IR Response

IR #1 - Forest Pests
Good Afternoon David,

Staff require further information to assess NGTL's Project Update No. 1 and Variance Request:
 
  Reference:
  1. NGTL, 1 August 2023, Application, Attachment 14 – Interactions Table, Vegetation, PDF page 12 of 71, C25727-8
  2. NGTL, 26 October 2023, Environmental and Socio-Economic Assessment (ESA), Section 6 Assessment of Effects on Vegetation and Wetlands, Table 6.8, PDF page 181 of 318, C26936-2
  3. NGTL, 26 October 2023, Environmental Protection Plan (EPP), Table 1, PDF page 19 of 406, C26936-4
  4. NGTL, 29 February 2024, Project Update No. 1 and Request for Variance, Updated EPP, PDF page 5 and 24 of 232, C28569-1
     
  Preamble: In reference i) NGTL stated the following:

The Project Development Area (PDA) is located in the Inactive Holding Zone for mountain pine beetle (Alberta Agriculture and Forestry 2021a); mountain pine beetle boreholes and tree mortality were observed in the PDA during field surveys.

In reference ii) NGTL indicated there was a total of 13 mountain pine beetle sites observed within the Regional Assessment Area of the Valhalla North Section, with 11 being in the PDA.

In reference iii) NGTL committed to the following regarding mountain pine beetle:
 
  1. Through consultation with a professional forester, pine beetle presence will be confirmed, and appropriate mitigations developed.
  2. If timber infested with mountain pine beetle is encountered during clearing for the Project, consult with a professional forester and AAF prior to hauling.
  3. Non-merchantable timber infested with mountain pine beetle will be burned on site and will not be retained for rollback or firewood

In reference iv) the first commitment from reference iii) was removed and only the second and third commitment remain with no explanation.

The CER notes that no reason was given for dropping the first commitment included in reference iii) but omitted in reference iv), despite the presence of mountain pine beetle being noted in references i) and ii).
     
  Request: Provide either:
  1. the following with regard to mountain pine beetle:
    1. justification for removing the commitment from reference iii);
    2. an explanation of how mountain pine beetle presence will be confirmed; and
    3. an explanation of how similar levels of environmental protection and adherence to provincial requirements with regard to mountain pine beetle will still be achieved;
or
 
  1. an updated EPP with the commitment from reference iii) added back in.

Thank you,

Deborah Burgess
Regulatory Compliance Officer
403-389-2595

Theme/Sub-Theme for IR

Instruments / Conditions / Component

Filing Id Filing Title
C28569 C28569 NOVA Gas Transmission Ltd. - GPML Loop No. 4 (Valhalla North Section) and Berland River CS C3 Unit Addition - Project Update No. 1 and Variance Request
david_yee@tcenergy.com
Not specified
2024-03-22 00:00
2024-03-15 16:09
a)                 
1.  NGTL retained CCI Inc. for the timber assessment of the Valhalla North Section component of the Project. During the initial timber assessment in March 2020, the overall health of the trees was assessed by a professional forester from CCI Inc. No indication of mountain pine beetle infestation was noted. There were no areas observed with red attack or dead pine trees. The overall pine content along the ROW was noted as low. As a result, the risk of mountain pine beetle infestation was deemed to be low. In 2022 and 2023 Weyerhaeuser has harvested most of the remaining conifer stands that were within the proposed clearing footprint, further reducing the risk of mountain pine beetle infestation.
 
NGTL has removed the commitment (1) in reference iii), because it was included in the October 2023 EPP[1] in error, since this commitment was met during the timber assessment by CCI Inc. in 2020. NGTL is committed to evaluating the condition of the timber during clearing, and if timber infested with mountain pine beetle is encountered during clearing NGTL will consult a professional forester and AAF prior to hauling. Non-merchantable timber infested with mountain pine beetle will be burned on site and will not be retained for rollback or firewood.

2.  Mountain pine beetle presence (adults or larvae) will be determined by the Environmental Inspector (EI), or designate(s) by examining stressed or dead lodgepole pine trees during clearing activities using guidance available in Mountain pine beetle detection and management in Alberta (Government of Alberta 2020). Stressed or dead trees will be examined for signs of beetles including frass (sawdust) piles at tree bases, pitch-tubes (sap produced by the tree defending itself from attack), and reduced tree health (i.e., red needles, shedding bark). If signs of beetle attack are present, suspect trees will be examined to determine if mountain pine beetle egg galleries are present. Mountain pine beetles attack live trees and excavate an egg gallery in a vertical orientation under the bark along the length of the trunk. The EI or designate will inspect stressed or dead trees for the characteristic J-shaped hook at the bottom of the gallery – this feature is characteristic of mountain pine beetle who lay eggs on either side of the vertical gallery in egg niches (Government of Alberta 2020). Mountain pine beetle galleries can be distinguished from the galleries of other bark beetles (including lodgepole pine beetle, red turpentine beetle and engraver beetles) based on morphology; other beetle species construct galleries with a dissimilar morphology, including communal galleries, galleries without egg niches, or egg galleries in a branching x, y or star shaped orientation (Government of Alberta 2020). 

References:
Government of Alberta. 2020. Mountain pine beetle detection and management in Alberta. January 1, 2020. Agriculture and Forestry. 104pp. Available at: https://open.alberta.ca/publications/mountain-pine-beetle-detection-management-alberta-2020. Accessed March 2024.

3. Similar levels of environmental protection and adherence to provincial requirements with regard to mountain pine beetle will still be achieved through a commitment to examine and flag stressed and/or dead trees prior to clearing. These trees will be examined based on the methods outlined in response to question 2) above and will be subject to the remaining mitigations as outlined in the Project-specific EPP.
 
[1] Filing ID: C26936-4.
bernadette_cadden@tcenergy.com
2024-03-22 13:54

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