: What is the reclamation plan for the sites? response: The objective of 's reclamation program is to maintain equivalent land capability. The Reclamation Program document presents information about the various options and techniques to reclaim disturbed areas, example locations for the techniques and proposed timing of reclamation work relative to the construction schedule. Prior to construction, detailed reclamation plans will be developed. These detailed plans will be updated through construction to reflect final site conditions in the areas disturbed by construction. RDKS Question 10: The Regional District Works and Services Department should be consulted to determine camp needs such as waste disposal (liquid and solid), water use, recycling, etc. As we understand a meeting is being scheduled to do so. Coastal Gas link response: Members of our team had a detailed discussion ~.ith RDKS representatives in Terrace on February 23, The meeting was helpful in terms of informing us about the Regional District's plans and expectations, and about the RD's desire to conclude a waste management agreement with. RDKS Question 11: Staff requests a map be sent electronically showing all planned Multi-use sites and proposed camp locations. response: sent our current construction planning maps electronically to RDKS works manager and planners on January 14 and 15, At our meeting on February 23, 2016, it was agreed that would provide these maps to RDKS staff as shape files via our Sharepoint site. Page 6 of 6