PAC-RIM LNG PROJECT

PAC-RIM LNG INC.

FINAL

PROJECT REPORT

SPECIFICATIONS

Prepared by the

PAC-RIM LNG Project Assessment Committee

under the Environmental Assessment Act, S.B.C. 1994

April 11, 1996

Environmental Assessment Office


TABLE OF CONTENTS


PART I - PREFACE

PURPOSE OF THE PROJECT REPORT SPECIFICATIONS
THE PROPOSED PAC-RIM LNG PROJECT
PAC-RIM LNG INC.'S ENVIRONMENTAL ASSESSMENT AND MANAGEMENT STRATEGY
Public Consultation
First Nations Consultation
PREVIOUS REVIEW HISTORY
THE ENVIRONMENTAL ASSESSMENT PROCESS
Overview
Application to PAC-RIM LNG Project
Canadian Environmental Assessment Act and Process xvi
Prince Rupert Port Corporation Process xvii
National Energy Board (NEB) xvii
Relationship to Land Use Planning Processes xviii
PAC-RIM LNG Project and Land Use Planning xviii
STATUS OF EA REVIEW OF PAC-RIM LNG PROJECT xix
Project Application xix
Project Committee xix
PAC-RIM Project Committee xix
Application Of CEAA To The PAC-RIM Review xx
First Nations Participation xx
Scope of the Review xxi
Upstream Environmental Impacts xxii
PROJECT REPORT REVIEW STAGE OF ENVIRONMENTAL ASSESSMENT PROCESS xxiv
Project Report xxiv
Draft Project Report Specifications xxv
Finalizing the Project Report Specifications xxv
Scope of Project Report Specifications xxvi
Screening of the Project Report xxvi
Project Report Review and Decision Making xxvii
Basis for Project Certification Decision xxvii
Public Hearing (optional) xxvii
Project Approval Certificate xxviii
Permits, Licenses and Other Approvals xxviii
Review of Future Proposals to Modify a Certified Project xxix

PART II - PROJECT REPORT SPECIFICATIONS

INTRODUCTION 1

1. Topics for Assessment in the Project Report

2. General Reporting Requirements for the Project Report

2.1 Project Description

2.2 Project Purpose/Rationale: Gas Supply

2.3 Mapping Scales

2.4 Comments on PAC-RIM's Environmental Management Strategy And Methodology

2.5 Complying with the Project Report Specifications

2.6 Land Use Considerations

2.7 Public Consultation

2.8 General Comments

2.9 Pipeline Route Selection

2.10 LNG Plant Site Selection

A. PIPELINE - Environmental, Resource Management And Technical Issues

A1 General
A2 Waste
A3 Water Quality
A3.1 Stream Crossing
A4 Fish and Wildlife
A4.1 General
A4.2 Fish
A4.3 Waterfowl and other Avifauna
A4.4 Wildlife Habitat
A4.5 Access
A4.6 Noise Impacts
A5 Air Impacts 31
A6 Recreation Issues 32
A7 Timber Resources 33
A8 Agricultural Resources 33

B. LNG FACILITIES, MARINE LOADOUT, TANKERS, AND UTILITY CORRIDORS - Environmental, Resource Management and Technical Issues

B1 Waste Management and Water Quality
B1.1 Water and Habitat Information
B1.2 Dredging
B1.3 Pollution from Tankers
B1.4 Coolant Water Discharges
B2 Fish
B3 Wildlife
B3.1 Waterfowl and Other Avifauna
B3.2 Noise Impacts
B4 Utility and Access Corridors
B5 Air

C. SOCIO-ECONOMIC AND COMMUNITY ISSUES

C1 Cost-Benefit
C2 Employment and Local Socio-Economic Benefits
C3 Infrastructure and Government Services
C4 Transportation and Access
C5 Accommodation Requirements
C6 Public Health and Safety
C7 Tourism

D. CULTURE AND HERITAGE

E FIRST NATIONS ISSUES

F. MALFUNCTIONS AND ACCIDENTS

F1 Pipeline and LNG Plant Facilities
F2 Marine Vessel Traffic Management

G. CUMULATIVE EFFECTS

H. OTHER CEAA REQUIREMENTS

H.1 Assessment Of Alternatives
H.2 Follow up and Environmental Monitoring
H. 3 Capacity of Renewable Resources

I. DISMANTLING AND ABANDONMENT

J. REQUIREMENTS TO SATISFY THE PRINCE RUPERT PORT CORPORATION'S ENVIRONMENTAL APPRAISAL DOCUMENT

APPENDICES

Appendix 1 Project Committee Response to Public Issues and Concerns

Appendix 2 Summary of Comments Made at PAC-RIM LNG Inc.'s Public Consultations

Appendix 3 Issues and Concerns Arising from Prospectus Review under the Energy Project Review Process

Appendix 4 Permits and Approvals

Appendix 5 Project Committee Membership

Appendix 6 First Nations Consultation


ACRONYMS USED IN THIS REPORT

ALR - Agricultural Land Reserve
CEAA - Canadian Environmental Assessment Act
CCG - Canadian Coast Guard
CORE - Committee On Resources and the Environment
CWS - Canadian Wildlife Service
DFO - Department of Fisheries and Oceans
DIAND - Department of Indian Affairs and Northern Development
EA Act - Environmental Assessment Act
EAO - Environmental Assessment Office
EMP - Environmental Management Plan
EPP - Environmental Protection Plan
EPRP - Energy Project Review Process
ER - Ecological Reserve
ERC - Energy Removal Certificate
LNG - Liquefied Natural Gas
LRMP - Land and Resources Management Plan
MAFF - Ministry of Agriculture, Fish and Food
MEI - Ministry of Employment and Investment
MELP - Ministry of Environment, Lands and Parks
MOF - Ministry of Forests
MOH - Ministry of Health
MOTH - Ministry of Transportation and Highways
MSS - Ministry of Social Services
NEB - National Energy Board
OCP - Official Community Plan
OWHC - Office of the Wet'suwet'en Hereditary Chiefs
PA - Protected Area
PAC-RIM - PAC-RIM LNG Inc.
PNG - Pacific Northern Gas
PRPC - Prince Rupert Port Corporation
ROW - Right-of-Way
SBTC - Ministry of Small Business, Tourism and Culture
TEM - Terrestrial Ecosystem Mapping
TERMPOL- Technical Review Process to Safeguard the Environment From Pollution and To Ensure the Safe Development and Operation of Marine Terminal Systems and Transportation Sites
VEC - Valued Environmental Component

PART I - PREFACE

PURPOSE OF THE PROJECT REPORT SPECIFICATIONS

PAC-RIM LNG Inc. has applied under the Environmental Assessment Act for a project approval certificate for its proposed Liquefied Natural Gas (LNG) facility. The Project Committee which has been set up to steer the assessment of this project has determined that PAC-RIM LNG Inc. must file a Project Report (or detailed impact assessment submission) in support of its application.

The purpose of the present document is to set out final Project Report Specifications (or terms of reference) for the Project Report. These final specifications have been prepared by the Project Committee on the basis of input received from the public, First Nations and federal, provincial and local government agencies, and comments made by the proponent during the review of the proponent's application and supporting documentation and the Draft Project Report Specifications.

This Preface describes the background to the current review of the LNG proposal. Pursuant to section 21 of the Act, Part II of this document sets out in final form the proposed specifications. These final specifications are accompanied by appendices, which are intended to itemize issues which have been raised by the public and government agencies during the review of the proponent's application documentation. Appendix 1 summarizes the Project Committee's response to each issue identified by the public.

The specifications have been finalized by the Project Committee, taking account of comments received on the draft version of the specifications, which was released for public review and comment.

THE PROPOSED PAC-RIM LNG PROJECT

PAC-RIM LNG. Inc. (PAC-RIM) has submitted a proposal to develop a liquefied natural gas (LNG) project which would purchase pipeline quality natural gas from sources in northeast British Columbia and Alberta and transport it via a dedicated pipeline system to a LNG processing plant on tidewater on the Pacific coast in the vicinity of either Bish Cove on I.R. #6 near Kitimat (507 km), or on Ridley Island near Prince Rupert (592 km). The coastal facility will include storage and processing facilities and a marine loading terminal.

PAC-RIM will construct and operate either a 24" (dedicated only to the PAC-RIM project) or a 30" diameter pipeline (if destined for domestic use as well) on an 18metre wide right-of-way. The proposed pipeline would commence at Summit Lake and would generally follow the existing Pacific Northern Gas (PNG) pipeline right-of-way (ROW). PAC-RIM expects pipeline construction to be completed within one year at a capital cost of approximately $575 to $725 million (depending on the route and pipe diameter selected).

In addition, the pipeline will require a number of compressor stations initiating at Summit Lake (number is dependent upon the final route selected and the pipe size): the Kitimat route would require 2 compressor stations for the 30" pipe and 3 for the 24" pipe; and the Prince Rupert route would require 3 compressor stations for the 30" pipe and 4 for the 24" pipe.

The proposed LNG facility has a design capacity of 14.2 x 106 m3/day (500 mmcfd--million cubic feet of gas per day or 3.5 million tonnes of LNG/year) and consists of:

Capital costs of the LNG plant facility are estimated to be approximately $850 million, and the plant is intended to be constructed over a three year period.

PAC-RIM LNG INC.'S ENVIRONMENTAL ASSESSMENT AND MANAGEMENT STRATEGY

In its application, PAC-RIM has presented three key components that it intends to employ to prepare and implement an environmental assessment management strategy for the life of the project:

· Environmental Management Plan (EMP) - the EMP will be a life-of-project document outlining how the environmental objectives for the project will be achieved. The framework for the EMP will result from consultations with both the review agencies and the public and will be developed during the Project Report preparation. The EMP will include statements of Environmental Management Priorities and Implementation Schedule, Environmental Management Strategy, Consultation Strategy, Description of the Existing Environment and Identification of Valued Environmental Components at Risk, Environmental Protection Planning, Vessel Traffic Management, Fisheries Liaison, Contingency and Emergency Response Planning, Environmental Effects Monitoring, Employees Environmental Education and Orientation, EMP auditing procedures and a list of key contacts and resource persons.

· Environmental Assessment Methodology - the methodology involves identifying Valued Environmental Components (VECs) based on issues identified through public and regulatory review. For each VEC, the existing environment is described, spatial and temporal boundaries established, and zones of influence and population boundaries are determined.

Impact assessment will involve the identification of project-VEC interactions and issues and concerns, evaluation of existing knowledge regarding these interactions and an evaluation of the significance of the potential impacts. The definition of impact significance will be provided for each VEC and potential impacts and cumulative effects will be considered. For each VEC the proposed mitigation and monitoring strategies will be presented and potential residual impacts described. Compensation strategies will be outlined as required. These will be documented in the Project Report.

· Public and Stakeholder Consultation - during all stages of the project.

Public Consultation

Under the EA process, project proponents are primarily responsible for public consultation. The adequacy of the proponent's public consultation activities and plans are reviewed by the Project Committee, and further measures can be required [to be conducted by either the EAO or the proponent].

During the application review period which ended on December 8, 1996, PAC-RIM LNG Inc. conducted an extensive consultation process with representatives of regulatory agencies, First Nations, industry, municipal governments and elected officials, Chambers of Commerce, individual businesses and business organizations, landowners, environmental groups, and other stakeholders and potentially interested members of the public:

At the conclusion of the public comment period on the project application, PAC-RIM LNG Inc. submitted a report entitled Summary Report on Public Consultation. The report summarized the issues identified through the public consultation process during the application review stage of the project application. Records of all discussions were attached as appendices to the summary report. The report and appendices are available for public review at the Environmental Assessment Office Project Registry and the satellite repositories.(1)

Since December 8, 1995, PAC-RIM LNG Inc. has responded by letter to all members of the public who submitted written comments to the Environmental Assessment Office on the PAC-RIM project application during the application review period. Copies of the letters and responses are filed on the Environmental Assessment Office Project Registry.

Since March 21, 1996, PAC-RIM LNG Inc. has sent letters to each member of the public who submitted written comments to the Environmental Assessment Office during the public review of the PAC-RIM Draft Project Report Specifications. Copies of the letters and responses are filed on the Environmental Assessment Office Project Registry

First Nations Consultation

PAC-RIM has committed to on-going consultation with all affected First Nations to identify Aboriginal rights, entitlements and interests, and to co-operatively address any concerns with respect to any infringement of these rights within project planning. PAC-RIM has contacted all potentially affected First Nations, and provided them with notification regarding the project, project information and information regarding the review of the project. A comprehensive summary of consultation to January 25th, 1996 is attached as Appendix 6.

PREVIOUS REVIEW HISTORY

PAC-RIM began preliminary consultation with regulatory agencies and key stakeholders in late 1994 in order to identify potential issues and concerns with respect to the project. In February 1995, PAC-RIM submitted a Prospectus under the Energy Project Review Process (EPRP) which was potentially a four stage process: Prospectus, Draft Energy Project Certificate Application, Energy Project Certificate Application, and possibly public hearings. It was understood at that time that this Process could be superseded by the process under the new Environmental Assessment Act (EA Act) when it was proclaimed, and that this could result in the need to submit an application under that Act.

The Prospectus was circulated for comments to key stakeholders, government agencies and First Nations on March 16, 1995 (see Appendix 3 for a summary of review comments). This review provided PAC-RIM with useful information and feedback for the scoping of issues. At that time it was noted by the Environmental Assessment Office (EAO) that the Prospectus did not meet the application requirements of the soon to be proclaimed EA Act.

Because the project had only completed the Prospectus level review, PAC-RIM was required to file an Application (equivalent to a Draft Energy Project Certificate Application) under the new EA Act once it was proclaimed on June 30, 1995. Therefore, a Transition Order placing the project at an appropriate stage within the EA process was not required.

THE ENVIRONMENTAL ASSESSMENT PROCESS

Overview

The Environmental Assessment Act received Third Reading and Royal Assent on July 8, 1994, and was proclaimed on June 30, 1995. Prior to formal proclamation of the Act, the Energy Project Review Process had been followed in reviewing the PAC-RIM LNG project, as noted above.

The intent of the new legislation is to create a comprehensive, timely and predictable, open, accountable, integrated and neutrally administered process for the assessment of the environmental, economic, social, cultural, heritage and health effects of a wide variety of major developments (industrial/ manufacturing, mining, energy, water management, waste disposal, food processing, transportation and tourism).

The legislation establishes a staged process through which the potential effects of projects are identified, and potential means of preventing or mitigating adverse effects are developed and considered. The process is intended to support provincial goals for sustainability by ensuring that projects are constructed in a manner which minimizes adverse effects to the extent possible, while contributing economic and social benefits over the long term.

The legislation provides for participation by interested parties. Reviews are administered by the Environmental Assessment Office (EAO), and steered by project committees comprised of government representatives (federal, provincial, local, First Nations and, where appropriate, neighboring jurisdictions).

Application to PAC-RIM LNG Project

The PAC-RIM proposal is being reviewed under the EA process because the pipeline capacity, storage facility, and processing plant all exceed the size thresholds set in the Reviewable Projects Regulation (enacted pursuant to section 3 of the Environmental Assessment Act) for automatic EA review: (1) pipeline and facility have the capacity to transport in one year an energy resource that can yield by combustion 16 PJ or more of energy; (2) the energy storage facility is capable of storing an energy resource in a quantity that can yield by combustion 3 PJ or more of energy; and, (3) the processing plant processes gas at the rate of 3 PJ or more/year. The PAC-RIM project is 183 PJ.

Canadian Environmental Assessment Act and Process

In British Columbia, it is possible for a development to be potentially reviewable under both federal and provincial EA processes, and both jurisdictions have enacted new legislation in 1995. The Canadian Environmental Assessment Act was proclaimed on January 19, 1995. Projects may be subject to the federal process if any one of four conditions (or "triggers") is satisfied: the project is proposed by a federal agency, or is located on federal land, or entails federal financial involvement, or requires regulatory action by a federal agency under any legislated provision listed in the Law List (a regulation enacted under the federal statute).

Faced with possible process duplication, the federal and provincial governments are currently negotiating a harmonization agreement, intended to eliminate as much potential procedural duplication as possible. The goal is to conclude an agreement which provides for individual projects to be subjected to a single review process, designed to meet both federal and provincial requirements. In the meantime, provisions in the provincial legislation ensure extensive involvement of interested federal departments in all reviews conducted under the provincial process. The Project Report Specifications contain the necessary elements so that the Project Report will satisfy the CEAA requirements for a Comprehensive Study should one be required.

Prince Rupert Port Corporation Process

One of the sites being considered by PAC-RIM is on Ridley Island at Prince Rupert. Environmental assessments of projects on Ridley Island are under the jurisdiction of the Prince Rupert Port Corporation (PRPC). The Canadian Environmental Assessment Act does not apply to Crown Corporations such as Port Authorities and, therefore, the PRPC has jurisdiction to conduct its own environmental assessment in the event that PAC-RIM chooses the Ridley Island site. The PRPC has indicated to the EAO that they would use the information gathered through the BC environmental assessment in making their decision so that studies would not have to be repeated. This is similar to the informal harmonization process with the federal government whereby the Project Report may be accepted as a CEAA Comprehensive Study. Similarly, if the Project Report meets the information requirements of the PRPC, it would be accepted as their Environmental Appraisal Document.

Since the Project Report will contain information to satisfy provincial, federal and PRPC requirements, any changes that may occur regarding the status of the PRPC as a result of discussions underway to privatize it (which could alter its authority to conduct environmental assessments), will not result in any delays or confusion because all the jurisdictions likely to assume any authority to conduct assessments are involved in this review.

National Energy Board (NEB)

The NEB has declined jurisdiction to approve the pipeline because, in its opinion, the pipeline does not fall within the definition of an inter-provincial pipeline under the National Energy Board Act as it is entirely within the province of B.C. However, PAC-RIM will be required to apply to the NEB for a long-term Export License, which would normally require a public hearing. Appendix 4, Permits and Approvals, describes the NEB requirements for an export license. PAC-RIM would be expected to provide information about the assessments that have been done under other jurisdictions when applying for the export license and the NEB would then decide if these assessments were adequate. If the application for an export license was submitted before the EA review was completed, the NEB would likely require that the results from an EA review be made available to the NEB prior to a decision by the NEB on whether or not to approve the export license application.

The NEB must take into account section 118 of the National Energy Board Act which requires the Board to satisfy itself that the quantity of gas to be exported does not exceed the surplus remaining after due allowance has been made for the reasonably foreseeable requirements for use of gas in Canada having due regard to the trends in the discovery of gas in Canada.

Relationship to Land Use Planning Processes

The EA process is strictly a project-specific review mechanism. It has not been designed as a land use planning mechanism, and has no jurisdiction to perform this function. The EA process will only assess projects within the context of the prevailing land use policy and planning framework of an area by evaluating the degree of compatibility of a development proposal with any specific land use planning objectives set in the vicinity of that development.

The EA process also examines the effects of projects on adjacent land uses, determining the degree to which adjacent pre-existing land uses may be affected.

The EA process, in reviewing projects, is not expected to await the outcome of planning processes which have yet to be completed. While British Columbia is moving as quickly as possible to complete land use plans across the province (e.g. through the recent CORE planning tables, the Protected Areas Strategy and the Land and Resource Management Planning [LRMP] Process), it may well take several more years before plans are completed for all areas. In the meantime, government recognizes that, in the absence of plans or where plans are incomplete, development decisions must continue to be taken, using the best available information and in the context of responsible stewardship and the prevailing land use regime.

Review mechanisms such as the EA process and the Forest Practices Code will be employed to review proposed developments, taking account of the environmental and socio-economic implications of such development with respect to existing land use commitments. Where planning is underway, project committees set up under the EA process will take account of any plans or planning objectives which are newly affirmed, prior to these project committees having to make recommendations to Ministers on whether or not particular projects should be granted project approval certificates.

PAC-RIM LNG Project and Land Use Planning

The pipeline component of the PAC-RIM LNG project crosses through several areas in which Land and Resource Management Plans are being formulated (South Kalum, Bulkley, Lakes, Vanderhoof, and Prince George). It potentially passes through areas where Protected Areas are established or are being considered (Williams Creek Ecological Reserve, Gitnadoix Recreation Area, Skeena River Ecological Reserve, Exchamsiks Provincial Park, Old Man Lake/China Nose proposed protected area, Salvus area) and where there are approved development plans in place (e.g. Ayton Creek). Where Protected Areas have been established, and no provision was made in their creation allowing for revision of the PNG right-of-way, then the PAC-RIM pipeline would not be allowed to pass through the area.

STATUS OF EA REVIEW OF PAC-RIM LNG PROJECT

Project Application

Following the proclamation of the Environmental Assessment Act on June 30, 1995, PAC-RIM submitted an application for a project approval certificate under the new legislation on August 15, 1995. This application was rejected by the EAO because it did not meet the requirements of s. 7 (2) of the EA Act and was resubmitted on September 15, 1995 and accepted for review.

Project Committee

Under the Act, project committees are the primary source of policy and technical expertise for the review of each project, and are expected to:

Working with the EA Office, project committees have overall responsibility for ensuring that project reviews: are comprehensive and technically sound; involve all of the potentially interested parties; and are conducted in a timely and efficient manner in accordance with the legislated time limits established for individual review steps.

PAC-RIM Project Committee

Following receipt of the proponent's original application, the EA Office took steps to establish a project committee to steer the review of the proposal. The Project Committee, consisting of federal, provincial and local government agencies and First Nations held a preliminary meeting prior to the submission and acceptance of the application in Prince George on September 8, 1995. Subsequent meetings were held in Smithers (November 30, 1995) and Terrace (January 18-19, 1996). The Project Committee membership is listed in Appendix 5.

Application Of CEAA To The PAC-RIM Review

The federal government has not yet made a formal determination of whether or not the federal EA process is applicable to the PAC-RIM LNG project and may not do so until a Project Report is submitted. Pending such a determination, individual federal departments are pursuing their interests and concerns through their direct participation in the work of the Project Committee.

If the Canadian Environmental Assessment Act (CEAA) is triggered, federal agencies with decision-making responsibilities relating to the project that will trigger CEAA, will have to ensure that the requirements of the federal Act are satisfied. This will entail, among other things, ensuring that a report is prepared that meets the requirements of a Comprehensive Study Report. Such a report would have to address a number of factors including cumulative impacts, effects of accidents and malfunctions, the significance of identified effects, the purpose of the project, alternative means of carrying out the project and the need for, and requirements of, a follow-up program.

CEAA will likely be triggered if the location at Bish Cove (Kitamaat Village Indian Band) near Kitimat is chosen because it will involve leases to take up Indian reserve land. In this case, DIAND would likely be the lead federal agency. However, if the Prince Rupert site is chosen there may not be any federal decision-making powers that would require the application of CEAA.

As far as the pipeline is concerned, there may not be any federal CEAA triggers if stream and river crossings are designed so as to not have any impacts on fish habitat. If there are any impacts to fish habitat at stream crossings of the pipeline for which habitat compensation is required, there would be a CEAA trigger under s. 35(2) of the Fisheries Act with the Department of Fisheries and Oceans (DFO) being the CEAA responsible authority (RA). Even if there were such impacts, the RA could limit the scope to those crossings where the impacts are. Other potential federal CEAA triggers include the Navigable Waters Protection Act (by the Coast Guard) and the Indian Act (by DIAND), where the pipeline crosses Indian Reserves and such crossings require approvals by that department.

First Nations Participation

The Act requires that any First Nation whose traditional territory includes the site of the project or is in the vicinity of the project, be invited to sit on the project committee. In the case of the review of the PAC-RIM LNG proposal, the pipeline route crosses through the traditional territories of several First Nations and, one of the two plant locations is actually located on reserve lands of the Kitamaat Village Council (Haisla). All potentially affected First Nations have been invited to sit on the Project Committee (see Appendix 5 for a complete listing of all First Nations invited) and so far, representatives from the following First Nations have attended one or more Project Committee meetings: the Office of Wet'suwet'en Hereditary Chiefs (OWHC), the Kitamaat Village Council (Haisla), Stellat'en, Sai'kuz (Stoney Creek Indian Band), Allied Tsimshian Tribes, Tsimshian Tribal Council, Metlakatla Indian Band, Lax Kw'alaams Indian Band, Kitsumkalum Indian Band and the Lhiet-Lit'en Nation.

Additionally, the Kitsumkalum, OWHC, the Haisla have submitted comments on the proponent's application documentation and the Kitselas Indian Band submitted a letter of interest in the review. PAC-RIM has begun consultations with all the affected First Nations.

Scope of the Review

The Project being reviewed includes the following three components: a dedicated sales gas pipeline from Summit Lake to the west coast; a LNG plant and storage facilities at either Kitimat or Prince Rupert; a marine loading facility for LNG shipment on special LNG tankers (including environmental pollution, and aspects of the tanker operations relating to traffic management).

The scope of the PAC-RIM LNG project review does not include review of potential environmental impacts of upstream natural gas infrastructure (upstream from the pipeline where it connects to the Westcoast pipeline at Summit Lake) resulting from obtaining (new wells), processing (gas plants) and transmitting (pipelines) this gas (i.e. impact on existing pipelines running through Pine Pass; increased compressor station capabilities; steps needed to be taken by Westcoast Energy Inc. to transport an additional 500 million cubic feet of natural gas per day from Northeast B.C. to Summit Lake).

There are several reasons why this decision has been taken:

Upstream Environmental Impacts

While not included within the scope of the EAO review of the PAC-RIM application, the upstream environmental impacts of gas exploration and development are reviewed by MEI and other agencies through multi-agency referral processes. Additionally, projects may be assessed under the Environmental Assessment Act if they are included in the Reviewable Projects Regulation.

The Ministry of Environment, Lands and Parks (MELP), while recognizing that the supply system which collects the gas from the gas producers and any associated pipeline development which crosses the mountains to Summit Lake, are not part of this review, wishes to emphasize the need for those aspects to be subject to an environmental assessment.

The Ministry of Employment and Investment (MEI) reviews the environmental effects of upstream activities and facilities through the following multi-agency referral processes:

Auhorizations Required:
Provincial

Ministry of Environment, Lands and Parks;

Regional Operations

Water Management Branch

Environmental Protection Division

BC Lands

Environmental Assessment Branch

Agricultural Land Commission

Agricultural Land Commission

Ministry of Municipal Affairs: Office of the Fire Commissioner

Ministry of Small Business, Tourism and Culture Archaeology Branch

Ministry of Forests

Ministry of Health

Fisheries Act

Water Act

Waste Management Act

Land Act

Environment Management Act

Soil Conservation Act

Agricultural Land Commission Act

Fire Services Act

Heritage Conservation Act

Forests Act

Industrial Health Camp Regulations

Food Premise Regulation

Safe Drinking Water Regulation

Sewage Disposal Regulation

Approval for activities that impact fish and fish habitat.

Approval of alterations and work in and about a stream (Section 7) and for short term use of water (Section 7).

Permit the discharge or emission of effluent waste or contaminants into air, land or water. Restrictions regarding solid and toxic wastes.

Regulation of the sale, lease and license of occupation, rights-of-way, special use permits, easements, map reserves and permission to construct on crown lands.

Requirements for impact assessment and environmental protection as ordered

Permit for the removal of soil from an ALR. Regulations to prevent/control soil erosion.

Approval to use land in the ALR for other than farm use.

Approval for more than 22.5 liters of fuel storage on site and on site fuel dispensing.

Approval to excavate or alter sites of archaeological or historical significance.

Approval for activities involving timber cutting, slash disposal, etc.

Approvals involving the construction camps.

Federal

Department of Fisheries and Oceans

Canadian Coast Guard

Department of Energy, Mines and Resources: Explosives Branch

Canadian Environmental Assessment Agency

Environment Canada:

Environment Protection

Canadian Wildlife Service

Fisheries Act

Navigable Waters Protection Act

Explosives Act

Canadian Environmental Assessment Act

Environment Protection Act

Canadian Wildlife Act

Migratory Bird Conventions

Approval for activities that impact fish and fish habitat including discharges of deleterious substances. Requirements for the provision of fishways, canals, fishscreens or guards and the flow of water.

Permit for activities in, around, under and over navigable waters for commerce, transportation or recreation.

Use and transport of explosives.

Requirement for environmental assessments (screening, comprehensive study) for federal projects and projects requiring approvals under federal acts.

Environment and human health, toxic substances, water/air quality standards.

Permission for activities affecting wildlife and wildlife habitat in wildlife and wildlife areas.

Approval for activities affecting migratory birds and their habitat.

Regional/Municipal

Regional/Municipal Governments

Municipal Act

Regional and Municipal By-Laws

Permits for construction. Approval of zoning or re-zoning. Regulation of set backs, development densities (FSR), local land use and building codes. Permits for clearing and burning.

PROJECT REPORT REVIEW STAGE OF ENVIRONMENTAL ASSESSMENT PROCESS

Project Report

The project report is the primary detailed impact assessment submission required from a proponent under the EA process, and is prepared by the proponent at the second review stage, following review of an initial application for a project approval certificate at the first review stage. Under the legislation, the application review stage is designed to identify issues, and thereby to establish the scope of the detailed review. The project report review stage is intended to determine whether or not identified issues are resolvable. The proponent's project report is expected to contain an assessment of issues identified, and proposed mitigation strategies, and forms the basis for this determination. A proponent will be notified that the project committee requires a project report where, in the committee's opinion, further issues need to be addressed in more depth.

At its first (November 30, 1995) meeting, the PAC-RIM Project Committee concluded that the review of the PAC-RIM application was likely to reveal various unresolved issues with respect to the potential effects of the proposed development, and that consequently, a second stage of the EA process (the project report review stage) would be required before the Project Committee would be in a position to make recommendations to the Minister of Employment and Investment and the Minister of Energy, Mines and Petroleum Resources about whether or not the project should be certified.

Thus, as noted at the beginning of this Preface, the purpose of Part II of this document is to set out in final form the proposed specifications for the Project Report.

Draft Project Report Specifications

When a project report is required, the project committee first prepares specifications for the project report in draft form, taking account of review comments received on the initial application from the public, First Nations and federal, provincial and local government agencies, as well as any responses to comments made by the proponent as per section 18 (b) of the Act.

In this case, the draft specifications were assembled on the basis of feedback received on the PAC-RIM application during a public comment period which ran from October 10, 1995 to December 8, 1995.

Finalizing the Project Report Specifications

Under the legislation's Prescribed Time Limits Regulation, the intent is that the Draft Project Report specifications are made public and placed on the project registry for a period of up to 30 days, during which the public may comment on them.

Following expiry of the public comment period, the project committee finalizes the project report specifications, taking account of public, agency and proponent comments, and provides them to the proponent as the framework for preparation of the project report. The project committee established the public review period at the full 30 days which concluded on March 21, 1996.

Scope of Project Report Specifications

The scope of project assessments conducted under the Environmental Assessment Act is potentially very broad. Section 1 of the legislation explicitly defines "effects" of projects to include "...environmental, economic, social, cultural, heritage and health effects...".

In view of this, the project committee, in drafting the project report specifications, exercises judgment about which issues require further reporting by the proponent in the project report. As part of the process of finalizing the project report specifications, the project committee considers all of the representations received on both the proponent's application and the draft project report specifications.

In deciding on which issues are to be addressed at the project report stage of review, the project committee is also guided by certain policy principles:

A broad range of issues have been raised by the public and government agencies with respect to the proposed PAC-RIM development. The reader is referred to Appendix 1 for a response from the Project Committee on each issue, indicating whether or not the issue is being pursued at the project report review stage (with reasons stated in cases where the issue is not being considered further). This serves to demonstrate that issues raised by the public have been recognized and considered by the Project Committee, and also provides the rationale for the proposed handling of individual issues.

Screening of the Project Report

A project report, when submitted by a proponent, is screened briefly by the project committee to ensure that it generally addresses the topics incorporated into the specifications, before being accepted for formal detailed review. However, screening is not an in-depth review of the technical content of the submission, and its acceptance for formal detailed review in no way implies acceptance of the project.

Proponents must comply with the project report specifications to the fullest possible extent. If the project report, when screened, is deemed to be incomplete, it will not be accepted for review, but instead will be returned to the proponent so that the deficiencies can be rectified.

Project Report Review and Decision Making

Once accepted for formal detailed review, the project report is circulated for public review and comment for a period of up to 60 days. Input received on the project report from the public, First Nations, local, provincial and federal government agencies, and the proponent is taken into account by the project committee in concluding its review of the proponent's application.

Review of the project report forms the primary basis for recommendations which the project committee must make to the Minister of Environment, Lands and Parks and the Responsible Minister (in this case, the Minister of Employment and Investment) on whether the project should be certified (with conditions), or rejected, or subjected to a public hearing held by the Environmental Assessment Board (EA Board). The project committee recommendations are advisory, and are not binding on the two Ministers.

On receipt of the project committee's report and recommendations, the Minister of Environment, Lands and Parks and the Responsible Minister decide whether a project should be certified, denied a certificate, or referred to the EA Board for a public hearing.

Basis for Project Certification Decision

The policy intent of government is that project certification will normally be recommended by the project committee where all policy-type issues have been resolved, and all technical issues have been addressed in sufficient depth to satisfy the project committee that they can be managed effectively by proven and affordable means. Where certain issues remain unresolved or where, for whatever reason, the project committee cannot agree on a recommendation, it may instead decide to present, for the consideration of Ministers, various possible decision options, together with an analysis of their pros and cons. In making a decision, Ministers will consider the potential benefits of the project, as well as the potential adverse effects.

Public Hearing (optional)

If the two Ministers opt for a public hearing, they then develop draft terms of reference for the hearing, focusing the hearing process on what they consider to be the key outstanding issues. They may also incorporate a reporting schedule for the hearing process into the terms of reference. The draft hearing terms of reference are circulated for public review/comment for up to 60 days, after which the Ministers finalize them and forward them to the EA Board.

The EA Board is responsible for conducting a public hearing. At the conclusion of the hearing, it prepares a report and recommendations which it then submits to full Cabinet. The Board's recommendations are advisory, and Cabinet must decide either to issue the project approval certificate (with conditions) or to deny the proponent a certificate.

Project Approval Certificate

A project approval certificate, if issued, would authorize the project to proceed subject to any development restrictions or conditions which may be imposed by Ministers or by Cabinet, usually on the advice of the project committee or the EA Board respectively.

The intent of government is that a project approval certificate would not incorporate approval of project components which have not been addressed in adequate detail in the project description presented in the project report, or which are identified only notionally, since without information on the nature, location and extent of the project component, it is not possible to conduct a site-specific impact assessment. Where such project components are critical to the overall development (i.e. where the overall development could not proceed without the coordinated and linked development of such components), inadequate reporting could result in overall decision making delays.

Project approval certificates are normally issued for the life of the development of the project, and have the flexibility to accommodate the staging and the scheduling envisaged for the development. However, a certificate does not remain in good standing indefinitely, if development does not immediately proceed. The Act provides that a certificate expires if the development has not been substantially started within three to five years of certificate issuance (the exact term is indicated in the certificate). The Act contains some time extension provisions in such circumstances, on application by the proponent.

Permits, Licenses and Other Approvals

Typically, when and if a project approval certificate is issued, the proponent will still have to file detailed applications for the various licenses, permits and other forms of approval which are necessary to construct and operate the project. Applications for permits may be filed at any time before or after the certificate is issued, but processing of permit applications and issuance of permits cannot be completed until after the project approval certificate has first been issued.

If a proponent avails itself of the provisions of the Act which allow the proponent to apply concurrently for permits at either the project report review or public hearing stages of the EA process, the intent would be that adjudication of permit applications would be completed, and decisions rendered, within 30 days of the issuance of a project approval certificate. Requests for concurrent permits at the Project Report review stage must be made prior to submitting the Project Report.

Review of Future Proposals to Modify a Certified Project

Once a project approval certificate and other necessary permits to construct and operate a project have been issued, the proponent will be expected to develop the project in accordance with these regulatory approvals, unless modifications to the project have been lawfully approved.

If the proponent wishes to modify the approved project layout or design, or the approved manner in which it is to be constructed or operated, or wishes to expand the project by adding new components, the proponent must apply for approval to do so from the appropriate regulatory authority(ies).

The review mechanism used to evaluate such applications will vary, depending on the nature of the modification or expansion for which approval is sought. In principle, three situations could arise:

PART II - PROJECT REPORT SPECIFICATIONS

INTRODUCTION

The Project Report Specifications contain the additional information requirements (additional to what is planned in the Application) recommended by the Project Committee, to be included by PAc-RIM in the Project Report. These requirements are clearly indicated in the shaded boxes.

In addition to the information requirements, this report includes comments and advice from reviewing agencies and the Project Committee, as well as their responses to public comments (Appendix 1), which, while not part of the information required in the Project Report, may provide useful additional insights into government's perspective and reporting expectations with respect to some of the issues which need to be addressed in the Project Report. These are intended to assist PAC-RIM LNG Inc. in developing the Project Report. In addition, this report clearly indicates which agency has made an information request so that PAC-RIM LNG Inc. can know who to contact in order to clarify any requirements.

1. Topics for Assessment in the Project Report

In these project report specifications, reporting requirements are identified with respect to the following general topics:

2. General Reporting Requirements for the Project Report

2.1 Project Description:

Input of the Project Committee

PAC-RIM must present a firm development plan, supported by objective scientific and technical information on those issues which are considered outstanding, as documented in these project report specifications.

The project description presented in the project report will be deemed to be the final form of the project proposal for which a project approval certificate is being sought. Any uncertainties about the exact composition of the development proposal must be clarified. Any changes to the proposed development, as it has been understood and reviewed to date under the EA process, must be clearly explained.

Information describing each project component is required in the project report, presented in sufficient detail to make possible a determination of whether or not individual development components, built to the proposed design parameters, are technically feasible, and to permit an adequate site suitability assessment and effects analysis to be performed, both for individual project components, and for the overall development. This stipulation does not mean, however, that the proponent is expected to provide final layout plans or final engineering designs or final technical specifications in the project report for each individual project component. This level of detail is seldom necessary to complete the impact assessments required to support an informed certification decision by government. The only exceptions would be those rare instances where final layout and design details are necessary to resolve uncertainties about the acceptability of a specific project design component, feature or mitigation measure. Such instances would be explicitly identified in the project report specifications.

General Project Report Reporting Requirements

· At the project report stage, the sites (or site options) for individual project components for which a project approval certificate is sought must be located with precision, both within the primary development area and off-site (in the case on any off-site infrastructure components), so that impact assessments on individual project components can be conducted in a detailed site-specific manner, taking account of local conditions.

It is understood that the proponent, having not selected a site for the LNG plant, will be required to report on both site options. However, if a decision on the LNG plant site is made before the project report is finalized, PAC-RIM will only be expected to submit a project report containing information on the selected site and will not be expected to provide the detailed comparative data related to the two plant site options outlined in these specifications.

· The project report should provide sufficient information on all the reasons (environmental, economic, social, cultural and heritage, etc.) why the final site was selected (also see section H.1 below).

Input of the Canadian Environmental Assessment Agency

Information Required in Project Report

· The Project Report should clearly identify the scope of the project under review. CEAA section 15(3) requires the assessment to consider the environmental effects of all project activities associated with the construction, operation, decommissioning or abandonment of the project.

If there is a CEAA trigger, a Responsible Authority (RA) will be identified who will determine the scope of factors to be addressed as per section 16 of CEAA.

2.2 Project Purpose/Rationale: Gas Supply

The question of the adequacy of the Province's gas supply to meet both the PAC-RIM requirements and the long-term needs of residents of the Province has been raised by several commenters. This issue will be addressed by the proponent in its applications to the National Energy Board for an Export License, and to MEI for a Energy Removal Certificate and assessed in those agencies' processes.

Input of the Ministry of Employment and Investment (MEI)

MEI, when considering energy removal applications, prepares a detailed reserves evaluation report on the gas dedicated to the removal. This report assesses the applicant's ability to meet is proposed contractual commitments. Depending on the results of the review and other policy considerations, the Minister may issue an Energy Removal Certificate (with or without conditions), refuse the application, or refer the application to the BC Utilities Commission for a hearing.

Adequacy of B.C.'s gas reserves (established marketable gas reserves and undiscovered potential marketable gas reserves): MEI notes that:

  1. PAC-RIM requires 97 billion cubic metres of natural gas over the life of the project.
  2. The known (proven by drilling) marketable gas reserves in BC and Alberta total 1,824 billion cubic metres.
  3. The potential (undiscovered estimated) marketable gas reserves in B.C. and Alberta total 3,067 billion cubic metres (BC's total marketable natural gas reserves are estimated at between 45 and 60 Tcf).
  4. Canadian natural gas exports in 1995 were 70 billion cubic metres.
  5. Alberta and B.C. natural gas production in 1995 was 130 billion cubic metres.
  6. PAC-RIM requirements are 5 billion cubic metres/year, or 3.8 percent of production in 1995.

Information Required of PAC-RIM by MEI in the ERC Application:

Information Required by NEB in Export License Application:

MEI must be satisfied that the proposed pipeline is of an appropriate diameter. PAC-RIM is proposing to install either a 24 inch pipeline, which would have the capacity to transport the 14.1 106m3/d (500 mmcfd) of gas required by the proposed LNG plant, or a 30 inch pipeline which could accommodate increased volumes as required to meet long-term demand growth in the region.

Information Required in the Project Report

· MEI wishes to know the proposed design capacity of the 30 inch pipeline option. MEI also wishes to obtain more information about the potential markets that PAC-RIM anticipates within British Columbia for the excess volumes, including the timing of those markets (MEI).

Input of the Ministry of Environment, Lands and Parks (MELP)

While it is acknowledged that upstream (source of natural gas, connecting and processing facilities, and transmission lines) environmental impacts are not part of the review of the PAC-RIM LNG proposal and are subject to separate environmental assessments, MELP is concerned about the potential for significant environmental impacts if the sourcing of the gas to supply PAC-RIM requires new processing or pipeline development (or significant upgrading).

Information Required to Accompany the Project Report

· PAC-RIM is requested to provide the Project Committee, for information purposes only, with copies of its applications to the NEB for an Export License and MEI for an Energy Removal Certificate. If one or both of these applications are not completed at the time of the submission of the Project Report, PAC-RIM is instead to provide information: relating to the adequacy of BC's and Canada's gas supply to meet PAC-RIM's requirements; and, secondly information on upstream transportation arrangements including transportation contracts and the term and contracted capacity of the transportation arrangements (MELP). With respect to supply and markets, verification is required that the required supply of gas has been secured and that a firm market exists (also required as part of PAC-RIM's application to MEI for an Energy Removal Certificate).

2.3 Mapping Scales

For preparation of the project report, no one standard mapping scale will meet all needs, but, based on experience with existing formal EA processes in British Columbia over the last 20 years, supporting mapping of the project development site, off-site development areas and surrounding areas in the zone of potential impact typically ranges in scale between 1:20,000 and 1:5,000, depending on such factors as the size of the project, or the type of landscape feature or impact issue or project component being mapped.

If and when a project approval certificate is issued, final engineering designs will then be required for the various permit applications which must be filed by the proponent in order to obtain the necessary authorizations to construct and operate the certified project. Often, the scale of mapping necessary to support permit applications is significantly greater than 1:5,000 (e.g. 1:1,000 or 1:500 or 1:200).

If PAC-RIM avails itself of the provisions of the Act which allow a proponent to apply for permits at either the project report review or public hearing stages of the EA process, final engineering design detail may then be required concurrently with the EA review in order to support the permit applications.

Input of the Ministry of Transportation and Highways (MOTH)
Input of the Ministry of Environment, Lands and Parks (MELP)
Information Required in Project Report

· PAC-RIM LNG Inc. to plot the project development site (LNG plant and linear pipeline corridor), off-site development areas and surrounding areas in the zone of potential impact on no higher scale basis than 1:20,000 mapping (unless otherwise indicated in these Specifications) and indicate the existing PNG pipeline, the required additional width of the right-of-way clearing directly attached to the existing PNG pipeline, and any portions of the ROW not directly attached to the existing PNG pipeline.

2.4 Comments on PAC-RIM's Environmental Management Strategy And Methodology

GENERAL
Input of the Ministry of Environment, Lands and Parks (MELP)

The proponent has presented a framework in the Application that is useful for issue scoping and for preliminary identification and evaluation of impacts. The structured approach that PAC-RIM has set out is a good one for this stage in the review. The elements in the proposed Environmental Management Plan and the Environmental Effects Monitoring will address many of the concerns with the project. The Ministry will want to review drafts of these components as early as possible in the review to provide input to their development and use. The ministry has questions with the timing of implementation of these components and the relationship with permitting and other regulatory aspects. In addition, the collection and incorporation of baseline data in project planning is critical.

Input of Environment Canada

Given the level of detail required for a federal CEAA comprehensive study report, the factual information with respect to environmental impacts of this project that will form the basis of the EMP, should all be contained in the Project Report.

With respect to pipeline issues, the Project Report should focus on areas where changes to the landscape will occur. That is, assessment of impacts should include areas where the proposed ROW would depart significantly from the PNG ROW and at the compressor stations. With respect to the plant and the marine loading facility sites, the assessment should be quantitative according to the requirements indicated by Environment Canada in section B. The relative impacts of project alternatives on wildlife, including the relative impacts of pipeline alignments should be included in the Project Report.

In general, the Project Report should contain: a description of the migratory bird resource for all aspects of the project (species presence, relative abundance and habitat use); a description of existing habitat in the environs of all project components and relating quantified habitat impacts on migratory bird species using the habitat; quantified predictions of impacts on migratory birds; and use of indicator species for a follow up program.

Input of the District of Kitimat

The level of detail and the quality of preliminary environmental assessment provided by the proponent within the application is impressive and the methodology comprehensive. The Environmental Management Plan which extends through the life of the project demonstrates excellent corporate commitment to environmentally responsible development and operations. We envision the principal elements of the plan - those of Environmental Protection Plans (implemented for all construction, operational phases and life cycle of the project) and the Environmental Effects Monitoring program (featuring scientific studies conducted to avoid conflict with valued environmental components) are by their very virtue - extensive, comprehensive and directed toward mitigation based on science and technology application to preserve environments.

SIGNIFICANCE CRITERIA
Input of the Canadian Environmental Assessment Agency

Information Required in Project Report

· Should CEAA be triggered then, section 16 (1) requires the consideration of the environmental effects of a project and their significance.

Input of the Ministry of Environment, Lands and Parks (MELP)

The company has conducted a "preliminary" environmental assessment to determine whether impacts are considered significant. It is stated that the assessment at this stage is not intended to be detailed but rather a comprehensive overview of potential project-VEC interactions, proposed mitigation strategies and a statement of potential impact of the project. Recognizing the preliminary nature of this assessment, the ministry has concerns with the significance criteria developed for most of the VECs and the conclusions derived regarding significance. For example, for some sites, changes to a population "in a localized area over a short period of time in a manner similar to natural variation" may be significant and not as the report concludes, insignificant. Whether or not a change of this magnitude is significant or not significant depends on the characteristics and history of the population affected and should not be generalized. Similarly, the statement on page 124 that the loss of important winter wildlife habitat for moose and deer populations along the route will be negligible needs to be supported with biophysical habitat information for the area. Data on the predicted localized impacts and the population must be presented in the Project Report to permit a decision on level of significance.

Input of Environment Canada

Environment Canada has noted the proponent's statement that the potential impact of the project on water quality and air quality is rated insignificant. Our Science Division has indicated that an in-depth review would be required before they could assess the validity of these statements, or identify any further issues and information requirements. For example, all effluent discharges such as process waters or storm waters need to be characterized, environmental effects described and mitigative measures proposed.

Input of the Ministry of Social Services (MSS)

A number of "insignificant impact" classifications include parameters such as the condition to return to "pre-project levels or patterns within the operating life of the facility" (20 years). These include "Quality of Life" p. 140, and "Health" p. 153 for the pipeline component and "Quality of Life" p. 170, and "Health" p. 187 for the LNG plant. The potential for twenty years of high impact is unacceptable from a community/health perspective. The proponent should review and redefine these parameters to trigger the need for mitigation during the life of the project.

Input of Health and Welfare Canada

Health Canada accepts the World Health Organization's definition of health (health is a complete state of physical, mental and social well being and not merely the absence of disease or infirmity; that health is the extent to which an individual or group is able on the one hand to realize aspirations and satisfy needs, and on the other hand to change or cope with the environment). The proposed criteria do not conform to this definition and are not acceptable.

Input of the District of Kitimat

Kitimat is comfortable with the term "insignificant" used by the proponent and understands this to mean that technology, science, methodology exists to reduce to acceptable levels - a framework for scientific analysis and this forms the basis of the proposed environmental methodology, planning and commitment of the project proponent.

Input of the Office of the Wet'suwet'en Hereditary Chiefs (OWHC)

OWHC does not agree with the definitions of "significance" and "insignificance" used by PAC-RIM as the intrinsic values of the Wet'suwet'en are the connections to the land. No areas within territories are deemed less valuable (significant) than another.

Input of the Ministry of Health (MOH)

The proponent has defined one of the significant impacts as "affects the human health and safety of the community in sufficient magnitude to cause a change in the physical well-being or in long-established activity patterns of the community

that would not return to pre-project levels or patterns within the operating life of the facility" (page 187). This definition, and other similar ones, are not acceptable to MOH. After extensive consultation with the proponent and members of the Project Committee, MOH requires two changes: firstly, the terms 'significant' and 'insignificant' are potentially misleading and the proponent must use complementary terms such as 'significant' and 'not significant' for logical clarity, and second, MOH will work with the proponent to define 'significant' as it relates to health effects. However, MOH emphasises that their requirements under the Environmental Assessment Act may not coincide with Health Canada's requirements under CEAA.

Information Required in Project Report

· The proponent should consult with Project Committee agencies to develop acceptable significance criteria and the data base needed to implement the environmental assessment procedure proposed in the application and report on these consultations.

2.5 Complying with the Project Report Specifications

The Project Committee has tried to make its comments on the nature of its concerns and the related Project Report Specifications as clear and detailed as possible. However, it is not its responsibility to develop final terms of reference in the detail needed to commission the proponent's additional studies.

The proponent must assess all of the issues identified in the Project Report specifications, unless responsibility is assigned to another party.

It is important that the proponent follow the specifications scrupulously to avoid delays in review at the project report stage, and to permit the Project Committee and the public to complete the project report review in a timely and efficient manner, and with a minimum of time-consuming iterations.

Thus, unless the context clearly indicates otherwise, the Project Report Specifications are obligatory reporting requirements (not merely discretionary suggestions or requests for information or analysis). If a reporting request were deemed to be optional, this would be clearly stated in the Specifications, and would normally reflect public interest in a matter for which there are no relevant public policy expectations.

By way of clarification, and to avoid any misunderstanding, it should also be noted that, in the Project Report Specifications, the application information requirements for the licenses and permits which would have to be obtained for the PAC-RIM LNG project have been identified by some review agencies (also see Appendix 4). This material is presented in the specifications only as advice for the information of the proponent and other parties to the review. This information is not intended to be, and does not constitute, an obligatory part of the proponent's reporting requirements at the project report review stage.

It is a normal part of the process for the proponent to meet with individual agencies to clarify and refine the specifications through discussion, and this is encouraged. Similar meetings may also be helpful once the proponent has drafted provisional terms of reference for the commissioning of the various study programs which may be needed to fulfill the requirements of the Project Report Specifications. If the public has questions with respect to the intent of the project report specifications, these may be communicated in writing to the responsible agency, either directly or through the EA Office, and a response will be arranged, either in writing or, where warranted, through meetings between the public and relevant agency staff.

Input of the Project Committee
For each issue identified, the Project Report must:
  • evaluate the impact potential of the project, both adverse and beneficial, detailing source, magnitude, level of significance and risk, and also the identities of affected parties (i.e. those people or companies potentially impacted and requiring compensation - registered trapline owners, guide outfitters, etc.), properties, lands or resources (the Environmental Assessment Act defines "project" as the construction, operation, dismantling or abandonment of a physical work);
  • in cases where PAC-RIM is required, by these Specifications, to negotiate and work jointly or cooperatively with an agency or First Nation to collect information or undertake studies, and, where the Executive Director is satisfied that PAC-RIM, despite efforts made in good faith, has been unable to do so, PAC-RIM is to provide the information, and make its assessment, independently.
  • present proposed mitigation measures (technically and economically feasible) designed to reduce potential adverse effects and clearly indicate the level of significance of the residual impacts;
  • if appropriate (i.e. where not the proponent), identify the party which has impact management responsibility;
  • identify follow-up/monitoring programs if the project is approved;
  • where the potential for adverse impacts is substantial and there is any significant doubt about the effectiveness of proposed mitigation measure(s) in reducing these impacts to acceptable levels, the proponent should also propose practicable contingency measures which could be adopted after the development is underway, in case of a failure of the intended impact management measures to achieve their objectives. Examples of potential contingency measures, depending on the issue of concern, could include relocation of facilities, installation of backup facilities, revised development scheduling, revised design specifications, or changes in operational practices.

2.6 Land Use Considerations

Input of the Project Committee

Where Protected Areas have been established, PAC-RIM will have to examine each individual PA arrangement to see whether or not any provision is referenced allowing for revisions to the existing PNG pipeline right-of-way and whether or not this would apply to the proposed PAC-RIM right-of-way expansion. If such provisions have not been included, then PAC-RIM would not be allowed to use the protected area for its pipeline route.

Input of the Ministry of Environment, Lands and Parks (MELP)

The proposed LNG pipeline corridor potentially crosses 4 protected areas and one proposed protected area in the BC Parks Skeena District: Williams Creek, Ecological Reserve, Gitnadoix Recreation Area, Skeena River Ecological Reserve, Exchamsiks River Provincial Park, Old Man Lake/China Nose proposed protected area. The Park Act and The Ecological Reserve Regulations prohibit industrial activities, including surface disturbance of pipeline development in ecological reserves or parks. It is recommended that the proponent avoid these areas.

Williams Creek Ecological Reserve ("ER"). This ER is located on the south side of Williams Creek and was established to protect terraced bogs and representative forests of the Coastal Western Hemlock biogeoclimatic zone. The pipeline appears to avoid the ecological reserve, however, the corridor and pipeline should be clearly marked to avoid the ecological reserve.

Gitnadoix River Recreation Area. This recreation area protects the Gitnadoix River watershed and Alastair Lake. The Gitnadoix River has high fisheries values. Currently the PNG pipeline crosses the mouth of the Gitnadoix, however the Skeena and Gitnadoix river beds are unstable in this area. This past summer PNG has had to reinforce that area to protect the pipeline. Another pipeline in the area would required additional stabilization action, which would further compromise fisheries values and recreation values for the Gitnadoix River. It is recommended that the pipeline corridor cross the Skeena River east of the Gitnadoix to avoid the area at the mouth of that river.

Skeena River Ecological Reserve. The Skeena River ER was established to protect unlogged floodplain islands with black cottonwood communities and encompasses several islands in the Skeena River across from the Exchamsiks River. Any removal of vegetation on ecological reserve is prohibited so realigning the pipeline route to avoid this ecological reserve (where the primary purpose is protection of the vegetation) is recommended.

Exchamsiks River Provincial Park. This park protects a old growth floodplain spruce stand. It is recommended that the pipeline corridor be drawn along the south side of Highway 16 to avoid Exchamsiks Park.

Oldman Lake/China Nose Proposed Protected Area. This area was proposed to protect an example of the Sub-Boreal Spruce-dk Biogeoclimatic subzone and local and regional recreation values. Conservation and recreation values may be compromised by the proposed pipeline corridor.

In addition to the areas discussed above, the proposed pipeline may also affect Prudhomme Lake, Diana Lake and Lakelse Lake provincial parks. The pipeline and corridor should avoid these protected areas. In terms of existing protected areas, the route proposed between Terrace and Kitimat would have less impact than the route proposed between Terrace and Prince Rupert.

2.7 Public Consultation

Input of the Project Committee (EAO as contact)

Section 23 (a) of the Environmental Assessment Act, allows for the requirement that the proponent include in the Project Report "one or more plans, showing ... how the proponent intends to carry out ... public consultation about the project". All records of consultation which PAC-RIM includes as part of its Project Report, will be subject to the B.C. Freedom of Information and Protection of Privacy Act. The following requirements are in addition to any other consultation activities planned by PAC-RIM.

Information Required in Project Report
  • PAC-RIM to provide details of consultations planned as per section 2.6.5.3 of its Application.
  • PAC-RIM to contact and consult with representatives on the list of Cattlemen's Associations and Farmers Institutes provided to the proponent by the EAO on November 15, 1995 and report on these discussions/consultations.
  • PAC-RIM to consult with representatives of organizations and businesses in the Terrace area who have submitted comments on the Draft Project Report Specifications and report on these discussions/consultations.
  • PAC-RIM to provide details of consultations undertaken during the preparation of the Project Report and details of any plans it has for consultations following submission of its Project Report.

2.8 General Comments

Input of the Ministry of Employment and Investment (MEI)

MEI supports this project in principle and believes the project is consistent with government objectives of job creation, regional economic development, market diversification, supporting value-added exports of natural resources, and the development of the natural gas industry. MEI must be satisfied that a proposed project which utilizes British Columbia's natural gas resources is environmentally sound. MEI has no specific environmental concerns regarding this project at this time and believes that adverse environmental impacts can be avoided or mitigated to an acceptable level. MEI's mandate includes ensuring that the province's natural gas resources are developed and used in a way that maximizes the economic benefit to British Columbians. In general, MEI believes the project could have a positive economic impact for British Columbia, providing a secure, long-term, alternative market for British Columbia's natural gas industry, value-added processing of our natural resources, and export diversification.

Input of the District of Kitimat

The project is fairly straightforward from technical and potential environmental impact points of view, uses established technology and has been designed according to rigorous assessment practices. It is a full integrated and defensible project at the technical and legal level. The company is committed to be open, to document issues, and to fully satisfy the requirements of the Act, and Kitimat is satisfied that its interests will be protected. The Environmental Management Plan has examined issues from earlier LNG projects and other projects from the region. The application and project report will incorporate issues raised during the review of these projects and issues identified directly by PAC-RIM as part of its consultation initiatives. PAC-RIM has set criteria to identify the significance of various impacts. Kitimat is pleased with the opportunity that further study will eliminate previous misconceptions about the Port of Kitimat, the Kitimat environment and suitability for expansion. Kitimat views the application as a starting document, designed to contribute to wider discussion of the project methodology.

The issues scoping completed by the proponent, we believe to be representative of reality for the Plant and Marine Terminal Facilities, particularly for the Kitimat location. We are pleased with the degree of research the proponent has undertaken toward previous proposals and reports. We have confidence in their ability to differentiate science from partisan motivated documentation - such as is contained in previous project proposals. Our concern remains however, that many government ministries continue to absorb and align present day understanding of Kitimat and its environment based on outdated, erroneous information which has historically arisen through Prince Rupert - Kitimat competition for industrial development.

Input of the Kitamaat Village Council.

Kitamaat Village Council has identified the following general concerns which include, but are not limited to: environment, resource, social, economic, cultural, health and safety, as areas of concern.

2.9 Pipeline Route Selection

Section 2.2.1.1 of PAC-RIM's application describes the pipeline route selection criteria. The comments below are intended to provide additional advice to PAC-RIM to assist them with route refinement.

Input of the Ministry of Environment, Lands and Parks (MELP)

The ministry has stated that the pipeline alignment should be selected on the basis of environmental as well as economic considerations. The proponent states in the Application that final routing of the pipeline will be guided by criteria, including the ability to install the right of way (ROW) adjacent to or in the vicinity of the Pacific Northern Gas (PNG) ROW to minimize effects. While the ministry agrees with the approach of consolidating pipeline impacts within one corridor, in some cases, creating another 18 m ROW abutting the existing PNG ROW may not be preferred due to impacts to ecologically sensitive areas, such as wetlands, or protected areas.

Permitting Advice:

PAC-RIM LNG should define boundaries of Notation of Interest for the linear corridor to the minimum width possible, taking into account the potential need for adjustment for engineering or environmental concerns. Maximum width of the corridor to be no greater than 1 km.

PAC-RIM LNG Inc. is responsible to complete a status of the linear corridor at their own expense to determine private and Crown parcels.

PAC-RIM LNG Inc. to apply for Interim License of Occupation for ROW purposesfiled concurrently with EA review.

Route Advice:

If the route follows the PNG right of way, there are several areas where PNG presently has erosion problems of great significance. These areas should be avoided altogether or engineered so the erosion problems are reduced (i.e. pipeline placement below the scour depth). Areas with erosion problems are:

Telkwa River, sheet 11 Khyex River/Lachman Creek, sheet 16

Zymoetz River, sheet 12 Work Channel, sheet 17

Kasiks/Khyex Rivers loop, sheet 15 Furlong/Hatchery Creeks, sheet 18

Skeena River by Gitnadoix River, sheet 15 Limonite Creek, sheet 12

Possible options include:

Limonite/Zymoetz - higher elevation; deeper underground placement

Skeena River by Gitnadoix River - the area upstream of the existing pipeline crossing is being very actively eroded by Skeena River flows. BC Hydro is presently trying to protect their power line and PNG their pipeline. The LNG line should cross the Skeena upstream of this section to avoid the present erosion problem.

Kasiks/Khyex Loop - PNG is presently working on many repairs to this particular loop. The mainstems and tributaries (Arden Creek) have high fish values. Erosion is significant, space limited. The LNG line would be better located along the Skeena River and stay out of this area.

Work Channel area - this area has physical restraints, lots of water, careful placement required.

Furlong/Hatchery Creeks - high erosion creeks are active alluvial fans, higher elevations for line placement.

Information Required in Project Report

· PAC-RIM will have to provide an environmental and economic rationale for a preferred alignment in its Project Report based on the following information requirements:

1. PAC-RIM is required to do Terrestrial Ecosystem Mapping (TEM) for those sections of the pipeline route identified as having sensitive or valued wildlife habitat. TEM mapping, as well as existing biophysical information, will provide guidance to avoid environmentally sensitive areas for final route selection and will be used to develop mitigation/compensation requirements for the project once the final alignment is known. This applies to both the new ROW and the ROW adjoining the PNG ROW.

PAC-RIM is to locate sensitive and valued wildlife habitat areas along its proposed ROW based on a review of existing biogeoclimatic maps, 1:250,000 TEM mapping and other available information identifying rare and endangered species sites (from the Conservation Data Centre), wetlands and ungulate winter ranges in the proposed pipeline corridor, and information on traditional uses. PAC-RIM is to present the locations of sensitive and valued habitat to regulatory agencies (and to the OWHC in areas of their traditional territory) for review and consultation before proceeding with detailed TEM mapping. (Also see OWHC and MOTH requirements on pages 17 and 26).

For the areas identified, TEM mapping must be conducted according to the method set out in Standards for Terrestrial Ecosystem Mapping for BC (1995) [contact Ted Lea, 387-9781]. Mapping at a survey intensity level 4 (10-25% of the polygons sampled) will be required at a scale of 1:20,000 for 1 kilometer on both sides of the proposed alignment. Mapping at a more detailed scale (1:5,000) should be carried out around proposed compressor station sites. PAC-RIM to provide copies of the TEM maps to MELP (contact Ted Lea) to ensure that maps meet provincial standards prior to finalization of the Project Report.

  1. Aquatic biophysical habitat inventory is required for all proposed stream crossing sites or potential areas of stream, lake or wetland encroachment according to the methods outlined in Lake and Stream Inventory Standards and Procedures (Resource Inventory Committee, draft of May 1995).
  2. Information on protected areas and sensitive sites will also be required to determine route selection. The Application states that this information will be collected. However, it will be necessary to include this as part of the Project Report and justification for the route selected.
  3. The company will have to monitor wildlife use in specific areas (determined from the TEM habitat maps as being impacted habitat) of the proposed pipeline, compressor stations, access roads and other areas of disturbance (PAC-RIM should examine the methods outlined by David Hatler - A Method for Monitoring Wildlife in Managed Forests, March 1991). The timing of wildlife monitoring should be agreed to in consultation with MELP wildlife staff (contact Lorne MacIntosh, 847-7288).
  • To facilitate review and agreement on the final alignment, the proponent should show all relevant environmental information affecting the route selection on the route maps and present these in the Project Report. The route maps in the Application name crossings and some sensitive areas, e.g., ecological reserves. For the Project Report, results and summaries of TEM mapping, aquatic biophysical studies and other relevant environmental information must be shown on the maps or appropriately referenced.
  • In many of the areas identified as having erosion problems, there is not enough room for another pipeline of 18m clearance width. Alternate route placement should be investigated and shown whether feasible or not.
Input of the Kitimat-Stikine Regional District

Generally it has been the preference of this Regional District that linear developments be grouped into common corridors. According to the Application, the company proposes to deviate from the Pacific Northern Gas right-of-way east of Terrace and descend into the Kitimat Valley through the largely undeveloped Williams Creek drainage. Pacific Northern Gas has had problems over the years with flood damage in the Copper River and there may be very justifiable reasons for choosing the Williams Creek alternative.

The Regional District asks that the appropriate agencies consider whether development of the Williams Creek corridor is acceptable given the ecological factors. A number of related issues also arise: are there advantages for maintaining a secure supply of natural gas to the region by developing separate routes and pipelines; would it be feasible or useful and does this project present an opportunity to later decommission the Copper River pipeline; will the pipeline routing be selected to accommodate future potential for other linear development (road access and hydroelectric transmission lines) through this area? It is beyond the scope of this review but the Regional District would also like to record that opportunities should be encouraged to install an "oversize" pipe (at least through the Telkwa to Terrace section of the route) to facilitate other economic development in the northwest.

Input of the District of Kitimat

Concern about the degree of difficulty for installation, maintenance, and operation, sensitivity of the Skeena River watershed, and avalanche activity of the Terrace-Prince Rupert option. The risk to the environment in this area we believe to be beyond mitigation.

Input of the Ministry of Transportation and Highways (MOTH)

The Ministry has a reserve on crown lands through the Telkwa Pass, with the intent of preserving right of way for a highway through the Pass. This is especially important at the height of the Pass where building possibilities are limited by the terrain and lakes there. The notation will not be canceled but accommodation for the pipeline will be considered.

The Ministry has a preliminary line for a route through the Pass. If the new pipeline does closely parallel the PNG line, there should be little conflict. However, on the application 1:50,000 mapping, the two pipelines appear to diverge. If this is the case there may be conflict between the pipeline and highway alignments.

Bridges accessing the area south west of Telkwa have the following restrictions:

Telkwa Bridge - legal axle loads; Height 4.82m; Width 5.73m (the tight radius turns on the bridge approaches may be awkward, although the route is used by logging trucks now); Quick bridge - maximum load 8 tonnes.

The ministry will not cancel its interest in the route but may give conditional approval to construction within the Pass. The ministry's preliminary design (on 1:5,000 base map) could serve as a reference for this issue.

Information Required in Project Report
  • The proposed pipeline route, relative to the preliminary highway alignment through Telkwa Pass, is required as part of the Project Report and should be mapped at 1:5,000.
  • The proponent should consult with the regional office prior to drafting a final alignment and must reach agreement with the Ministry on a pipeline alignment that will not impede a future highway.
Input of the Ministry of Employment and Investment (MEI)

MEI is satisfied that the proposed pipeline route is reasonable and justified given its purpose to bring natural gas from northeast British Columbia and Alberta to a plant located on the coast. MEI supports PAC-RIM's proposal to utilize or generally parallel the existing Pacific Northern Gas (PNG) right-of-way to the extent practicable, subject to deviations for technical, environmental and/or socio-economic considerations.

Input of the Provincial Agricultural Land Commission

Approximately 1/5 of the total pipeline route would cross the Agricultural Land Reserve (ALR). Pipelines, if given appropriate consideration of individual landscape features, legal lot lines, buildings, etc., and if constructed using proper construction and reclamation techniques, need not cause a permanent debilitation to lands in the ALR. When identifying a location for a pipeline which will minimize any impact to farm operations and the soil source, these are some of the considerations taken into account when choosing a pipeline right of way: looping - placing a second pipeline within an existing right of way; using exiting utility or transportation corridors; avoiding farm headquarters, structures or sensitive areas to a farming operation; avoiding prime agricultural soils; and locating along topographic breaks.

Input of Environment Canada

Meaningful avoidance of critical habitat for rare and endangered species can best be accomplished at the corridor planning level.

2.10 LNG Plant Site Selection

Input of the Ministry of Employment and Investment (MEI)

MEI is satisfied that the alternative plant sites of Kitimat and Prince Rupert represent viable and acceptable choices, given the requirements for sheltered deep-water port facilities with access to the ocean and proximity to Pacific Rim markets, as well as certain existing industrial infrastructure. MEI would prefer that the company identifies its chosen plant site as soon as possible, but in any case prior to submission of a Project Report.

Input of the District of Kitimat

Kitimat has a large estuary area associated with the Kitimat River. Most of existing industrial development is located on and within this estuary. However, the PAC-RIM LNG project, located at Bish Cover 10 km distant from Kitimat estuary and harbour industrial development is without history of development and does not affect the Kitimat Estuary. The exact plant site designated is across Bish Cove 1/2 nautical mile from the Bish Creek Estuary, and the proposed roads and pipelines are distanced from the creek estuary and are with the width at plant site in excess of 1 nautical mile, the depth in excess of 150 metres, current ranging 5 -1 knot and tides in excess of 6.4 meters and offer exceptional natural assistance to cooling water systems and discharge effects. Any issues arising from estuary impacts will be regulated through traditional estuary management channels and will involve multi-stakeholders at provincial and federal levels.

Kitimat believes that the location decision should be made in the best interest of Canada and BC vs. at the interests of the sales and shipping end of the project. Economic, environmental and investment factors play a significant role in this project and from our realm of understanding outweigh decision control of location by offshore recipients of the commodities.

The District believes all information and issues associated with the PAC-RIM project must stand on its own. Technology, information methodology, economy, government regulations, and world markets have all changed dramatically over the past 10 years. The PAC-RIM project must be reviewed in the context of 1996. Referring to previous proposals is not relevant and can be misleading. The Dome Project was significantly larger than what is being proposed by PAC-RIM LNG and therefore had entirely different criteria associated with all aspects of the project. Should Project Committee members need to pursue an appropriate and relevant comparison to a previous project that shares similar "perspective" to the PAC-RIM LNG project, the "Rim-Gas" project proposed in 1982 is far more similar in scope than Dome.

Input of Environment Canada
Input of the Ministry of Environment, Lands and Parks (MELP)

PAC-RIM should minimize impacts from the LNG plant by selecting the most appropriate site.

A. PIPELINE - Environmental, Resource Management And Technical Issues

A1 General

Input of the Ministry of Forests (MOF)

The pipeline ROW may result in a number of environmental effects such as soil disturbance, loss of vegetative cover, stream damage, interference with wildlife habitat, damage to the forage resource, introduction of noxious weeds and possible removal of natural range barriers. Most of the effects of the ROW of concern to the Ministry of Forests have been identified in the Application.

Assuming that PAC-RIM is able to gather the required environmental data, the environmental effects of the project will be mitigated and addressed through permit conditions and Forest Practices Code requirements. Because the pipeline route has not been finalized, it is not possible to indicate what measures will be required at this time.

Input of Environment Canada

The recent release of the federal Canadian Biodiversity Strategy has resulted in draft guidelines on biological diversity in environmental assessment.

Information Required in Project Report

· The Project Report should address the potential effects of the project on biological diversity including flora and fauna.

Input of the Kitsumkalum Indian Band

Input of the Kitselas Indian Band

Information Required in Project Report

· PAC-RIM LNG Inc. to consult with the Kitsumkalum Indian Band on avoiding natural resource impacts of the lower Skeena River and with the Kitselas Indian Band on avoiding impacts within the Copper River Watershed, Lower Skeena valley and the Upper Kitimat watershed.

Input of the Kitamaat Village Council
Information Required in Project Report

· PAC-RIM LNG Inc. to consult with the Kitamaat Village Council on project impacts on soil, plant and wildlife conditions on the Kitimat River and its watershed, and potential impacts on traditional uses and archaeological/cultural sites, and any mitigation proposed.

Input of the Ministry of Environment, Lands and Parks (MELP)

PAC-RIM should: minimize impact of pipeline corridor on water quality, aquatic life, wildlife, and human health; minimize impact of pipeline on protected areas and should develop appropriate mitigation plan for impacts of pipeline construction, especially on stream crossings.

Information Required in Project Report

· PAC-RIM to evaluate and report on the potential for mitigation of impacts of construction of pipelines and compressor stations based on experience and history of similar operations elsewhere (i.e. the PNG pipeline).

A2 Waste

Input of the Ministry of Health (MOH)

The proponent proposes to truck sewage and solid waste to receiving stations and should be aware that sewage and waste disposal arrangements must be made to the satisfaction of the concerned MHO (or his designate) or with MELP. Features of such an arrangement might be expected to include written agreements from these receiving stations to receive the waste, and contingency plans to deal with spills (Permitting Issue).

Input of Health and Welfare Canada

Concerns related to water include sewage discharge from construction camps and operation facilities.

Information Required in Project Report

· PAC-RIM to identify impacts of sewage discharge and mitigation plans.

Input of the Ministry of Environment, Lands and Parks (MELP)

If cooling water is necessary at the compressor stations, a closed-circuit loop should be utilized. Sanitary sewage should be discharged according to the Ministry of Health's design criteria or MELP criteria, depending on volume of effluent discharged. If oily effluent is to be discharged, oil water separators should be incorporated into the design of the building.

Information Required in Project Report
  • PAC-RIM to identify and assess the impacts of various toxic and potentially hazardous compounds that will be used in and around compressor stations and in their service lines, including fuels, cleaners, hydrocarbons, PCBs, solvents, etc., and plan for containment of the compounds identified.
  • PAC-RIM to identify any other waste streams or materials that could be released (e.g., road salt and paints) and plan for treatment.
  • PAC-RIM to explain the way that effluent is discharged from hydrostatic testing.

A3 Water Quality

Input of Environment Canada

The proposed Lakelse Lake Wildlife Management Area, mentioned in Section of 4.1.1.11.1 of the Application is rated as class 3M for the waterfowl according to Canada Land Inventory mapping for waterfowl production capability. Class 3M indicates that while an area may not be critical for waterfowl production, it is important for staging during migration or for over wintering. It appears from the pipeline maps that the pipeline does not approach the lake very closely. However, any impacts due to increased sedimentation should be avoided.

Information Required in Project Report

· PAC-RIM to fully address the impact of the project on water quality. The Project Report will need to fully substantiate any conclusions made regarding the significance of impacts on water quality.

A3.1 Stream Crossing

Input of the Ministry of Environment, Lands and Parks (MELP)

The most sensitive aspect of this pipeline project will be the stream crossings.

MELP has developed several standards towards stream crossings which would be required during construction. They are:

Input of the Department of Fisheries and Oceans (DFO)

There are concerns regarding the construction of the main gas trunk-line from Summit Lake to the site, and the plan to construct in one year. There are many stream crossings to be considered, with streams of all different sizes to be handled. DFO's Prince George office has provided some level of detail for the fisheries concerns. When the final route selection has been made, the same information can be provided for the remainder of the route.

A general assessment of this project has been completed for the water crossings which are within the Fraser River drainage portion of the project. A summary of this assessment, including comments on each water crossing (listed from east to west), has been provided (please consult actual text of submission for chart describing on a crossing-by-crossing basis, the Salmon Values and/or concerns, the recommended installation, the Instream Work Windows and additional comments). In summary, directional drilling is recommended for the Salmon River crossings and for the Stuart River. If directional drilling is not achievable, PAC-RIM is to discuss alternatives with regulatory agencies. The remainder of the crossings are either of no concern or are recommended for installation with isolation of flow within the specified work window periods. (DFO - Prince George)

Water crossing with potential implication to salmon values

The primary focus of this assessment, as provided within the previous table, has been directed towards the protection of anadromous salmonid habitat within the Fraser River drainage portion of the proposed PAC-RIM Project. This has included the identification of crossings for which there is a potential for direct impacts (on site spawning habitat, rearing habitat for both) or indirect impacts (water quality concerns for downstream spawning/rearing habitats) to salmon and recommendations for appropriate mitigation measures. Watercourses for which DFO has specific concerns regarding impacts to salmon habitat.

Mitigation measures listed within this table for each crossing include DFO recommendations for the most appropriate types of installation and the provision of DFO instream work windows. In regard to installation methodology, recommendations are provided for water crossings where inappropriate installation would have the potential to impact salmon habitat. These recommendations include: isolation of flow (flume or dam/pump); directional drilling; and aerial crossing. Instream work windows deemed appropriate for these activities have been included and are based upon the most appropriate timing for avoidance of potential impacts to incubating eggs/alevins and adult salmon within specific watercourses. The Ministry of Environment, Lands and Parks (MELP) should be contacted for their comments regarding these proposed crossings, especially concerning the stated instream work windows and any requirements for modifications required to safeguard trout values.

The following list of general conditions should be applied to those pipeline water crossings that have the potential to impact salmon values:

Water crossings without potential implications to salmon values:

For pipeline crossings where there is not a potential for direct or indirect impacts to salmon habitat, MELP should be contacted for their comments concerning trout values, recommended installation measures and appropriate instream work windows. In the absence of specific comments from MELP concerning installation measures, it is assumed that installation will be conducted under isolation of flow and subject to the general comments listed above.

Coast Guard has reviewed the proposed pipeline route and has identified the following waterway crossings that will require an application to Coast Guard under the Navigable Waters Protection Act.

Salmon River Kasiks River Porpoise River Stuart River Skeena River Lakelse River Endako River Gitnadoix River Little Wedeene River Bulckley River Lachman River Zymoetz River

Clore River Khyex River

It is likely that these pipeline crossings will be exempted from the requirements of the Navigable Waters Protect Act provided that:

Information Required In Project Report (MELP, DFO, CCG)
  • PAC-RIM to provide detailed mapping of the stream reaches where the pipeline will cross.
  • PAC-RIM to describe methods that eliminate the potential for stream impacts, and a summary of results of situations where these methods have been used successfully.
  • PAC-RIM to provide information on construction of stream crossings:

- timing of construction and schedule consistent with applicable DFO and MELP recommended instream work windows.

  • silt control measures proposed
  • crossing plans and methods
  • erosion control measures proposed.
  • construction plan as per CCG advice above including description of construction techniques and methods.

· PAC-RIM to commit to employ methods that have been agreed to by the regulatory agencies or provide justification for alternative measures.

  • PAC-RIM to identify creeks with higher fish resource values and conduct limited sampling of suspended sediments at locations upstream and downstream of the crossings to confirm control measures are working during construction. The analysis must be capable of resolving differences of increased sediments of 10mg/L or 10% over background...(a clarity wedge will not suffice).
  • PAc-RIM is advised that dewatering of streambed must be accompanied by fish salvage conducted by a qualified professional.
  • PAC-RIM to engage an environmental consultant to monitor pipeline installation and ensure mitigation measures are employed.
  • PAC-RIM to provide details of measures planned to prevent substances (such as silt) deleterious to aquatic life from entering the rivers during construction and operation.
  • PAC-RIM to properly restore all stream side areas after construction.
  • PAC-RIM to provide details of all mitigative measures that will be employed to minimize potential impacts that the stream crossings and project construction will cause (such as, prevention of run-off from any disturbed upslope area from entering watercourses during construction and prior to the re-establishment of vegetation).

A4 Fish and Wildlife

A4.1 General

Input of the Ministry of Environment, Lands and Parks (MELP)

There are numerous resource conflicts that will need to be avoided in the construction phase of the pipeline with mammals, terrestrial ecosystems, fish, migratory birds, other avifauna habitat and streams along the pipeline routes. MELP is also concerned about the effects the ROW may have on animals (e.g., changes in migration routes, implication for traplines).

Information Required in Project Report
  • PAC-RIM to identify and create resource inventories along the pipeline route guided by results of the TEM of sensitive habitat where there are impacts and identify resident and migrant species, vegetation, as well as critical migration corridors wherever the project will alter the land.
  • PAC-RIM will be required to identify impacts and address any adverse impacts of the project on registered traplines.

Input of the Office of the Wet'suwet'en Hereditary Chiefs (OWHC)

TEM will assist in identification of the wildlife capabilities within the ROW and the ability for the Wet'suwet'en to exercise Aboriginal rights. In order to determine the extent of habitat losses, field surveys are required in order to minimize or avoid impacts.

Information Required in Project Report

  • PAC-RIM to study and assess the impact on wildlife resulting from increased access due to widening of the existing corridor.
  • PAC-RIM's assessment to include any new roads, borrow pits and compressor stations.
  • PAC-RIM to do TEM (s) for compressor stations should be at the site series level and at a scale of 1:5,000 covering an area of 1 km in all directions from each compressor station.
  • PAC-RIM to do TEM (s) at a scale of 1:20,000 at a site series level for the pipeline route in the Telkwa pass area (from Limonite Creek east to the confluence of the Bulkely River and the Telkwa River).
Input of Environment Canada

Section 4.1.1.5.1 of the Application does not indicate that field surveys will be done to assess wildlife use along the route of the pipeline. While government agencies are a useful source of information on a small number of species, particularly waterfowl near the coast, there are large areas in the interior of the province and numerous migratory bird species for which insufficient information is available to make a full and fair assessment of the impact of a project of this scale.

Information Required in Project Report

· Field surveys to establish species occurrence, relative abundance and habitat use along the pipeline route should be conducted during breeding season (any deviations from this requirement must be agreed to by Environment Canada) and the results included in the project report.

A4.2 Fish

Input of the Department of Fisheries and Oceans (DFO)

With regard to the impact of the pipeline on non-salmon areas, PAC-RIM LNG Inc. to contact MELP for comments regarding trout values and instream work windows. Concern about the impact of water-crossings on fisheries values.

Information Required in Project Report
  • PAC-RIM LNG Inc. to identify fisheries resources in the streams affected by water crossings and measures to mitigate impacts at the Project Report stage- where information is not available on species and habitat, it will have to be gathered.
  • PAC-RIM to provide a fisheries assessment, conducted by a fisheries biologist, for the stream crossings which indicates:

- background tributary information

  • crossing site habitat information
  • details of fish species that utilize those habitats (habitats include foreshore, instream features and riparian vegetation)
  • recommendations
  • photographs of the sites.

A4.3 Waterfowl and other Avifauna

Input of the Ministry of Environment, Lands and Parks (MELP)

The proponent should contact the BC Conservation Data Centre @ (604) 356-0928 to obtain up to date information on rare and endangered species. The Conservation Data Centre supplies tracking lists showing red and blue listed species for vertebrates, vascular plants and in some cases invertebrates and non vascular plants for most forest districts or forest regions.

Information Required in Project Report

· PAC-RIM to conduct an ecological inventory for all species in the areas of the pipeline ROW and LNG plant site to determine whther any red and blue listed species occur.

Input of Environment Canada

In general, the Project Report should contain a description of the migratory bird resource for all species using the pipeline including a description of species presence, relative abundance and habitat use. The description should also describe the existing habitat in the environs of all project components. The environmental assessment should relate quantified habitat impacts to impacts on migratory bird species using the habitat.

Issues Summary: The issues summary indicates the interests of Environment Canada with respect to potential pipeline impacts:

The federal government has a policy on Wetland Conservation and advises PAC-RIM that the final pipeline route alignment should not result in any net loss of wetland function in compliance with this policy. This would equally apply to the Bish Cove site if wetlands are found there.

Information Required in Project Report
  • Field studies along the pipeline ROW to determine species occurrence, relative abundance and habitat use at points along the ROW where land will be altered. Ideally these studies would encompass all life stages of the yearly cycle (e.g., impacts on breeding, migrating and overwintering). At minimum, these studies should be conducted in the breeding season (unless otherwise agreed to by the CWS). These studies are necessary to determine the impacts of pipeline construction on migratory birds.
  • A detailed documentation of expected habitat loss is required in order to predict the total impact of the project on migratory birds along the pipeline route.
  • Quantitative predictions of project impact on migratory birds should be made.
  • Every site of potential habitat loss should be described and detailed mitigation measures proposed. The environmental assessment should relate habitat losses to changes in habitat use by migratory birds.
  • Field surveys will be necessary to ensure that impacts to sensitive species (i.e., red, blue and COSEWIC listed species) of avifauna are avoided or minimized.
  • Construction schedule must show that new clearing does not take place during nesting season.

A4.4 Wildlife Habitat

Input of the Ministry of Environment, Lands and Parks (MELP)

The proponent is advised to design a ROW reclamation program that minimizes the use of chemicals for controlling vegetation. Plans for revegetation of the ROW should be developed in consultation with the Pesticide Management Program and Habitat Management of the ministry. In general, rehabilitation should occur with species native to the area to recreate habitat lost to development. Any fence construction along the pipeline should be designed so as not to exclude wildlife movement.

Input of the Office of the Wet'suwet'en Hereditary Chiefs (OWHC)

OWHC requests that they be copied on any applications from PAC-RIM for the use of herbicides within Wet'suwet'en traditional territory.

Input of the Ministry of Agriculture, Fish and Food (MAFF)

Support the position of the Northwest Weed Committee that strict attention be paid to preventative weed control during construction of the proposed PAC-RIM LNG project in northwestern BC. This area of the province is comparatively free of many noxious weeds that are having a devastating impact on agricultural and natural resources in other areas of the province.

To prevent a serious noxious weed situation from developing during and after construction, project personnel should be aware of the impact that their activities have on weed development. It is also critical, as we have learned from past experience, that all equipment used in construction be well cleaned prior to entry to the project so as to remove adhering weed seeds. This is especially the case for equipment originating from outside the northwest sector.

Immediate post-disturbance revegetation with top quality seed having the lowest weed seed tolerance allowed under the Canada Seeds Act is essential.

A high level of awareness by project personnel during development followed by a post-construction monitoring program will prevent a serious economic and environmental threat developing from noxious weed invasion.

Information Required in Project Report

· PAC-RIM LNG Inc. to develop a plan for reclamation of the ROW for review and approval by MELP and MAFF that meets the following objectives:

- minimizes the use of herbicides for controlling vegetation;

  • replaces lost wildlife and grazing habitat;
  • ensures that appropriate standards are in place to prevent the introduction of noxious weeds during and following construction of the pipeline.

A4.5 Access

Input of Environment Canada

Section 4.1.1.5.4 of the Application indicated that increased access to hunters is not a concern because it could be limited and managed on a local basis by wildlife regulatory officials. CWS would like to remind the proponent that access management is the responsibility of the proponent.

Information required in Project Report

· PAC-RIM LNG Inc. to develop plan for access management.

Input of the Ministry of Environment, Lands and Parks (MELP)

Where possible, reclamation of service roads and other areas of disturbance should be required to pre-existing conditions. Bonding may be required and, if so, an adequate level will be determined by government based on reclamation costs provided by PAC-RIM.

Information Required in Project Report

· PAC-RIM to outline plans for reclamation of service roads and other areas of disturbance when no longer needed.

A4.6 Noise Impacts

Input of the Ministry of Environment, Lands and Parks (MELP)

Input of the Office of Wet'suwet'en Hereditary Chiefs (OWHC)

Noise levels should be minimized to avoid impacts to people and wildlife.

Information Required in Project Report

· PAC-RIM to provide details regarding noise levels as part of compressor station siting criteria and assess impacts upon people and wildlife.

A5 Air Impacts

Input of Environment Canada
Information Required in Project Report

· PAC-RIM to fully address the impact of the project on air quality. The Project Report will need to fully substantiate any conclusions made regarding the significance of impacts on air quality.

Input of Ministry of Health (MOH)

Smoke from burning slash must not be allowed to become a health hazard or a serious nuisance to human settlements near the ROW.

Information Required in Project Report

· PAC-RIM to indicate how slash will be disposed of, so that smoke from burning slash (if any) will not become a health hazard or a serious nuisance.

Input of Health and Welfare Canada
Input of the Ministry of Environment, Lands and Parks (MELP)

MELP will require emission dispersion modeling for each compressor station to identify the potential for environmental impacts from NOx, and will require information about environmental risks associated with operation and maintenance at these facilities. Consideration should be given to using tub grinders to dispose of stumps and land clearing debris rather than open burning during pipeline construction.

Information Required in Project Report
  • PAC-RIM to provide necessary baseline data and mitigation plan in Project Report on: impact of air emissions from compressor stations, LNG plant and pipeline on ambient quality, vegetation, wildlife and human health.
  • PAC-RIM to do dispersion modeling for each compressor station to identify the potential for impacts from NOx, SO2 and other gases and provide information about operational and emergency methane releases at the compressor stations.
  • Describe the extent of such emissions - quantity and quality of gas.
  • Odours, CH4, NOx, VOC have to be characterized.
  • A literature search should identify if any of these gases are expected to approach nuisance or impact thresholds for any species or area use.
  • As part of the risk assessment and impact analysis that PAC-RIM will have to conduct for the compressor stations, results of emissions modeling must be used to predict environmental impact levels. Alternative sites and/or treatment should be considered if emissions are predicted to cause siognificant impacts.
  • During operation and maintenance of the pipeline, all emissions and discharges will have to be detailed. Methane emissions during blow-downs, pigging operations and potential emergencies should be discussed.

A6 Recreation Issues

Input of the Ministry of Environment, Lands and Parks (MELP)

In addition to ensuring the protection of the physical and biological aspects of fish and fish habitat for those rivers named as Classified Waters in the Provincial Regulations for angling (e.g. Zymoetz River), MELP has a responsibility to ensure that the quality of angling experience is maintained. Because of Class 1 and 2 designations for the Zymoetz River, MELP prefers that the proponent avoid impacting this system by rerouting the pipeline.

Information Required in Project Report

· PAC-RIM should provide a plan to avoid and or mitigate visual, noise and disturbance impacts on anglers along the Zymoetz River. This plan should provide alternatives to aerial crossings, pipeline encroachments, location of compressor stations and should consider the timing of heavy equipment operation and access planning to avoid impacting anglers.

Input of Ministry of Forests (MOF)

In addition to timber matters, the Ministry of Forests has a mandate to manage range and recreation resources and consider other forest resources (for the latter, as that term is defined in the Forest Practices Code of British Columbia Act). Although MOF's recreation program is mentioned in the application, the Recreation section in the Social VECs category fails to mention ministry recreation sites or trails. MOF indicates that there may be some local effects on recreation. Any effects resulting from increased access on MOF recreation sites or trials or program in general would have to addressed by PAC-RIM in the permitting stage. MOF indicates that the potential effect of the project on other forest resources appears adequate.

Information Required in Project Report

· PAC-RIM to assess the impacts of alternative pipeline routes on MOF's recreation sites and trails (trails and sites near Telkwa are likely to be impacted most).

· PAC-RIM to assess the visual quality impact of their alternative routes in accordance with MOF's standards for visual quality objectives.

A7 Timber Resources

Input of Ministry of Forests (MOF)

One effect of the project will be the loss of the ROW land from the productive forest base. Although its size, in relation to the entire timber resource, is not significant. All other effects (i.e., soil disturbance, revegetation, stream bank stability etc.) can be addressed or mitigated through the permitting process.

Information Required in Project Report

· PAC-RIM to assess the positive and negative effects associated with any new access roads constructed by PAC-RIM to access the ROW that will result in access to previously inaccessible forest.

· PAC-RIM to specify the amount of productive forest land that will be covered by the ROW for the various routes and report on the timber types (using MOF's inventory standards) and the volume of merchantable timber on those lands.

A8 Agricultural Resources

Input of Ministry of Forests (MOF)

The Application discusses the range mandate of the Ministry of Forests in the Agricultural Land Use section in the Economic VECs category. In general, the discussion of the issues and the assessment of the potential impact on range in the Application is satisfactory. Local environmental effects, as they relate to range, will have to be addressed at the permitting stage.

Information Required in Project Report

· PAC-RIM to assess the potential effects of the ROW on tenures issued under the Range Act and propose measures to mitigate any potentially significant effects identified.

Input of the Ministry of Agriculture, Fish and Food (MAFF)

All disturbed areas adjacent to cultivated fields and range areas should have the same quality control applied for soil and site reclamation, and for re-establishing vegetation and weed control. The standards noted by the Agricultural Land Commission should apply to farmlands not in the ALR as well as to range areas.

All efforts should be made to re-seed areas with locally approved seed mixes, either by contacting the land owner, Ministry of Forests District Range specialist or the Ministry of Agriculture, Fisheries and Food District Agrologist.

All efforts should be made by PAC-RIM to replace fencelines and gateways disturbed during construction, and to construct temporary fencing that will effectively prevent livestock from entering the construction zone. Permanent fences and gateways are to be constructed according to the landowners' specifications, or by the standards set on range by the MOF Range specialist.

Temporary loss of grazing on private improved pasture land should be compensated by PAC-RIM through some source of forage supply. Loss of crop production due to construction or timing of reclamation should be compensated to the agricultural producer.

All underground works such as water lines, drain tiles, and power/gas lines should be located on private farmland prior to construction activities. The period of disruption should be minimized with the landowner fully briefed about the period of disruption and the method of reconstruction of those works.

All surface works, such as, ditches, waterways fencelines, corrals etc. should be avoided or, if disturbed, reconstructed in consultation with the landowner.

In addition to the Agriculture Land Commission's conditions on dewatering of trenches, construction activities should avoid the diversion of streams, creeks or any construction pumpage onto farmland without the knowledge, consent and approval of the landowner.

All residues of construction activity will be collected and removed from the construction sites and not buried or burned on any part of the construction sites, i.e.: construction or personal garbage items.

Affected landowners to be identified, consulted and compensated.

Information Required in Project Report
  • PAC-RIM LNG Inc. to apply quality control standards to ALR and Non-ALR land as well as to range areas.
  • PAC-RIM LNG Inc. to comply with details provided by MAFF regarding pipeline construction issues and to also comply with guidelines presented in ALC Schedule A.
  • PAC-RIM to identify all affected landowners and provide information on any mitigation/compensation measures planned.

B. LNG FACILITIES, MARINE LOADOUT, TANKERS, AND UTILITY CORRIDORS - Environmental, Resource Management and Technical Issues

B1 Waste Management and Water Quality

Input of the Prince Rupert Port Corporation

Secondary treatment is available on Ridley Island and is currently used under capacity.

Input of Environment Canada
Information Required in Project Report

· PAC-RIM to fully address the impact of the project on water quality. The Project Report will need to fully substantiate any conclusions made regarding the significance of impacts on water quality.

Input of the Department of Fisheries and Oceans (DFO)
Input of Health and Welfare Canada
Input of the Ministry of Environment, Lands and Parks (MELP)

The proponent should consider the possibility of designing an LNG plant effluent treatment system to accommodate tanker bilge wastes and tanker sewage effluent to reduce the need for marine dumping. If the term "burnpit" actually implies that material will be burnt in an earthen pit, the proponent should consider a condensate collection and recovery capability. PAC-RIM should provide details at permitting on treatment plant design and performance standards for treatment of all process effluents, sewage, or spills to a level of secondary treatment.

Information Required in Project Report

  • PAC-RIM to describe the sewage discharge, treatment of drainage, waste water and storm drain systems within the plant facilities (DFO) and construction camps (Health Canada) and propose treatment measures.
  • A storm water management plan will be required for either of the proposed sites. The proponent shall explain the methodology used to develop and implement an effective storm water plan for the plant site. The design of this plan should ensure that unacceptable materials from the plant site will not be discharged into the storm water collection system.
  • When describing the design of the facility, PAC-RIM will have to detail the nature and characteristics of emissions and effluent discharges that may be anticipated during emergency and/or scheduled shut-downs and start-ups. This information will be required to ensure that human and environmental risks are minimized.
  • PAC-RIM to detail the cleanliness of the water being discharged at the propane feed-gas cooler, along with the potential for recycling this effluent stream.
  • PAC-RIM to detail the cleanliness of the water from the condensate dehydrator and how the organics removed will be dealt with.

B1.1 Water and Habitat Information

Input of the Ministry of Environment, Lands and Parks (MELP)

A large degree of flexibility in the design and engineering for the facility will be necessary to provide for control of contaminants at the source. Once an adequate data base of ambient conditions has been generated, models can be used to predict if impacts associated with this facility will be detectable during the life of this project and to determine whether further control or tretament measures are required. It is critical that background data collection and modeling proceeds as soon as possible. MELP's approved Working Criteria for Water Quality (1995) should be consulted for reference to acceptable marine receiving criteria. The proponent is also referred to "Coquitlam, Pitt River and Burrard Inlet Water Quality Assessment Objectives" (July, 1990) for guidance on conducting an assessment on water quality impacts. Both documents are available from the Water Quality Branch, MELP, 387-9500.

Information Required in Project Report
  • PAC-RIM to collect information on the receiving environment prior to construction of the facility in order to document baseline conditions. Plans for baseline studies must be submitted to relevant agencies for review and approval before studies are undertaken.
  • PAC-RIM to provide both oceanographic and meteorological modeling to ensure that ambient objectives are not exceeded due to the installation of the LNG facility.

B1.2 Dredging

PAC-RIM has stated that it does not intend to do any dredging, however, some work is required at the Kitimat location for wharf pilings, foundations, etc. which may cause disturbances. Specifically, at the Prince Rupert location, the project will be using an existing structure and there is no plan to do underwater construction at that site (except for minor work to install the cooling water diffuser).

Input of Environment Canada

There is no mention in Section 4.3.1.1.4 of the Application of the physical and chemical oceanographic concerns for the marine loading facility and of the disturbance or re-suspension of any contaminated sediments. This could be a concern to the fisheries resource or fish habitat. Industrial activity at Kitimat has resulted in contaminated sediments, particularly with PAH's, in the northern sections of Kitimat Arm. This contamination may or may not extend to Bish Cove, site of the proposed marine loading facility.

If dredging is required at either port location, and the sediments are contaminated, they may not meet criteria for ocean disposal pursuant to a permit issued by Environment Canada under the Canadian Environmental Protection Act (CEPA) Part VI. Uncontaminated sediments may be disposed of at sea subject to obtaining an Ocean Disposal Permit. Environment Canada should be consulted prior to commencement of any sampling program for ocean disposal to ensure the program design is adequate.

Information Required in Project Report
  • If any dredging or other disturbance of marine sediments is expected at the loading facilities, PAC-RIM should test the sediments for contamination and present the results in the Project Report.
  • PAC-RIM should identify the proposed method for disposal of any

sediments whether contaminated or not.

· PAC-RIM should identify mitigation measures to prevent the resuspension of any contaminated sediments disturbed by construction or dredging.

B1.3 Pollution from Tankers

Input of the Department of Fisheries and Oceans (DFO)
Information Required in Project Report

· PAC-RIM to provide information regarding pollution issues associated with the special tanker traffic and shipping of the LNG product and provide a mitigation plan.

B1.4 Coolant Water Discharges

Input of Environment Canada

Elevated water temperature in the marine environment has been shown to be deleterious or lethal to fish.

Information Required in Project Report

· PAC-RIM to assess the effects of coolant water discharges. This must include an analysis to demonstrate that the thermal loading into the receiving environment at the point of discharge, within the initial dilution zone, and outside this zone, is not deleterious to fish. The Project Report will need to fully substantiate any conclusions made regarding the impacts from coolant water discharges.

Input of the Department of Fisheries and Oceans (DFO)
Input of the Ministry of Environment, Lands and Parks (MELP)

The cooling water should be obtained from deeper waters. The heat exchanging capability of cooler water may allow smaller volumes of water to be pumped, thus reducing operating costs. In addition, loss of marine life will likely be reduced if water is removed from the less productive, light reduced aphotic zone. Finally, by utilizing deep, cold, unproductive waters, the necessity of using large volumes of algaecides may be eliminated or reduced.

Information Required in Project Report

· In order to design the cooling water diffuser so that discharges meet or exceed the Pollution Control Objectives for the Chemical and Petroleum Industries of BC, the proponent must do the following:

- provide data such as tide speed and direction, thermal stratification and temperature at point of discharge as well as other parameters required in consultation with regulatory agencies. As noted in the pollution control objectives, the maximum temperatures going to the diffuser will have to be below 90 degrees Fahrenheit, whereas the ambient temperature outside the initial dilution zone should not experience more than a 2 degree Fahrenheit increase;

  • provide sufficient data to facilitate plume dispersion modelling prior to installation of the diffuser in order to ensure that the ambient objectives will not be exceeded;
  • provide a description on the extraction method and any screening requirements for the use of cooling water from the ocean, as well, as assess the effects of temperature increases from cooling water into the marine environment;
  • describe any treatment regimes for the coolant water (e.g., chlorination, fungicides, biocides, etc.) and how these treatments will be neutralized before coolant water is discharged back into the ocean;
  • and is advised that alternative technologies to the use of hypochlorite solution as an algaecide in cooling water should be pursued to avoid the detrimental environmental effects of hypochlorite.

B2 Fish

Input of the Ministry of Environment, Lands and Parks (MELP)

The Application states that more detailed information will be available in the Project Report for marine fishes, mammals and benthos and avifauna in the area of the proposed marine loading facility. The proponent is advised to consult with MELP and the appropriate federal agencies to ensure that data are adequate to assess effects on the marine environment.

Information Required in Project Report
  • PAC-RIM to provide detailed mapping of the foreshore at the LNG plant site.
  • PAC-RIM to provide adequate baseline information for marine fishes, mammals and benthos and avifauna in the area of the proposed marine loading facility to characterize the aquatic life of the area and to identify and evaluate impacts and develop mitigation measures.
  • PAC-RIM to provide data on important and sensitive habitats and populations if existing inventory information is lacking.
Input of the Department of Fisheries and Oceans (DFO)

Both proposed sites seem to involve the foreshore to some extent. How much is impossible to say because there are no details. We believe in each case some foreshore alienation will occur, and will necessitate authorization under section 35(2) of the Fisheries Act. There would need to be discussions of mitigative techniques to reduce impacts and of compensation options.

Site diagrams do not detail presence of streams and fish habitat within the desired areas. Once the final LNG plant site has been chosen, DFO can provide its resource information for that area.

Information required in Project Report
  • PAC-RIM to map the marine foreshore at the LNG loadout site to provide details of the habitat types present and the fish species using that area.
  • PAC-RIM through discussions with DFO, to identify the steps necessary to determine how to appropriately mitigate and compensate for foreshore alienation.

B3 Wildlife

B3.1 Waterfowl and Other Avifauna

Input of Environment Canada

The following issues have been identified as concerns:

Information Required Report in Project
  • PAC-RIM to provide a description of the existing environment which should indicate species occurrence, relative abundance and habitat use at the plant and marine loading facility. Studies should include all seasons (habitat use is expected to include breeding, migration staging and overwintering) unless otherwise agreed to by the CWS.
  • PAC-RIM's assessment should include quantitative predictions of impacts (e.g. changes in species distribution) on waterfowl and marine birds during construction and operation of the LNG plant, access road and marine loadout facility along with proposed mitigation measures.
  • PAC-RIM's assessment should include quantitative prediction of impacts (e.g. changes to species distribution) on other avifauna in the general vicinity of the LNG plant, access road and marine loadout facility. Data are needed to substantiate impact predictions and proposed mitigation measures should be presented.

B3.2 Noise Impacts

Input of the Ministry of Environment, Lands and Parks (MELP)

Noise levels from the plant site should be addressed prior to designing and installing the LNG processing facility.

Information Required in Project Report

· PAC-RIM to assess the impact of noise on resources and people and identify what levels of noise are expected and what resources or populations may be sensitive to noise. Noise impacts to residents should also be considered in this regard.

B4 Utility and Access Corridors

Input of the Ministry of Environment, Lands and Parks (MELP)
Information Required in Project Report
  • Details on the 10 km of access road for the Bish Cove site on Kitimat Arm and the 15 km of power line required for either site are required.
  • Environmental baseline information to be collected for the pipeline should be available for the road since the routes overlap and this information should be used to develop the preliminary alignment and design requirements. If the road and pipeline are built on a separate ROW, environmental baseline information as set out in the pipeline section above will be required for both.
  • The proposed ROW for the powerlines for both proposed LNG sites and any related access or service roads should be presented in the Project Report together with environmental baseline information, as set out in section 2.9.

B5 Air

Input of Health and Welfare Canada
Input of Environment Canada
Input of the Ministry of Environment, Lands and Parks (MELP)

The Application mentions various ìtypicalî emissions such as NOx , CO, CH4, and VOCís (volatile organic compounds). Emissions of VOCís and NOx may contribute to the formation of ozone and acidic precipitation in both Prince Rupert and Kitimat. The LNG plant, with its various unit operations, may create a long term and potentially large scale contribution of contaminants to the airshed wherever the facility is located.

The following comments relate to the actual facility operation and combustion sources. Many of these comments pertain to the permitting process that will be necessary. The following comments were formulated while reviewing the schematic flow diagram for LNG production (Figure 2.5). The condensate separator will have to be something other than a glycol dehydrator due to the potential for benzene emissions. The complete gas cleaning process will have to be detailed, including solids, gasses and liquids removal. The fate of the rejected gasses, liquids and solids will also have to be detailed. In the schematic, H2O and C5+ compounds are removed from the process stream at the condensate dehydrator.

In 1992, Canada signed the United Nations Framework Convention on Climate Change and further committed to stabilizing national greenhouse gas emissions at 1990 levels by the year 2,000. B.C. has endorsed this plan and has committed to stabilize provincial emissions at the 1990 level by the year 2,000. As part of the Greenhouse Action Plan adopted by the Province in 1995, an inventory of greenhouse gas emissions is being developed throughout the Province. For the PAC-RIM project, the information requirements for the inventory of greenhouse gases (carbon dioxide, methane, and nitrous oxide) are set out below. In order to track progress in achieving the goal of stabalizing greenhouse gas emissions, estimates of emission levels predicted for the year 2,000 are required.

Information Required in Project Report
  • The full emission spectrum of the facility needs to be determined, including a detailed list of the VOC's and other contaminants, and the effects of predicted emissions compared with the sensitivity of the affected airshed.
  • The proponent will be required to present information which will detail how emissions will affect the airshed and watershed at all sites being considered for the facility. Issues that will have to be addressed in the Project Report include: estimated concentrations of contaminants at the point of maximum impingement; the potential impacts that emissions may have on water quality, vegetation, human health, wildlife in the airsheds affected; and ways in which these impacts can be minimized or avoided (i.e. all combustion devices to be equipped with low NOx burners).
  • Monitoring of the emissions and ambient levels (or of resultant contaminants such as ozone) will be required unless the proponent can demonstrate that the specific equipment configuration precludes release of these materials.
  • At least one (possible more in complex terrain) meteorological station, capable of generating wind data for dispersion modeling will be required. In order to provide input data for emissions modelling, the proponent will be required to establish a meteorological station at the selected site. Existing meteorological data from either Prince Rupert or Kitimat will be inadequate for the modelling exercise. This will also form a fundamental component of contingency planning for release of gaseous materials. Details regarding meteorological station site selection, data requirements and emissions modelling approaches can be obtained from the Regional Air Quality Meteorologist, Doug Johnson.
  • Emissions from all combustion devices will have to be quantified and there may be need for periodic reassessment of the emitted levels.
  • The Application indicates that monoethanolamine will be used to strip CO2 from feedstock gas. The proponent should provide information on any fumes or other compounds that could be potentially released and if so, what hazards could be associated with releases. The emission characteristics from the MEA system should be qualified and quantified. If the CO2 that is emitted from this source is to be captured, details regarding that process should also be identified.
  • Emissions and condensates from the feed gas drying molecular sieves will have to be detailed.
  • PAC-RIM LNG Inc. to provide emission levels, necessary baseline data and mitigation plan for reducing or controlling emission levels, and assess the impact of air emissions from compressor stations, LNG plant and pipeline on ambient quality, vegetation, wildlife and human health.
  • PAC-RIM to assess environmental impacts associated with use of gas turbine generators to be used for emergency power. The Emission Criteria for Gas Turbines is a relevant document to identify the emission levels that will be expected from such a generator.
  • Specifics regarding the handling and processing of distillates in the C5+ fractionation unit - (are these odorous compounds and at what temperatures are they volatile) will be required (this is the last 'open' portion of the LNG circuit where emissions and/or effluents are generated).
  • PAC-RIM to discuss measures proposed to offset or reduce greenhouse gas emissions from the facilities.
Input of the District of Kitimat

Kitimat has an existing market for CO2 removed during the LNG process. In Kitimat, the Methanex Corporation - a producer of methanol and ammonia required CO2 as a byproduct for industrial processing. This mitigates the most serious of the LNG plant emissions at the Kitimat location. Air quality in Kitimat is monitored by industry and provincial environment and regulatory controls apply. Kitimat is confident that PAC-RIM will meet or exceed all emission compliance requirements.

C. SOCIO-ECONOMIC AND COMMUNITY ISSUES

C1 Cost-Benefit

Input of the Ministry of Employment and Investment (MEI)

Information Required in Project Report

· MEI will require that a cost-benefit analysis be prepared as part of the Project Report to facilitate a full assessment of the true costs and benefits of the project to British Columbia. MEI will prepare terms of reference for this analysis which will include consideration of the factors noted below.

Benefits:

·border revenues from the sale of LNG (20 year cash stream)

Costs:

  • capital cost stream over 20 years, including plant, pipeline, marine terminal facilities and future modifications
  • operating costs for the above
  • estimated opportunity cost of excess capacity on the PAC-RIM or PNG pipeline due to the project
  • federal taxes paid
  • estimated payments to Alberta producers and pipelines to use Alberta gas
  • effect on PNG gas sales and pipeline capacity

Other Parameters:

  • sensitivity analysis of risk factors
  • results using an eight, ten and 12 percent discount rate
  • calculations using real Canadian $1995
  • explanation of assumptions and risks

C2 Employment and Local Socio-Economic Benefits

Input of the Ministry of Employment and Investment (MEI)

Information Required in Project Report
  • PAC-RIM to prepare a social costing analysis of the project. Included in this analysis will be the implications of the project for social factors such as employment, income, and regional development. MEI will prepare terms of reference for this analysis which will include consideration of the following factors:
  • health and safety issues
  • government revenues generated through taxes and royalties
  • new employment generated
  • regional impacts, such as new direct local revenues resulting from the project
  • estimate and explanation of economic spin-off for local communities
  • other community investments
  • PAC-RIM to provide information on local employment and training opportunities (including a breakdown of types of jobs available and skill requirements and some analysis of the local availability of those skills) and the recruitment process for these positions especially as it pertains to the region (MEI encourages 'regional-hire' policies), infrastructure requirements, local procurement and provincial revenue/cost projections.
  • PAC-RIM to assess both the social and economic impacts of the project, suggest mitigation measures to address adverse impacts, and contain any plans proposed to maximize regional socioeconomic benefits.
Input of the Ministry of Health (MOH)
Information Required in Project Report

· PAC-RIM to indicate any plans it may have to involve employees in management and these should be noted in the project report as a positive social impact.

Input of the Kitimat-Stikine Regional District

The Application document provides some initial statements on regional employment and income impacts. The company should document its efforts to ensure that project benefits accrue to the north.

Information Required in Project Report

· PAC-RIM LNG Inc. to elaborate on the following topics:

- regional economic impacts (including housing strategies)

  • transportation scenarios for the movement of liquefied natural gas and supply of goods to the plant
  • methods the company will use to give opportunities for people living in the area to obtain employment or be suppliers to the project
  • program of developing a suppliers' list.

Input of the Purchasing Commission (Comments made on the Prospectus during the EPRP)

The Purchasing Commission would like the opportunity to review the procurement plan once is it completed. The Purchasing Commission can also assist in arranging one or more "Supplier Days" for the exchange of information between the Project Manager and potential suppliers. The proponent should try to debundle the project to create contracts manageable by B.C. suppliers.

Input of the City Of Prince Rupert

The issues concerning Prince Rupert have been adequately addressed or will be addressed in the Project Report stage of the review. The traditional basis for the stable and diversified economy in Prince Rupert and the surrounding region has been the fish, forest and port related industries, as well as the burgeoning tourism potential of the North Coast. A project, such as being proposed by PAC-RIM LNG Inc., will provide the economic diversity required to take us into the twenty-first century. PAC-RIM LNG Inc. will not only provide long-term local employment and related benefits, it will act as an impetus for additional projects such as those which may result from value added or those which may result from economics of shared infrastructure.

Input of the District of Kitimat

The project represents the largest single investment opportunity open to British Columbia at present. Kitimat is confident that MEI will play a significant role in supporting the economic benefit this project represents to B.C. and Canada and will provide, when required, a balanced view which measures economics and environment in the context of long term sustainable development.

The project is entirely private sector financed and Kitimat is confident it will be carefully managed. This is in alignment with present provincial government policy and is supported by Kitimat. The proponent's excellence is evidenced not only through its business and environmental approach but also by the fact that it has voluntarily committed to prepare a Project Report. This demonstrates commitment, strength of character; competency and great confidence in the proven environmental methodology they will exercise throughout the plant life.

The project represents expansive economic opportunity for British Columbia both during the construction and operational life. A significant element of economic opportunity lies within the context of the natural gas feedstock.

Over sizing the pipeline beyond the immediate plant requirements allows for economic opportunities and benefits to the long term sustainability of methanol production in British Columbia and cannot be ignored in project review.

The new pipeline would provide increased supply and lower cost of gas for Methanex's Kitimat Plant, provide for immediate expansion opportunity, and additional job creation and exports from the region. The company has indicated that lower cost for gas makes its British Columbia operations an attractive site and would have affected its recent decision to locate in Chile. It is envisioned that if the PAC-RIM project located in Kitimat, the long term security of this value-added manufacturing will be assured. Methanex is very supportive of this project, has agreed to assist with planning, to use the excess CO2 and has expressed interest in investing in the pipeline. The current supply contract with PNG expires in 2001 and the corporation will need a better price to maintain it's viability in British Columbia.

We believe socioeconomic impacts will be substantial. The infrastructure in Kitimat is sufficient and can be easily expanded to meet additional needs of the industry and its workforce both during construction and ongoing operation. Much of the workforce can be housed within the existing, very affordable housing market and the vacancy rate (presently 7.6%) represents additional housing options for construction needs. Kitimat provides unique support to its industry and workforce including: an economic development focus in facilitating businesses to develop that will service and supply Kitimat industry from within the community; a community skills centre which serves industrial and business clients with state of the art training and development; and a technology training continuum which commences within the Kitimat secondary school system and leads to an undergraduate degree at UNBC.

Kitimat has an exceptionally skilled building trades workforce. The capability of these trades enhance the proponent's ability to provide high percentages of local contracting and local skilled labour for construction and operation of the LNG plant and terminal facilities.

Input of the Ministry of Social Services (MSS)

The proponent must make every reasonable effort to hire local labour (as stated) and, if possible, recipients of Income Assistance.

Information Required in Project Report

· PAC-RIM LNG Inc. to provide a hiring policy which details any plans it has to address employment equity issues and the hiring of people on income assistance.

Input of the Ministry of Agriculture, Fish and Food (MAFF)
Information Required in Project Report

· PAC-RIM LNG Inc. to assess impacts on local employment and training opportunities and provide a hiring policy which details any plans it has for local employment and training opportunities.

Input of Health and Welfare Canada

Balancing any negative impacts will be employment and training opportunities in areas of low employment, compensation for loss of use of traditional foods and medicines, and income sharing opportunities. These measures may lead to improvements in the economic capability, strength and well being of the affected communities and result in an improvement to health.

Information Required in Project Report

· PAC-RIM LNG Inc. to detail any plans it has for: employment and training opportunities in areas of low employment; mitigation and compensation to Aboriginal people for loss of use of traditional foods and medicines; and maximizing and enhancing economic benefits to Aboriginal people (i.e. income sharing opportunities).

Input of the Office of the Wet'suwet'en Hereditary Chiefs (OWHC)

Input of the Allied Tsimshian Tribes
Information Required in Project Report

· PAC-RIM LNG Inc. to provide details and any plans that provide for economic, employment and training opportunities for First Nations people.

C3 Infrastructure and Government Services

Input of the Ministry of Agriculture, Fish and Food (MAFF)
Input of the Ministry Of Employment And Investment
Information Required in Project Report
  • PAC-RIM to assess the impact of the project on social support services (e.g. schools, RCMP, local health care, etc.), Aboriginal impacts, housing and propose mitigation.
  • PAC-RIM to assess the impact of its work crews on recreational facilities in communities.
Input of the Kitamaat Village Council

Information Required in Project Report

· PAC-RIM to assess impacts on Kitamaat Village (community, local government) through community based consultation process and provide information on any mitigation measures necessary for impacts both during construction and through the life of the project.

C4 Transportation and Access

Input of the Ministry of Agriculture, Fish and Food (MAFF)
Input of the Ministry of Transportation and Highways (MOTH)
Input of the Ministry Of Employment And Investment

Assessment of the project in terms of regional traffic and safety impacts will require additional data. It is expected that traffic impacts during pipeline operation will not be significant, but maintenance activities and the traffic movements they will induce should be documented. The greatest impacts (on highway and additional and specialized traffic) are expected during the construction phase, mainly due to ROW clearing and pipeline construction.

Information Required in Project Report
  • PAC-RIM to assess the project in terms of regional traffic and safety impacts (truck, barge, rail, etc.). This will require additional data including: origin and destination of significant movements of materials, supplies, and crews; routes of importance for accessing pipeline construction areas, e.g. south west of Telkwa; and roads emergency response plan.
  • PAC-RIM to document maintenance activities and the traffic movements they will induce.
  • A mitigation strategy will be needed for the potential risk from transport of dangerous/hazardous materials.

C5 Accommodation Requirements

Input of the Ministry of Health

Permits will be required for food preparation, drinking water, sewage disposal, and camp operations (Permitting).

Input of the Kitimat - Stikine Regional District

If camps must be used rather than available accommodation in communities, tenures should ensure that permanent settlement or land alienation does not follow.

Input of the Ministry of Agriculture, Fish and Food (MAFF)

Proponent to communicate with local Ministry of Social Services staff on impacts of the project on housing and accommodation.

Input of the Ministry Of Employment And Investment

Any plans to erect temporary construction camps for pipeline and plant workers should be discussed with local Ministry of Social Services staff.

Information Required in Project Report
  • PAC-RIM to provide accommodation plans for construction crews (including locations of temporary camps and communities affected).
  • PAC-RIM to assess the impacts of work crews on communities (including the capacity of communities to accommodate crews, and mitigation plans proposed).

C6 Public Health and Safety

Input of the Ministry of Social Services (MSS)

During the construction phase of the project, the employees will be "on site" for weeks at a time - when employees "come out of the bush", substance abuse and subsequent spousal and/or child abuse or neglect can be an issue.

Input of the District of Kitimat

Kitimat does not anticipate any health issues from the location of PAC-RIM's LNG plant within municipal boundaries as the nearest population is in excess of 7 km from the plant location.

Input of the Ministry of Health (MOH)

During the construction phase, many of the workers will be working long

hours in isolated locations. When they require recreation, they may tend to

indulge in high-risk behaviour.

Information Required in Project Report

· PAC-RIM to indicate any plans (e.g. drug and alcohol abuse programs, staff training) for mitigating potential destructive behaviour (e.g. substance abuse, negative impacts on family or community) of its construction crews as a result of long periods of crew isolation.

C7 Tourism

Input of Ministry of Small Business, Tourism and Culture

The Ministry is currently revisiting its Northwest Tourism Resource Inventory and will have information on existing use and capability for a range of tourism activities available by the end of the fiscal year 1996/97. This information may be useful in determining impacts. It should also be noted that the Ministry will be supporting the Lakes and Prince George LRMPs and will have information on existing use and capability.

Information Required in Project Report
  • PAC-RIM to document existing tourism businesses both along the pipeline route and, if applicable, in the vicinity of the LNG plant and assess the positive and negative (i.e. visual disturbance, noise, dust, smoke, traffic, etc.) impacts of the project on these operations and activities (e.g. use areas, scheduling, seasonality and impacts on resources) and where appropriate, outline strategies to avoid or mitigate negative effects.
  • PAC-RIM to assess tourism impacts, impacts on water quality, aquatic life, wildlife, and visual quality, on the Zymoetz River, a Class 1 angling river.

D. CULTURE AND HERITAGE

Input of the Ministry of Small Business, Tourism and Culture (SBTC)

The Archaeology Branch recommends that the issuance of a Project Approval Certificate be contingent on completion of the proposed archaeological overview and impact assessments (i.e. identification of archaeological sites, assessment of site significance, identification of potential impacts to archaeological sites, identification by the Archaeological Branch of impact management requirements - implementation of impact management measures prior to ground disturbance that may damage archaeological sites such as geotechnical drilling).

An impact assessment is required in order to identify potential impacts and mitigative options. The proposed pipeline corridor has not been adequately assessed. The impact assessment will require a Heritage Inspection Permit pursuant to section 7 of the Heritage Conservation Act (HCA). This permitted work must be undertaken in advance of ground disturbing activities. The implementation of impact management measures may require Heritage Investigation permits. Heritage Investigation permits will, in most instances, be required prior to specific developments taking place, although in some instances they may run concurrently with development.

The Archaeology Branch's mandate is restricted to areas of Provincial jurisdiction. Impacts to archaeological resources on federal lands could impact the ability to understand related sites located on provincial lands. There is moderate to high potential for archaeological sites at the proposed plant sites, both of which are on federal land.

Potential for ancient archaeological sites - the pipeline and other facilities will cross raised marine terraces and other early-Holocene/late-Pleistocene land forms. Some areas along this route are considered to have high potential for early period archaeological sites of high scientific significance.

Unavoidable impacts to archaeological sites from development activities which occur subsequent to completion of impact assessment and management studies may require a permit pursuant to section 5 of the HCA.

Heritage Inspection and Heritage Investigation Permits issued under section 7 of the Heritage Conservation Act provide the authority to collect data from archaeological sites for impact assessment and mitigative data recovery purposes. These permits are required prior to commencement of ground disturbing activities associated with development and prior to the issuance of the Project Approval Certificate. Heritage Alteration Permits issued under section 5 of the Heritage Conservation Act follow from inspection and investigation permits and allow alteration of archaeological sites during development activities, provided archaeological impact assessment and management studies have been completed, and are accepted by the Archaeological Branch.

Input of Department of Canadian Heritage

The Department of Canadian Heritage concurs with the above comments and assents to have the archaeological overview assessment information requirements described below applied to federal lands.

Information Required in Project Report

· PAC-RIM to Commission an Archaeological Overview Assessment. This overview assessment is required to assist the Archaeology Branch in determining the need and terms of reference for an archaeological impact assessment (see below). The Archaeological Overview Assessment is to be undertaken in accordance with Section 3.4 of the British Columbia Archaeological Impact Assessment Guidelines (Archaeology Branch, 1995)

This study is also to address:

  1. Potential impacts on historic trails.
  2. The identification by a suitably qualified geologist of palaeo-landforms suitable for prehistoric Aboriginal land use or occupation.
  3. Ancillary facilities and developments including: any activities which entail direct ground disturbance; and any other activities which may have indirect effects on sites which are located "upstream" or "downstream" of the development areas. e.g. quarries, access roads, construction camps and associated waste management facilities, geotechnical investigations, service links to the plant site for sewer and water, distribution installations for CO2 sales, and/or improved access and increased traffic in the vicinity of sites sensitive to vandalism.
  4. Potential impact on marine archaeological sites.
  5. Potential impacts of project abandonment and restoration.

Study methodology requirements:

  1. The overview assessment is to include maps of archaeological potential at a scale of 1:20,000 for the pipeline corridor and any other locations which might be subject to ground disturbance by this project.
  2. The overview report and maps are to identify areas of potential disturbance directly and indirectly related to the proposed project, including all associated or ancillary developments.
  3. During selection of the team of consultants, consideration should be given to expertise and experience relevant to the range of natural and prehistoric cultural environments encompassed by this project.
  4. Comprehensive terms of reference for the overview assessment should be developed in consultation with the Archaeology Branch.
  5. Comparative analysis of both plant sites.
  6. PAC-RIM to use procedures and definitions provided in the B.C. Archaeological Impact Assessment Guidelines to evaluate significance.

· PAC-RIM to complete an Archaeological Impact Assessment. The impact assessment will require a Heritage Inspection Permit pursuant to section 7 of the Heritage Conservation Act (HCA). The Archaeological Impact Assessment must be completed prior to any ground disturbing activities in areas identified in the overview as having archaeological potential. Areas lacking sufficient data to accurately predict archaeological potential will also require investigation. Ground disturbance in areas identified in the overview as having nil or low archaeological potential should not occur until such time as an impact management strategy for such locations has been accepted by the Archaeology Branch.

· All of the above also apply to federal lands within the study area.

E FIRST NATIONS ISSUES

Input of Project Committee

The Environmental Assessment Act (s.22) identifies the potential impacts of the project on the exercise of Aboriginal rights as a matter that may be included in a project report. The Act (s. 23) also identifies plans for consultation with First Nations as a matter that may be included in a project report. This is a reflection of the fact that the identification of potential infringements requires both the involvement of First Nations in identifying their Aboriginal rights and consultations with First Nations by proponents to determine the potential adverse impacts of projects upon the exercise of those rights. The information gathered on potential impacts on Aboriginal rights is intended to contribute to an assessment on infringements in order for the ministers to fulfill their legal obligations. There is an understanding among provincial agencies that this information will be gathered as part of the Environmental Assessment process and will not have to be repeated by agencies in post-certification approvals.

PAC-RIM has stated (letter of January 25, 1996) that it has begun a consultation program with First Nations with the stated intent of establishing an on-going relationship built upon the foundation of respect, trust and cooperation to ensure that any potential impacts of the project are identified and understood. This includes: the early and open provision of information on the project; incorporation of local information in project planning activities to minimize any potential impacts of the project; maximizing employment and contracting opportunities; working with First Nation businesses to support their ability to undertake work; cooperating in training opportunities, etc.

The EA Guide (Appendix III, First Nations Issues) outlines obligations, roles and responsibilities. It also provides advice from First Nations on the importance of early consultation and the importance of meeting with First Nations in their communities to define the consultation process.

Information Required in Project Report
  • PAC-RIM to provide a summary of consultations undertaken, and planned, with each of the First Nations identified as being affected by the project (those invited to participate on the PAC-RIM Project Committee).
  • PAC-RIM to report on the results of those consultations including details (unless specifically prevented from doing so as a result of bilateral agreements between PAC-RIM and a First Nation, in which case, it should be so noted) of: the incorporation of local information in project planning activities; employment and contracting opportunities; work with First Nation businesses to support their ability to undertake project work; training opportunities; any plans for on-going consultation and the identification of impacts on the exercise of Aboriginal rights.
  • PAC-RIM to make its best efforts to assess and identify the impacts of the project on the exercise of Aboriginal rights. It is recognized that such identification usually results from a First Nation identifying its rights, often through consultative processes as described above, or as a result of specific studies undertaken.
  • PAC-RIM to detail measures to prevent or mitigate any adverse effects on the exercise of Aboriginal rights.
Input of the Kitamaat Village Council

The consultation process as related to the Kitamaat Village Council and Kitamaat Village community will have to be tailored based on mutual agreement and full involvement of the community. It is important to note that participation in consultations and, therefore, any decision-making, as concerned with this project, are community-based and demands which may be placed on the review process in the future as defined by the community-based process, whatever they may be, should not come as a surprise. The community consultations and requirements which arise in the future will have to allow for Haisla community members and/or their designates to be included in the study teams assembled by the proponent to address issues and concerns identified, to allow for full review of any issues/concerns by the Haisla representatives/designates as part, and at the cost of, the project.

Input of the Office of the Wet'suwet'en Hereditary Chiefs (OWHC)

Consultation: Consultation between PAC-RIM and the OWHC has been on-going. The OWHC considers the proposed pipeline corridor to be new and requiring assessment. Where the PAC-RIM ROW impacts sensitive areas that are adjacent to the existing PNG pipeline, assessments must be done to protect the sensitive areas prior to final route selection. All potential impacts resulting from the project, including potential infringements to Aboriginal rights, need to be addressed and dealt with prior to Certification.

The Wet'suwet'en territories that will be impacted by the pipeline are within the land claims area under ongoing treaty negotiations. Any deviation of paralleling the existing PNG pipeline will require a full assessment of impacts. Additional lands to be assessed will include any new roads, borrow pits, compressor station sites, etc.

Archaeological Study: As mentioned earlier the corridor will be considered as new and archaeological potential studies will be required.

Traplines: There are possible impacts on traplines owned by Wet'suwet'en trappers. Where impacts are identified, negotiations with Wet'suwet'en Trappers will be required.

Mapping: The mapping for the identification of impacted areas will have to be site series level at 1:20,000 scale, 1 km on either side of the proposed pipeline. In the case of compressor stations, TEM (s) will be needed at site series level

at a 1:5,000 scale 1 km surrounding the compressor stations.

Wildlife: The OWHC feels that the field manual, A Method for Monitoring Wildlife in Managed Forests (FRDA Report 172) is a better method of assessing wildlife capabilities.

Ethnobotanical Study: TEM will be advantageous for completing an ethnobotanical assessment of the Zones of Influence. An ethnobotanist may be needed to assist with the identification of Aboriginal Rights.

Socio-economic Study: PAC-RIM to assess the potential socio-economic effects (benefits and negatives) on the Wet'suwet'en.

Information Required in Project Report

· PAC-RIM is required to make its best efforts to provide information on the identification of the potential impacts of the project on the exercise of Aboriginal rights (it is recognized that such identification usually results from a First Nation identifying its rights, often through consultative processes, or as a result of specific studies undertaken).

Unless otherwise agreed to by the OWHC through consultations or agreements with PAC-RIM LNG Inc., with the EAO notified to that effect in writing, the OWHC requests that a Cultural and Traditional Use study, a Socio-economic study and an Ethnobotanical study on the impacted Wet'suwet'en territories be done at the Project Report stage.

The Terms of Reference for such studies will have to be mutually agreed to by Wet'suwet'en, PAC-RIM and the EAO. The OWHC would like to see included in the terms of reference, consideration of cumulative impacts, socio-economic impacts, impacts on free use of land base - ability to exercise unextinguished Aboriginal rights, impact on stream crossings and timing of installation, and ethnobotany. The OWHC will negotiate an agreement with PAC-RIM to conduct these studies themselves.

  • PAC-RIM to detail any measures to prevent or mitigate any adverse effects of the project on the exercise of Aboriginal rights.
  • PAC-RIM LNG Inc. to conduct a full assessment of the impact of the project on traplines and trappers where they are impacted by the project.
  • PAC-RIM to detail any measures proposed in cases (e.g. compensation) where traplines are impacted and Wet'suwet'en abilities for trapping interfered with.
  • PAC-RIM to inform the OWHC of any agreements reached with any First Nations whose land claim overlaps with the OWHC's and, to provide details of such agreements at the OWHC' s resquest, unless such ageements specifically do not allow for sharing of the details of the agrement.

Input of the Allied Tsimshian Tribes (Project Committee 1/19/1996)

First Nations should be part of the decision-making when it comes to the identification of traditional sites. When there is an archaeological site in a logging area, we send someone along with the archaeologist. We want a proper negotiation with regard to the terms for a trespass on First Nation land. Concerns include: employment and training, effects of tanker traffic on sea food gathering, and the potential of spills.

Input of the Kitselas Band Council

The Kitselas Band wishes to state for the record that the pipeline crosses on land that is part of its on-going treaty negotiations and it is not, therefore, prepared to approve any new developments within its traditional territories until such time as Interim Protection Measures are in place and/or the treaty process has been concluded for the Kitselas Indian Band.

Input of the Ministry of Forests (MOF)

PAC-RIM will need to identify the existence of Aboriginal practices in and around the pipeline which may give rise to Aboriginal rights and determine the effect of their activities on the exercise of those rights. Where an infringement of an Aboriginal right is likely, PAC-RIM would have to find ways to accommodate that right. Any permits issued by the ministry will contain terms to ensure that this accommodation takes place.

Input of Health and Welfare Canada

Concerns include the chemical and/or bacteriological contamination of traditional foods through the use of herbicides for ROW maintenance, the discharge of sewage from construction camps and operational facilities, discharge of hydrostatic testing water contaminated with petroleum products, loss of liquid product to the environment, spills of fuel or other chemicals used in the construction and operation of the facilities, deposition of combustion products on land and water.

In addition to concerns related to the actual consumption of traditional foods, there may also be indirect changes in diet resulting from the perception that traditional foods are contaminated. These changes may be detrimental to the nutrition, culture, and economics of a community which has previously relied on traditional foods.

Finally, the loss of access to traditional foods and medicines through the avoidance of the area by wildlife or elimination of the plants through clearing or herbicide use is a concern. The duration and magnitude of this loss is not clear and the consequences may be the same as those associated with avoidance of these foods.

Information Required in Project Report
  • PAC-RIM to make its best efforts to provide baseline data on use and availability of traditional foods and medicines in project area.
  • PAC-RIM to make its best efforts to assess the health impact of these concerns: quantitatively identify the use of traditional foods and medicines by affected First Nations, predict the alterations in the pattern of use which will result from the project, predict the medical, social, cultural and economic consequences of these alterations, and identify the measures which the proponent plans to put in place to mitigate these impacts.
Input of the Ministry of Employment and Investment (MEI)

MEI has a responsibility to protect the interests of First Nations potentially affected by a proposed energy project. MEI is satisfied that PAC-RIM has identified all First Nations potentially affected and is consulting with those First Nations about the project. MEI encourages PAC-RIM to continue those consultation activities to ensure that the general membership of all First Nation groups is made aware of the project and has adequate opportunity to identify interests in relation to the project. When those interests have been identified (which will be certificate-level information), MEI will work as part of the Project Committee to identify how they will be protected by existing legislation. In those cases where existing legislation does not protect interests, MEI will work with the Project Committee to identify means to avoid, mitigate to an acceptable level, or compensate for adverse impacts.

Since MEI has no authority on Indian Reserves it will look to the federal government to comment on its responsibility in relation to any reserve lands that may be affected.

Input of Indian and Northern Affairs Canada (DIAND)

In the event that a CEAA trigger is identified, DIAND is satisfied that the draft specifications will meet the requirements of a Comprehensive Study Report pursuant to CEAA. If there is no CEAA trigger identified, DIAND will not have an active role in the review process unless the affected First Nations request its assistance. The level of DIAND's involvement will be dependent upon its legislative and fiduciary obligations to First Nations.

F. MALFUNCTIONS AND ACCIDENTS

F1 Pipeline and LNG Plant Facilities

Input of the Ministry of Employment and Investment (MEI)

PAC-RIM will be required to provide full information on the natural gas transportation facilities as part of the application for the pipeline that will be submitted pursuant to the Pipeline Act. Pipelines and compressor stations are designed and constructed to the specifications set out in Canadian Standards Association, Oil and Gas Pipeline Systems Z662-94. Also, BC legislation requires plant inspection both during construction and over the operating life of the facility (Permitting requirement). LNG facilities are designed and constructed to the specifications set out in the Canadian Standards Association, Liquefied Natural Gas (LNG) - Production, Storage and Handling Z276-94. MEI will require full details of the proposed plant, including the cryogenic heat exchanger and related equipment for cooling and liquefying the natural gas and the LNG storage tanks as part of the application for the plant that will be submitted to MEI pursuant to the Petroleum and Natural Gas Act. MEI will also wish to see operational and production guarantees for the plant provided by Delta Catalytic. PAC-RIM should identify at the earliest possible time a key contact person for MEI staff to contact regarding technical and engineering matters (Permitting requirement). BC legislation requires plant inspection both during construction and over the operating life of the facility.

Input of the Ministry of Health (MOH)

The proponent will be required to involve the Medical Health Officer or the designate for drinking water supplies, food services, industrial camps, and sewage disposal systems. Detailed information will be required before permits can be considered. Further, the concerned MHO must be notified in the event of spills of hazardous substances or other threats to the public health.

Project Committee (MEI as contact)

Some of the expected adverse impacts arising from this facility relate to accidental spills. The initial plant layout for a LNG plant can reduce the hazard potential of such a facility. Keeping adequate space between storage tanks, combustion sources and occupied buildings can provide a substantial safety buffer in the event of a major spill or accident.

Input of the District of Kitimat

Geotechnical analysis is standard for all port developments and majority of large scale project construction regardless of location. Many coastal areas of B.C. have submarine clay formations, muskeg, and various other sediments that either challenge or cause mitigative design implications in order to meet necessary regulations and building codes. This is not unique and Kitimat would expect current sound geotechnical analysis to be performed as part of construction and location planning. Kitimat is thought not likely to be adversely affected or severely affected from offshore and west coast tsunamis due to the perpendicular orientation of channels leading 98 NM from open ocean to the port.

Input of the Ministry of Environment, Lands and Parks (MELP)

It was noted that electrical power will be supplied by B.C. Hydro. Several large industrial users in the area have reported power outages which result in environmental problems. It is noted that emergency power will be supplied by a gas-turbine-driven generator.

Information Required in Project Report

· PAC-RIM to describe plans for emergency power backup.

Input of the Ministry of Employment and Investment (MEI)

MEI must be satisfied that the proposed project represents a safe use of British Columbia's natural gas resource and is, therefore, concerned with the technical reliability of the project, including risk assessment and emergency response planning.

Input of the Canadian Environmental Assessment Agency

Information Required in Project Report

· Should CEAA be triggered by the project, PAC-RIM will have to meet the requirements that stem from s. 16 (1) (a) "consideration of the environmental effects of malfunctions or accidents that may occur in connection with the project", the scope of which will be determined by the Responsible Authority.

Input of Project Committee (MEI and Environment Canada as contacts)

Risk analysis is the initial step of contingency planning and is required to identify potential problems associated with any given activity and the risk each activity poses to the receiving environment and to human health and safety. Risk is typically defined as the product of the likelihood of a situation occurring (frequency) and the consequences of such an occurrence (impact).

Information Required in Project Report

· PAC-RIM to conduct a public safety and risk assessment study/analysis for the pipeline, the LNG plant and facilities and the marine vessel transport routes within Canadian waters. This will require:

- Information on populated areas and nearby industry (i.e. distances, numbers, etc.).

  • Seismic mapping and assessment of earthquake risks.
  • Geotechnical analyses for the LNG site and wharf
  • Consideration of lightning strikes and how the risk is dealt with.
  • Information on maximum wave heights (needed to properly design the wharf facility).
  • Mapping of the near-shore areas in order to determine the nature of the

sediments (implications on the wharf design).

  • Assessment of relative hazard of shipping approaches and potential for encounters with fishing vessels and other marine traffic.
  • Tectonic and geological mapping of the pipeline ROW and the facility/ wharf.
  • Geotechnical concerns regarding underwater mudslides and resultant waves.
  • Identification and availability of emergency anchorages.
  • Potential for shipping delays and consequences (e.g. on storage facilities).
  • Assessment of impacts of snow, wind, and fog on marine vessel transport and information on, and assessment of, the effectiveness of any mitigation measures planned to reduce risks (i.e. navigational aids, tugs, radar control).

· The risk assessment should include an assessment of the potential for damage to migratory bird populations due to an LNG spill during loading(CWS).

  • The risk assessment should provide a comparative analysis of the two sites.
  • The risk assessment should include assessment of the combined risks of the PNG and PAC-RIM pipelines where the two pipelines are routed in close proximity (MOH) and the proposed emergency response plan (MEI).
  • The risk assessment should provide information on the history of accidents and malfunctions of LNG plants (using similar design and technology), pipelines, and LNG marine vessels including the number and types of injury, period of risk, industry averages, and accidents caused by employee error and indicate how it plans to address such problems (including plans designed to reduce employee error) and keep industrial accidents to a minimum. A literature search and polling of experience from similar facilities should be conducted to validate the assumption that gas spills (which generate a vapour) are the principle expected impacts from this facility.

Input of Health and Welfare Canada, Department of Fisheries and Oceans, Allied Tsimshian Tribes, Ministry of Environment, Lands and Parks), the Project Committee (MEI as contact)

Reference is made to containment capability for the LNG storage tank facility. The British Columbia Fire Code (Section 4.3.7.3(1)) states that Where a diked area contains only one storage tank, the diked area shall be of sufficient size to contain a volume of liquid at least 10 per cent greater than the volume of the tank. Under a U.S. Department of Transportation rule (49 CFR 193), low and flat dikes used around LNG storage tanks are required to contain 150 percent of the storage tank capacity. These rules may both apply to the entire facility.

Information Required in Project Report

· PAC-RIM to describe and assess the potential effects and proposed mitigation for impacts of spills, including the potential effects of:

- spills upon sea food gathering and fishing (Allied Tsimshian Tribes).

  • spills of hazardous materials, or any materials that pose a risk to the environment.
  • water contamination through hydrostatic testing or by petroleum products.
  • spills from storage tanks and resulant vaapour clouds.

· PAC-RIM to outline its spill response (information on capability and the type of equipment available) and mitigation plans.

  • PAC-RIM to outline plans for spill control (from loading arm, storage tank leak or rupture, and loading pipe leak or rupture), spill detection and containment measures (critical in determining if the LNG plant provides a moderate or non significant risk to adjoining populations and resources).
  • PAC-RIM to outline plans or standard industry practices for fracture resistance and appropriate testing of the pipeline.
  • PAC-RIM to outline Contingency plans:

- for the compressor stations and the entire pipeline.

  • that discuss fuel handling protocols that will be used during construction activities. Hazardous materials should be stored and handled according to procedures developed as part of a spill contingency plan (MELP).
  • for the LNG Plant - spill containment design, automated spill detection

equipment, and the subsequent site specific containment/contingency

plans will have to be developed (Project Committee - MEI as contact).

- PAC-RIM to ensure that an emergency response plan is developed to meet or exceed the requirements of "CAN/CSA-Z731-M91 Emergency Planning for Industry." This is also required as part of an application for pipelines and facilities under the Pipeline Act and the Petroleum and Natural Gas Act.

Input of Ministry of Health (MOH)

Disaster planning and operational safety issues should be addressed to the satisfaction of the concerned MHO's (or their designates) and the local EMOs.

Information Required In Project Report

· PAC-RIM must develop worst case scenarios involving spills of LNG at the loading facility, at the plant, and along the pipeline, taking into consideration any mitigation and prevention measures planned, and an assessment of their effectiveness. These scenarios must be considered in a comprehensive risk assessment, which must include calculations of possible energy release and consequences such as blast and water displacement. If these are found to be significant, further modeling must be done to predict the final consequences to any inhabited areas or neighbouring installations, even if the estimated probability of occurrence is small. The risk assessment to include a consideration of factors which might cause spills (e.g. seismic and geo-technical).

F2 Marine Vessel Traffic Management

Input of the Allied Tsimshian Tribes

Concern about the potential impacts of marine vessel traffic upon sea food gathering and fishing.

Input of the Ministry of Environment, Lands and Parks (MELP)
Input of the Canadian Coast Guard

The Canadian Coast Guard has a process entitled TERMPOL (Technical Review Process to Safeguard the Environment from Pollution and to Ensure the Safe Development and Operation of Marine Terminal Systems and Transportation Sites). This is a non-mandatory process used in determining the need for making or revising regulations, or for implementing special precautionary measures that may affect a ship's operation within a particular marine terminal system or transhipment site. Implementation of a TERMPOL Report's recommendations is the prerogative of applicable agencies performing regulatory functions or of the proponent.

The purpose of the TERMPOL review is to objectively appraise operational ship safety, route safety, management, and environmental concerns associated with the location, construction, and subsequent operation of a marine terminal system. The appraisal enables an inter-departmental committee to identify potential problems and to recommend appropriate ameliorative measures.

The TERMPOL can be initiated by either the CCG, the proponent or through a recommendation by the standing committee which considers applications under the Navigable Waters Protection Act and can be done concurrently with the environmental assessment.

TERMPOL Studies and surveys include consideration of the following:

A TERMPOL assessment is managed by the Ship Safety Branch of the CCG and includes multi-agency representation as well as the proponent.

Information Required in Project Report

· PAC-RIM to either describe and assess the potential effects of vessel management and safety (including assessments of operational ship safety, route safety, management, and environmental concerns associated with the location, construction, and subsequent operation of a marine terminal system - also see details in risk assessment above ) and any mitigation proposed, OR to apply for a TERMPOL assessment.

G. CUMULATIVE EFFECTS

The B.C. Environmental Assessment Act [s. 22 (j), Matters to be included in project report], references "data necessary or useful to enable the assessment of the probable cumulative effects of the project." However, the Canadian Environmental Assessment Act [(s. 16 (1) (a)] does require such assessments for Comprehensive Studies when CEAA is triggered.

Input of the Canadian Environmental Assessment Agency

CEAA requires information as noted below and CEAA has developed a Reference Guide for the Canadian Environmental Assessment Act - Addressing Cumulative Effects (November 1994) in which cumulative effects are defined as "The effect on the environment which results from effects of a project when combined with those of other past, existing and imminent project and activities. These occur over a certain period of time and distance." It suggests that the assessment of cumulative effects must consider:

Information Required in Project Report

· Should CEAA be triggered by the project, PAC-RIM will have to meet the above requirements that stem from s. 16 (1) (a) "consideration of any cumulative environmental effects that are likely to result from the project in combination with other projects or activities that have been or will be carried out" the scope of which will be determined by the Responsible Authority.

Input of the Office of the Wet'suwet'en Hereditary Chiefs (OWHC)

The OWHC is concerned with the cumulative effects of an additional pipeline within Wet'suwet'en traditional territories [see Reporting Requirements under section D (OWHC)].

Input of the Ministry of Environment, Lands and Parks (MELP)

Information Required in Project Report

· Baseline monitoring of the air and water receiving environments must be adequate to determine the environmental acceptability of proposed loading from the PAC-RIM project.

Input of the Department of Fisheries and Oceans
Information Required in Project Report

· If CEAA is triggered, PAC-RIM to assess the potential for cumulative effects to the fisheries resources in the Skeena River and its tributaries and the Fraser River and its tributaries, as a result of the pipeline construction and the stream crossings involved.

H. OTHER CEAA REQUIREMENTS

H.1 Assessment Of Alternatives

Input of the Canadian Environmental Assessment Agency

Under CEAA, the consideration of the alternative means of carrying out the project and the selection criteria used to identify the preferred alternatives must include environmental factors. The information going into that decision and the decision-making process should be documented in the Project Report. Discussion of alternative means includes not only alternative sites and routes, but also alternative methods for construction, operation and mitigation.

Information Required in Project Report

· Should CEAA be triggered by the project, PAC-RIM will have to meet the requirements that stem from s. 16 (2) (b) consideration of "alternative means of carrying out the project that are technically and economically feasible and the environmental effects of any such alternative means" the scope of which will be determined by the Responsible Authority.

Input of Environment Canada
Input of the Ministry of Environment, Lands and Parks (MELP)
Information Required in Project Report
  • The proponent should compare the environmental, economic, health, cultural, heritage and social impacts (including a quantitative comparison on wildlife use and any disturbed contaminated sediments) of the two LNG plant sites (MELP, Environment Canada). There should be sufficient environmental data and analysis related to the two port alternatives to allow a meaningful comparison of environmental acceptability.
  • PAC-RIM to review previous port evaluations for similar projects, and discuss the advantages and disadvantages of Prince Rupert and Kitimat (Bish Cove) with respect to other locations described in those reports (MELP).

H.2 Follow up and Environmental Monitoring

Input of the Canadian Environmental Assessment Agency

The Report should clearly define the objectives of the follow-up program, provide the elements of the program, and specify who is responsible for financing and carrying out the follow-up program to ensure that feedback occurs and that any necessary remedial actions are taken when appropriate.

Information Required in Project Report

· Should CEAA be triggered by the project, PAC-RIM will have to meet the requirements that stem from . 16 (2) (c) consideration of "the need for, and the requirements of, any follow-up program in respect of the project" the scope of which will be determined by the Responsible Authority.

Input of the Ministry of Environment, Lands and Parks (MELP)

MELP requires a commitment from the proponent to provide environmental supervision during construction of the pipeline, LNG facilities/ marine terminal construction and related infrastructure, such as service roads, powerlines which has sufficient independence to stop work; and any subsequent mitigation/compensation measures determined to be necessary as part of the review of the project. The environmental supervisors' function is to ensure that impacts are avoided or mitigated by whatever means, including the authority to stop work. MELP and other permitting agencies require a full description of the environmental supervisors anticipated qualifications, scope of work and reporting relationship with government and the proponent. The cost associated with the environmental supervision and monitoring program, to be borne by the proponent, reflects the requirement for an adequate level of supervision and monitoring as determined by key permitting agencies, in consultation with the proponent.

Input of the Department of Fisheries and Oceans (DFO)

DFO believes environmental monitoring must be done by a person (s) who has the authority to stop work that is not conforming to agreed to and acceptable practices. The reporting structure for the monitor is important - need to ensure that they have sufficient authority to stop bad practices and environmental damage when they encounter it, and free them from being just other company employees. Reporting to the Construction Manager or Operating Manager alone does not satisfy this requirement. DFO needs assurance that the monitor reports any problems encountered to them promptly and that they are involved in developing the terms of reference that the monitor is working under. The CWS strongly supports the requirements of MELP and DFO.

Information Required In Project Report
  • PAC-RIM to include commitment for environmental monitoring by supervisor/monitors employed by PAC-RIM.
  • PAC-RIM to provide a full description of: the supervisor/monitors anticipated qualifications; indicating how these supervisor/monitors will have the independence and authority to stop bad practices and environmental damage when they encounter it; and reporting relationship with government and the proponent (PAC-RIM to indicate how these supervisor/monitors will report promptly to MELP and DFO on any problems encountered).
  • DFO and MELP should be consulted on the terms of reference for the position.
Input of Environment Canada
Information Required in Project Report

· On the basis of baseline surveys (presence, relative abundance and habitat use) indicator species should be selected as representative species for environmental monitoring in a follow up program.

H. 3 Capacity of Renewable Resources

Input of the Canadian Environmental Assessment Agency

Assessment of the capacity of renewable resources/sustainable-use effects should address those environmental effects as defined in the CEAA, and only those renewable resources likely to be affected in a significant way by the project. The temporal and geographic boundaries and scales used in the assessment of the capacity of renewable resources should be specified. The significance of each of the effects identified should be provided.

Information Required in Project Report

· Should CEAA be triggered by the project, PAC-RIM will have to meet the requirements that stem from s. 16 (2) (d) consideration of "the capacity of renewable resources that are likely to be significantly affected by the project to meet the needs of the present and those of the future" the scope of which will be determined by the Responsible Authority.

I. DISMANTLING AND ABANDONMENT

Section 29 (2) of the Reviewable Project Regulation of the Act, specifically excludes the review of the dismantling and abandonment phases of transmission pipelines.

Input of the Canadian Environmental Assessment Agency

Information Required in Project Report

· CEAA section 15(3) requires the assessment to consider the environmental effects of all project activities associated with the construction, operation, decommissioning or abandonment of the project.

Input of Ministry of Employment and Investment

MEI has requirements for reclamation and abandonment in its Drilling and Production Regulation, s.51 and s. 8 and 9 of the Pipeline Act. MEI recommends that reclamation and abandonment should be required according to the requirements in place at the time reclamation or abandonment is required.

Input of Prince Rupert Port Corporation

PRPC feels that it would be unproductive and premature to require detailed

planning for these aspects of the LNG project at this time. PAC-RIM has clearly indicated that although the project has a 20 year lifespan for financial planning purposes, its probable working lifespan would be longer than this, and that it intends to practice environmental stewardship for the entire working life of the project. A generic formula requiring PAC-RIM to either return the site to its original condition or leave it in a condition acceptable to PRPC is built into all of our standard leases if the plant comes to Prince Rupert. Based on past experience, twenty years from now the " state of the art" in environmental reclamation is likely to progress far beyond anything we might mandate today.

J. REQUIREMENTS TO SATISFY THE PRINCE RUPERT PORT CORPORATION'S ENVIRONMENTAL APPRAISAL DOCUMENT

The Prince Rupert Port Corporation has jurisdiction for conducting environmental assessments and making approvals on projects on the Port's lands. One of the sites being considered by PAC-RIM, Ridley Island, is so situated. The Port Corporation has agreed to informally harmonize its approval process with this review so that one process will satisfy the information requirements of all jurisdictions. The information requirements of the Port Corporation's Environmental Assessment Document have been incorporated into these specification. But for greater certainty, these requirements are included here:

Project Description: general description and justification; reasons behind choice of site; infrastructure and related equipment; presentation and schedule of implementation; construction work, including labour force and supplies; technological aspects and characteristic techniques of the project, and their qualification.

The existing environment: atmospheric - air quality and noise; land - flora and fauna; marine - aquatic resources; fresh and salt water, especially the municipal water supply; human - social, economic, cultural and health; municipal environment and transportation.

Environment at Completion of the proposal; impingement and mitigation, either physical, biological, socieconomic: raw materials used and finished products; transportation of raw materials and finished products; gaseous by-products and residual by-products; treatment and disposal of used water; residual solids and other wastes; analysis of the risk of accidents; the attitude of the public; knowledge gaps; results of public consultations.

Appropriate mitigation may be achieved through - best available technology, operational practices or management plans.

Residuals: impact if proposal proceeds, impact if it does not proceed, best compensatory package, recommended monitoring activities, environmental follow up/auditing and potential avenues of adjustment, any alternative means of carrying out the proposal that are technically and economically feasible.

APPENDIX 1

PAC-RIM PROJECT COMMITTEE

RESPONSES

TO

VIEWS EXPRESSED AND ISSUES IDENTIFIED BY THE PUBLIC

WITH RESPECT TO

THE PROPOSED PAC-RIM LNG PROJECT

PREAMBLE

This Appendix to the final Project Report Specifications identifies public views and presents the committee's responses. In its responses to individual issues, the committee indicates whether or not it considers them to be relevant to the assessment of the effects of the project, and whether or not it intends to pursue them during the Project Report review stage of the environmental assessment (EA) process.

In principle, there are four possible project committee responses to the views expressed and the issues raised by the public:

The public submissions received by the EA Office commenting on the proponent's application documentation and the Draft Project Report Specifications and comments received by PAC-RIM during their consultations have been analyzed.

There has been no attempt to substantively revise or reword or correct (where inaccurate) the manner in which these issues have been represented by the public. As would be expected, for some issues, individual representations conflict with one another.

In developing its responses, the Project Committee has relied heavily on the expertise of its members and other government agency participants in the review of the PAC-RIM LNG project, and where warranted, has presented its responses with reference to current public policy expectations.

NOTE: S - indicates comments on Draft Project Report Specifications

A. PIPELINE - ENVIRONMENTAL, RESOURCE MANAGEMENT AND TECHNICAL ISSUES

1. General

b) Thorough analysis of the potential impact of the route from Telkwa to Highway 37, including consultation with affected individuals should be done.

Potential impact of the pipeline route will be studied in detail as part of the Project Report. Issues regarding the impact of the proposed routing have also been raised by provincial and federal agencies.

Both the Draft Project Report Specs as well as the Project Report are subject to public review and the proponent is also required to report on its consultations. The Environmental Assessment Act requires that a Project Report describe the existing environmental, economic, social, cultural, heritage and health characteristics and conditions that may be affected by the project.

a) We do not consider that the Application has identified the significant potential effects of, and issues raised by, the PAC-RIM LNG project.

The Project Report will require that the proponent also address the additional issues that have been raised through the public and agency comments.

PAC-RIM LNG Inc. will be expected to provide sufficient information in the Project Report to allow proper determination of whether the potential impacts identified in the application are significant or not significant.

a) PAC-RIM's objective is to identify the potential impacts of the project on Value Environmental Components (VEC), and to develop an appropriate mitigation and monitoring strategy. The principal here should be the intention of avoiding impact and minimizing risk, not monitoring it.

One purpose of the Environmental Assessment Act is to prevent or mitigate adverse effects of reviewable projects. PAC-RIM will be expected to support all assessment of project impacts with suitable baseline data. In the Project Report, PAC-RIM LNG Inc. will be expected to identify measures that it intends to carry out to prevent or mitigate adverse effects of the project (Section 22 & 23 of the Act).

a) The repetitious chorus of..."the potential impact is rated insignificant"...across a range of VEC's. This work must be re-visited with a

more reasoned disciplined and a respect for the land and for the people who live here.

The CEAA requires the determination of the significance of impacts. However, some members of the Project Committee are concerned about the definitions used by PAC-RIM to determine significance and PAC-RIM is required to consult with agencies to arrive at acceptable definitions (see section 2.4).

a) What about PAS areas and other land-use designations requiring sensitivity of operations as proposed by the LRMP tables throughout the pathway of the pipeline and compressor stations, including the Stuart River crossing?

PAC-RIM is not allowed to go through already established Protected Areas unless provision was made for such use when those areas were established. PAC-RIM will need to obtain information on protected areas and sensitive sites in order to determine the most appropriate route selection for the pipeline. With regard to the issue of existing and proposed LRMPs, the Project Committee will review the project on the basis of the current land use status. However, if there are new LRMPs created before the end of the review process, they will have to be taken into consideration.

a) Lack of information on species potentially impacted by pipeline construction. Preliminary environmental assessment of potential impacts on various taxa that may occur in different sections of the pipeline route appear to be quite insufficient. It is acknowledged in the application that specific information is lacking and yet the impacts of the project on the VECs are assumed to be insignificant. Information is required at this stage for a proper review of environmental impacts.

The necessary information will be provided as part of the Project Report.

a) S The Zymoetz Watershed Committee is developing an access management plan and coordination with pipeline construction is necessary.

This Committee should contact the proponent if it has information to provide that will assist in pipeline route selection.

a) S There needs to be better communication between the EAO and groups like the Kalum South LRMP process and local watershed renewal projects.

PAC-RIM is not allowed to go through already established Protected Areas unless provision was made for such use when those areas were established. PAC-RIM will need to obtain information on protected areas and sensitive sites in order to determine the most appropriate route selection for the pipeline. With regard to the issue of existing and proposed LRMPs, the Project Committee will review the project on the basis of the current land use status. However, if there are new LRMPs created before the end of the review process, they will have to be taken into consideration.

a) S LRMP planning groups must be given a chance to review the project and bring to the Project Committee's attention any sensitive areas to be avoided.

See above.

a) S The Draft Project Report Specifications state (p. x) that the Environmental Management Plan will be a life of the project document. Does the EMP extend into a phase down of the project and are restorative measures ensured? Do bonds need to be placed?

PAC-RIM has indicated that its EMP will be in place for the life of the project and will include procedures to address decommissioning of the facilities. The Reviewable Project Regulation of the Environmental Assessment Act specifically excludes the review of dismantling and abandonment of transmission pipelines. Bonding may be required for some aspects of the project.

a) S How will long-term monitoring of environmental impacts occur?

Monitoring will occur during and after construction and will be addressed in the Project Report (see section H.2).

a) S There is a need for public involvement in pipeline route selection. Local knowledge can be a valuable asset.

PAC-RIM has conducted extensive consultations at the Application review stage, and will be required to conduct further consultations to prepare its Project Report. The Project Report Specifications will include certain specific requirements for additional consultation with concerned stakeholders.

a) S Every potential pipeline route should be thoroughly examined by the proponent and commented upon by environmental and conservation organizations, tourism businesses, the forest industry, regional districts, First Nations and other concerned citizens and then evaluated by the Environmental Assessment Office as to the most favorable route.

The Project Report Specifications contain information requirements designed to assure that the pipeline route selected has been thoroughly assessed for all impacts. The Environmental Assessment Act provides the opportunity for the public review of the Project Report once it is submitted by PAC-RIM.

a) S All decisions must be carefully weighed and time must not force the EAO to make rushed and unwise decisions that unfairly favour the proponent.

The Project Report will be screened to ensure that it fulfills the requirements contained in these Specifications. The Project Committee will review the Project Report taking into consideration its role as described in section 10 of the Act (provide expertise, advice, analysis and recommendations and to analyze and advise as to the potential effects and the prevention or mitigation of adverse effects. The Act also requires that the review be timely and section 15 of the Timelines Regulation specifies a time period of 70 days following the public comment period on the Project Report to make recommendations to the ministers.

a) S The Draft Project Report Specifications are unclear. Some of the specifications requested by agencies are bulleted and other are buried in text.

This has been corrected in the Final Specifications

a) S There is a need for a comprehensive planning exercise to decide on the most cost-effective and environmentally sound location for the LNG plant and the pipeline route.

This is one purpose of the EA review process.

a) S Serious consideration should be given to the pipeline route following Highway 16 and using the highway right of way for the pipeline route and at the same time providing natural gas for the Hazeltons.

Pacific Northern Gas (PNG) has previously investigated the potential for providing natural gas to the Hazeltons and surrounding area and has found the required gas extension to be uneconomic. The proposed PAC-RIM pipeline between Summit Lake and Terrace will follow the PNG route through the Telkwa Pass. Therefore, regardless of which company served the Hazeltons, a 50 mile lateral from the main transmission right-of -way would be required. A detailed study done in 1990-1991 determined that the cost of the lateral line would be approximately $10.5 million, an amount which would not be supported by project revenues from the Hazeltons and Moricetown. PNG applied for Provincial Gas Extension Program funding in 1991/92 to cover the financial shortfall and the government rejected the application.

a) S The proposed pipeline should include a gas line to the Hazeltons.

See above.

a) S Would it not make more sense to have one large pipeline to service PNG and PAC-RIM customers?

This is an issue beyond the scope of the review.

1. Water Quality and Stream Crossings

a) In the upper reaches of the Zymoetz, especially around Red Canyon and Sandstone Creeks, the soil type is very unstable. Disturbances by logging, road or pipeline building activities could result in an environmental catastrophe.

PAC-RIM LNG Inc. will be required to comply with DFO and MELP standards for the identification, design and implementation of any stream crossings required for the project.

a) How will PAC-RIM LNG Inc. be controlling sedimentation into the various creeks and the two crossings of the Salmon river?

See 2a above.

a) Previous pipeline projects have contributed to the degradation of the water quality of the Zymoetz river. This has happened through the construction phase and impact of heavy equipment, trees cut down for the ROW, and digging up the river bed for pipeline crossings.

The impact of earlier projects has been identified by both PAC-RIM and review agencies and will be an important consideration in route selection. The evaluation of cumulative effects and consideration of alternatives are matters that would be required under CEAA if it should be triggered, with the federal Responsible Authority determining the scope of study for those issues.

a) Aerial crossings are unsightly and detract from the natural beauty of the River canyons.

Regulatory agencies will require PAC-RIM LNG Inc. to select the most appropriate form of stream crossing based on a detailed assessment of the potential impact of each method that may be considered for stream crossings such as aerial crossings, directional drilling, or conventional crossings.

a) Erosion due to flooding has been a problem in the Zymoetz river and has led to the eventual relocation of the PNG line away from the river bed.

This issue has been identified by MELP and DFO and will be addressed as part of the requirements of the Project Report.

a) How can anyone be assured that the PAC-RIM LNG Inc. pipeline, which will be 2 or 3 times the size of the PNG line, will not cause extensive environmental damage in the Zymoetz River area?

PAC-RIM LNG Inc. is expected to conduct a thorough assessment of the potential impacts of the project and provide this information as part of the Project Report.

a) The Limonite Creek and Zymoetz River valleys are very narrow with almost no room for another 10" diameter pipeline or the much larger PAC-RIM LNG Inc. line.

See 2f above.

a) At best we can expect long term silt loading of the Zymoetz.

The issue of sediment loading has been identified by DFO and MELP and will be addressed as part of the Project Report.

a) S There has already been a lot of disturbance to the Zymoetz Valley from the PNG pipeline maintenance, re-routing and the original construction. The construction of another pipeline will alter and destabilize the valley even further.

The impact of earlier projects has been identified by both PAC-RIM and review agencies and will be an important consideration in route selection.

a) S Unless stream crossings are underground there will be damage. There will be sedimentation, spawning and rearing areas will be altered, and the stream channel and banks will be de-stabilized.

PAC-RIM will be required to describe methods that eliminate the potential for stream impacts, and provide a summary of results of situations where these methods have been used successfully. Agencies will require full details of construction of stream crossings, such as, timing of construction, silt control measures proposed, crossing plans and erosion control measures proposed. Furthermore, based on this review, PAC-RIM is expected to commit to employ methods that have been agreed to by the regulatory agencies or provide justification for alternative measures.

a) Similarly we would object to any loss of fish or fish habitat in the construction of a pipeline along Williams or Trapline Creeks, and the Skeena, Kitimat, Clore or Zymoetz Rivers.

PAC-RIM LNG Inc. will be required to identify a route for the pipeline that minimizes impacts of the pipeline corridor on water quality, aquatic life, wildlife, and human health. Any stream crossing proposed by the company will have to comply with all DFO and MELP standards for method and timing of construction.

a) Will dredging be used as part of the procedure for crossing the Skeena or Salmon Rivers?

PAC-RIM LNG Inc. will be required to comply with DFO and MELP standards for the identification, design and implementation of any stream crossings required for the project.

a) S DFO needs to include the Skeena drainage in its assessment of specifications required for the Project Report.

This is included in the Project Report Specifications.

1. Fish and Wildlife

a) The Zymoetz is a special river and it deserves special status. This was recognized by the Ministry of the Environment in 1990 when after intensive public consultation and review it named the Zymoetz as one of BC Classified Waters. To protect unique fishing opportunities the Zymoetz was labeled Class One waters above Limonite Creek and Class Two waters below. The provincial regulations synopsis states that BC is a favoured fishing destination for anglers from around the world and that a good part of this popularity can be attributed to a group of forty-two highly productive trout streams. These forty-two streams are listed as Classified Waters. In this list the Zymoetz is recorded twice. And furthermore the synopsis identifies five BC rivers as being so outstanding that they are given even more recognition and are labeled Class One Water. Of course the Zymoetz is on this list.

PAC-RIM LNG Inc. will be required to identify a route for the pipeline that minimizes impacts of the pipeline corridor on water quality, aquatic life, wildlife, and human health. Any stream crossing proposed by the company will have to comply with all DFO and MELP standards for method and timing of construction.

a) The Zymoetz River has one of the last healthy summer Steelhead populations left in the world. The great summer run Steelhead rivers are a thing of the past in the States of Idaho, Washington, Oregon, California and in British Columbia south of the Dean River.

See 3a above.

a) S PAC-RIM's route for its pipeline should follow the existing PNG line through the Limonite creek and Copper River sections. This mitigates the need to cross the Copper River and is preferable as the Copper River is an extremely high valued fish river.

See 3a above.

a) S MELP must be consulted about all aquatic values, not just trout.

Ministry of Environment, Lands and Parks information requirements in the Project Report address measures to protect water quality and fish habitat for all aquatic organisms, not just trout.

a) S There should be no further reduction in fishing opportunities as a result of silt loading in the Zymoetz River from construction.

The issue of sediment loading has been identified by DFO and MELP and will be addressed as part of the Project Report

a) S Three variables have not been addressed with regard to loss of fish or loss of fish habitat from pipeline construction: a) habitat structure; b) flow regime and c) energy source.

Activities in and about a stream, such as channelization, would have to be reviewed in terms of the impacts on the flow regime and fish habitat. Protection of fish habitat from pipeline crossings and encroachments is covered off under information requirements in section A3.1.

S There are no windows of opportunity for construction activity in the Zymoetz River because there are either migrating, holding, spawning or rearing salmon, steelhead or resident species throughout its length throughout the year.

The precise conditions at the locations of proposed river crossings must be identified in the Project Report.

a) S The river estuary is a critical habitat for juvenile salmon and baseline data will be required in order to test the assumption that the project will have no adverse effects.

Data has been requested in the Project Report to address this issue.

a) The upper portion of the Zymoetz River above Limonite Creek is designated as a Class I angling river.

This has been addressed in the Project Report Specifications (see section A4).

a) What damage will be done to the wildlife (both flora and fauna) by the pipeline corridors?

Reviewing agencies have identified the need for PAC-RIM LNG Inc. to minimize the impact of the pipeline corridor on water quality, aquatic life, wildlife and human health. PAC-RIM LNG Inc. will be expected to provide adequate data as part of the Project Report to demonstrate that the pipeline route is a route which minimizes the impacts on the environment.

a) The review should include the impacts on wildlife and habitat in north-eastern British Columbia and Alberta.

Environmental issues related to upstream development are beyond the scope of this review but are addressed in other approval processes.

1. Timber Resources

a) A rough estimate of area required for a 600 km. pipeline ROW occupies 10,000 ha which can support approximately 30,000 cubic metres of allowable annual cut. This represents thirty permanent jobs in communities along the way according to a recent study by Price Waterhouse on the value of the forest industry.

The Ministry of Forests has stated that the analysis by PAC-RIM LNG Inc. of the effect of the project on timber resources is sound and will not likely affect the Annual Allowable Cut. PAC-RIM estimates that the area of land needed for the ROW will not be 10,000 ha but rather 1065 ha for the Prince Rupert option and 910 ha for the Kitimat route. The ministry considers the amount of timber that will be removed to be insignificant as that term is used in environmental assessment methodology. However, the ministry is requiring PAC-RIM to report, for the various pipeline routes, on the amount of productive forest land that will be required for the ROW and the timber types and volume of merchantable timber on those lands.

a) Any land withdrawals from the productive forest land base along the pipeline ROW will add to allowable cut pressures already under stress from a number of alienations such as land claims, protected areas and forest practices code restraints.

See 4a above.

a) The project will lead to the withdrawal of land from the timber supply area. Every hectare withdrawn from the working forest will reduce the annual allowable cut by about 2.7 m3 in the Prince George TSA.

See 4a above.

a) Of an additional 18 metre row is required, this would impact 1.8 ha of productive or potentially productive forest land per kilometre along the 507 kilometre length of pipeline. This ROW could impact a total of 912 ha of forest land. Productive forest land is a finite resource, which over time has been reduced in area to accommodate rights of way, highways, urban development parks etc.

See 4a above.

a) We are opposed to any activities that result in permanent reductions to the working forest. SCI strongly recommends that PAC-RIM follow the existing PNG line to the mouth of the Copper River. This minimizes the need to alienate any additional land from the working forest.

See 4a above.

a) The PNG pipeline has been used to allocate the animal unit months to the rancher. If the pipeline area is unavailable for grazing for one or more years the rancher will be forced to put cattle into our cutblocks that have been reforested. Experience has shown that the longer the cattle are in the block, the greater the damage to our seedlings.

PAC-RIM LNG Inc. will provide a detailed construction schedule as part of the Project Report. Construction of the pipeline must comply with all permitting regulations and the Forest Practices Code. PAC-RIM will be required to identify parties impacted by the project and any proposed mitigation measures required (section 2.5). PAC-RIM has also committed to consulting with affected parties to evaluate potential effects and develop appropriate mitigation measures (possibly including fencing and grazing controls}.

a) S It is important to know how much productive forest land base will be removed by the project.

This will be addressed in the Project Report (section A7). PAC-RIM has estimated that approximately 1065 ha of land will be required for the Prince Rupert option and 910 ha for the Kitimat option and that their decommissioning plans include reforestation.

A. LNG FACILITIES, MARINE LOADOUT, TANKERS AND UTILITY CORRIDORS - ENVIRONMENTAL, RESOURCE MANAGEMENT AND TECHNICAL ISSUES

1. Fish

b) The proposed site of the plant at Kitimat threatens Bish Creek and its estuary. Although logging has caused some loss this creek supports populations of Steelhead, Salmon and Cutthroat trout.

PAC-RIM LNG Inc. will be expected to provide specific detail on the design, location and layout of the LNG plant as part of the information included in the Project Report. The potential impacts on fishery values in the area will be addressed as part of the Project Report.

1. Waste Management and Water Quality

a) Will the discharged sea water from the LNG plant degrade habitat for marine life in the area?

The impact of the LNG plant on marine life will be addressed as part of the Project Report in accordance with the DFO guidelines on foreshore impacts of the LNG plant.

a) Where will effluent from the plant be discharged?

PAC-RIM LNG Inc. will provide details as part of the Project Report. MELP requires that this include information on the types of wastes generated at the plant, the plans for storage and disposal of wastes, as well as the potential impact of runoffs from the plant on the water quality and the marine environment.

a) How will the impact of emissions on water quality be monitored over the life of the LNG plant?

PAC-RIM LNG Inc. will outline details of its Environmental Monitoring Plan as part of the Project Report.

a) Will intake water contain byproducts from other industries such as the pulp mill or the City Sewer System?

Existing effluents from other sources will be considered during the assessment of potential effects of project effluents on ambient water quality.

a) What will be the impact on the sea water near the plant in terms of any change in water temperature?

PAC-RIM LNG Inc. states that the net increase in temperature from the use of sea water as coolant will be limited to a change of 0.5 degrees C at a distance of 100 metres from the diffuser pipe outlet. MELP and DFO have identified the cooling process as an issue to be studied in more detail as part of the Project Report. DFO also requires PAC-RIM LNG Inc. provide baseline data in the Project Report to characterize the aquatic life of the area.

a) Will dredging be used to create the port facility?

PAC-RIM LNG Inc. has stated that there is no dredging currently proposed for the marine terminal facility.

a) S More baseline data is needed to determine the impact of any proposed seawater cooling system of an LNG plant at Ridley Island. Currents, thermocline etc. require a permanent buoy monitoring system. Pulp mill and city sewage parameters could be monitored and the cost could be shared with them.

The impacts of cooling water will be studied for both sites as will the impacts of waste management and water quality (section B1). If there is to be discharge from the site, monitoring of the marine environment may be required as part of a waste management discharge permit. The information requirements for monitoring are set out in the Project Report Specifications and include the need to address thermal stratification. Appropriate procedures to measure thermal stratification will be discussed with the proponent. While shared costs for monitoring systems may be feasible, such an option is entirely at the discretion of the proponent and is not required as part of an EA review.

1. Wildlife and Plants

a) S Special attention should be given to baseline data for epiphytes and epifauna on eel grass and bull kelp as these will be most sensitive to changes in chemical and temperature.

This issue depends on the final site selection. Ministry of Environment, Lands and Parks has requested that the proponent look at alternatives to the use of algaecides for control of algae growth in cooling water. If the proponent chooses hypochloride as an algaecide for example, the Ministry is aware of the potential for interactions with organic material. The potential for contamination from chlorinated organics will be taken into consideration in setting water quality objectives and in setting the level of treatment required for discharge of cooling water.

a) How will the port facility be constructed to avoid impacts on marine life, especially from dredging?

PAC-RIM LNG Inc. has stated that there is no dredging currently proposed for the marine terminal facility

1. Air

a) The removal of fossil fuels from the earth's crust represents the quantity of carbon dioxide that will be released into the earth's atmosphere regardless of where on the earth the actual combustion of the fossil fuel takes place. Is the government aware of the impact that this project will have on greenhouse emissions?

This is an issue which falls outside the scope of the review.

a) How will CO2 and hydro carbon emissions be controlled?

Air emissions from the LNG Plant and the compressor stations must be studied in greater detail at the Project Report stage. PAC-RIM LNG Inc. will be expected to provide detailed information on the types of emissions generated by the compressor stations and LNG plant, and identify impacts and mitigation strategies.

a) What will be the influence of the vented gases and carbon dioxide emissions from producing, processing, and transporting such large quantities of natural gas, especially with regard to global warming?

The emissions from the Compressor Stations and LNG plant will be characterized in detail in the Project Report, and their potential impact on air quality assessed. However, it is beyond the scope of the review to assess the impact of these emissions on the phenomenon of global warming.

a) Air pollution from the LNG plant. It is noted that emissions from the LNG plant and marine loading facility will include NOx, CO, CO2, CH4, and VOCs, and that these emissions will contribute incrementally to the emission loading within the existing airshed. It is expected that incremental impacts due to emissions from the project will be within provincial standards, and therefore insignificant, because of the intended design. The application should provide details of the design of emission sources so that these can be assessed by the Ministry of Environment and their comments made available to the public before the review proceeds to the Project Report stage.

This information will be provided as part of the Project Report and reviewed by the Project Committee. MELP, DFO and Environment Canada and Health Canada have provided extensive comments on the issue of emissions from the LNG plant and the loading facility. These comments are available to the public at the Project Registry and the satellite repositories.

A. SOCIO-ECONOMIC AND COMMUNITY ISSUES

1. Cost/Benefit

a) In order for the socio-economic analysis to be reliable, it should be done by independent professionally trained economists and social scientists.

The Project Committee has considered this issue and has decided not to treat this issue any differently than the other issues: i.e., the Project Committee develops the specifications, the company does the study and the Project Committee reviews and assesses the information/ assessment. The public will have the opportunity of reviewing and commenting on the Project Report. Should the socio-economic study, or any other studies, be considered to be inadequate, the Project Committee will determine if further work is required and who should undertake it.

a) What are the economic "incentives" that PAC-RIM is requesting of the Canadian/BC governments?

The project is entirely private sector financed PAC-RIM LNG Inc. has stated that it has no intention of requesting any economic incentives or funding, loans or subsidies, price support, or relaxation of environmental standards.

a) What benefits will British Columbians receive in exchange of these sustainable environmental values? What will local stakeholders receive as compensation?

A cost benefit analysis will be done as part of the Project Report.

a) The application does not make any estimate of the amount of exploration and development that will be necessary to supply an LNG plant with 500 million cubic feet of natural as per day (3.5 million tonnes per year) over a 20 year period. It is reasonable to assume that a contract to provide this amount of gas over this period will require a significant amount of additional exploration and development over what is now occurring. North-eastern BC is already being significantly impacted by oil and gas exploration and development. The cumulative impact of this project could be very serious indeed. No information is given on how much of the gas would come from BC and how much from Alberta, and from where in Alberta.

PAC-RIM LNG Inc. has noted that the project will require an export permit under the National Energy Board Act and an Energy Removal Certificate under the Utilities Commission Act. Sustainability and adequacy of supply of Canadian and B.C. natural gas resources will be addressed through these regulatory approvals processes. Issues pertaining to Canada's gas export policy and the source of gas for this project can be addressed in the NEB process which will include public hearings.

However, information on gas supply will also be included in the Project Report under Purpose/Rationale.

The environmental effects of upstream activities and facilities are addressed through other processes which are described in the Preface to the Project Report Specifications.

a) S Who will determine the cost-benefit of alternative route along Skeena from Smithers to Terrace instead of through Telkwa Pass?

The environmental review process assures that the adverse impacts of whatever route is selected are assessed and addressed.

a) What is the projected revenue over twenty years from the PAC-RIM proposal to British Columbia (royalties, taxes, fees, license dollars) British Columbia. (NEAC) resulting from the pipeline transfer of natural gas and from the LNG plant? What is the projected revenue from the tanker traffic and port facility?

This information will form part of the Project Report. MEI will require that a cost benefit study by PAC-RIM LNG Inc. and the terms of reference for this study are being developed.

a) Do the job opportunities offered by the one LNG Plant balance off the industrial possibilities cheap, available natural gas make achievable?

The cost-benefit information will form part of the Project Report. MEI will requires that a cost benefit study by PAC-RIM LNG Inc. and the terms of reference for this study are being developed.

a) S One important consideration in deciding whether the project should be approved is the returns the public, including local communities, can expect to derive from the export of gas, as well as the social consequences of constructing and operating the pipeline. The party responsible for this assessment must be objective and neutral and the analysis should be completed by professionally trained economists and social scientists.

A cost-benefit analysis will be required (section C1) as part of the Project Report. This will be reviewed by the Project Committee and the public will have the opportunity of commenting on it. If there are issues which arise about the information provided in the analysis, additional information may be required by the Project Committee.

a) If demand for natural gas is increased beyond know reserve capacity because of additional export markets, will political-socio-economic pressures exerted by major oil and gas companies sacrifice ecosystems/wildlife/wilderness to roads, exploration camps, and extraction facilities so that off-shore demand can be met?

Upstream environmental impacts of natural gas developments are reviewed under existing regulatory processes described in the Preface of these Project Report Specifications and are not part of the scope of this review.

a) When we as a society lock ourselves into guaranteeing export volumes of natural gas overseas, are we sacrificing options here at home?

See 1d and 1i above.

a) It is naive to assume that natural gas exports to the Pacific Rim countries can be easily terminated once they begin.

See 1d and 1i above.

a) S It must be possible to estimate how much additional exploration and development will be required to supply the amount of gas that is committed, from which a determination can be made of the kinds of impacts that can be expected.

See 1d and 1i above

a) The National Energy Board estimates an 11 years' natural gas reserve for Western Canada. How accurate is this estimate?

Western Canada's known marketable natural gas reserves are estimated at 67 Tcf for a total of 178 Tcf. (Source: National Energy Board, "Canadian Energy Supply and Demand 1993-2010", December 1994, Fig. A6-13).

British Columbia's total marketable gas reserves are estimated at between 45 and 60Tcf. This estimate includes cumulative production, established remaining and discovered reserves, and ultimate, technical potential. This information was developed using the report "Hydrocarbon and By-Product Reserves in British Columbia", dated December 31, 1994, a report by the Geological Survey of Canada entitled "Gas Resources of North East British Columbia", and internal MEI information.

a) What are the known reserves of natural gas (NG) in western Canada?

See 1d and 1m above.

a) If the above estimate is correct, what will be the effect on areas which rely on existing wells for their energy needs?

See 1d and 1m above.

The National Energy Board will require PAC-RIM LNG Inc. to assess the impact of the proposed export on Canadian energy and natural gas markets to ensure Canadians have no difficulty in meeting their energy needs at fair market prices.

a) In order to determine whether this project is in the public interest the public needs to know what Canada's reserves of natural gas are, and what the implications are for Canada's future needs.

See 1d and 1i and 1m above.

a) What are the projected industrial/domestic requirements for this alternative fuel, NG, over the next 50 years?

See 1d and 1i and 1m above.

a) If known reserves are not adequate to meet projected Canadian needs, where are the probable areas in British Columbia which may provide additional NG production? maps available? exploration/findings?

See 1d and 1i and 1m above.

a) Will guaranteeing off-shore markets for our non-renewable fuels continue to export manufacturing infrastructure and jobs to the Pacific Rim at the same moments in time that new industry and jobs are needed here?

A cost-benefit analysis will be done as part of the Project Report.

a) The issue of whether or not it is appropriate for Canada to be exporting natural gas to Pacific Rim countries is one which must be addressed in the course of the review. The implications need to be carefully studied and considered before any approval certificate is granted to PAC-RIM.

PAC-RIM LNG Inc. must obtain approval from the National Energy Board, which regulates natural gas exports from Canada, before any export can commence. See 1d and 1k and 1m above.

a) S The long-term export of power is a policy issue with serious implications. The first step in the review of PAC-RIM's proposal should be an application to the NEB, to address the export question through an NEB review, with public hearings, to determine whether the proposed export is in the public interest.

Sustainability and adequacy of supply of Canadian and B.C. natural gas resources will be addressed through the regulatory approvals processes. However, the Project Report will include, for information purposes, much of the information related to gas supply and transportation that will be included in both the NEB application and the ERC application to MEI (section 2.2).

a) SIt is not clear whether other agencies besides Mines have a say in the issuance of an Energy Removal Certificate. The application for that certificate should be part of this review process.

Information on adequacy of gas supplies will be provided as part of the review although the determination of the adequacy is part of the ERC process. (see section 2.2)

a) SThe application for an Export License needs to made to the National Energy Board prior to a comprehensive pipeline review.

PAC-RIM LNG Inc. has indicated that it intends to file an application for an Export License prior to completion of the EA review. See also

1u above.

1. Employment and Local Socio-Economic Benefits

a) During the construction period, construction workers will move from one location to another as construction proceeds. Situation of this kind can be socially destabilizing to both workers and the communities impacted. The assessment needs to identify anticipated problems and how they can be dealt with.

This will be addressed in the Project Report (section C).

a) During the construction period local communities may experience a boom and when construction phase is over the economic conditions in those communities could deteriorate. The assessment needs to identify these kinds of problems and how they can be dealt with.

Socio-economic impacts will be addressed in the Project Report (section C).

a) What will be the impact on communities of large, temporary influxes of people?

The impact of construction crews on communities will be assessed. PAC-RIM LNG Inc. is expected to provide details on the plans to accommodate and manage construction crews as part of the Project Report.

a) Will pipeline construction result in boom and then bust for communities along the route?

Detailed information on the impact of the project on employment will be provided as part of the Project Report.

a) How much of the revenue derived from the project will remain in British Columbia?

Detailed statements of revenue will be included in the Project Report. Ministry of Employment and Investment requires that a cost-benefit study be completed as part of the requirements of the Project Report.

a) Will there be enough specially-trained personnel, such as staff, crew and tradespeople, and where will they come from?

The Project Committee agrees that the issue of local employment opportunities is of great importance and the Project Report should describe more fully PAC-RIM LNG Inc.'s local hire policy.

a) Need to assess the potential long-term negative impact on the sport fishing business and tourism business in the Terrace area that may be impacted by degradation of the Zymoetz river due to pipeline crossings.

PAC-RIM LNG Inc. has committed to provide a comprehensive evaluation of the potential project effects in the Project Report. The environmental, social, economic, health, heritage and cultural impacts of a reviewable project are all assessed as part of the Project Report.

a) S Local guides/outfitters derive an important part of their income from angling/guiding in the Zymoetz watershed between July 1 and November 1.

PAC-RIM will be expected to address this issue in the Project Report (section 2.5).

a) S Construction should be timed to avoid peak fishing times and avoid adverse impact on angling guiding businesses

This will be addressed in the Project Report (section A6 and C7).

1. Transportation and Access

a) What assurance will be given by PAC-RIM LNG Inc. that any construction will include retaining our existing access and that future access crossings will be permitted?

The creation and management of access roads has been identified as an issue by the Project Committee. Access on an existing private road is negotiated between the owner and the company and PAC-RIM LNG will negotiate the terms of use with road and/or landowner. Any pipeline crossings must comply with safety and engineering requirements before a certificate to construct the pipeline crossing would be issued.

a) What assurance is there that PAC-RIM LNG Inc. will pay its fair share of the costs of road maintenance for use of the access roads during the construction phase?

PAC-Rim will negotiate the terms of use with road and/or landowner.

a) Impact of increased access, access proposed must be mapped and evaluated particularly construction of any permanent roads.

This will be addressed as part of the Project Report.

1. Public Health and Safety

a) What standards will govern the requirement that the LNG Plant be located at a certain distance from a settlement area?

There will be extensive requirements for additional information in the Project Report with regard to public health and safety and accidents and malfunctions. The proponent will be expected to provide details on any potential for major explosions, leaks, spillage, accidents and plans for how these will be addressed as part of emergency safety measures. The MOH also requires that the proponent develop a disaster management plan that includes careful assessment for the possible impact of a major leak and gas explosion.

LNG plants are designed and constructed in British Columbia to the specifications set out in the Canadian Standards Association LNG - Production, Storage and Handling Standard Z276-94. This code ensures the plant components are built and operated in a safe and reliable manner. British Columbia provincial legislation requires plant inspection both during construction and over the operating life of the facility.

a) What measures will be taken to protect the environment and people from the formation of a gas cloud that could travel down wind and ignite?

PAC-RIM LNG Inc. will be required to provide full details of risk assessment and the proposed emergency response plan in the Project Report. Emergency response plans must be developed by operators of oil and gas related facilities of British Columbia. These plans are reviewed by MEI and must be consistent with the specifications set out in the Canadian Standards Association Emergency Planning for industry CAN/CSA-Z731-95. These plans ensure that the impacts of accidents are minimized and disasters prevented.

The Workers' Compensation Board of British Columbia publishes "Industrial Health and Safety Regulations" which specifically address the Petroleum and Natural Gas Exploration, Drilling, Production and Service Industry. Compliance with these regulations ensures that work is carried out without undue risk of injury to workers.

a) The hazard of potential major uncontrolled releases of LNG. Proponent should provide detailed information on how it proposes to provide the necessary safeguards against major accidents at the LNG plant.

See 4a and 4b above.

a) What safeguards are there to protect the environment from spills at the LNG plant

See 4a and 4b above.

a) The course of the pipeline crosses several tectonic fault lines which regularly experience seismic activity. What are the chances of pipeline ruptures due to earthquakes and other accidents, such as those which occur during the loading and moving of larger tanker vessels?

See 4a and 4b above.

a) How will safety be assured if tankers are traveling along the Douglas Channel?

This issue will be addressed in the Project Report,

1. Tourism

a) Logging activities, clear cut scars, and pipeline corridors are not viewed favourably by tourists. It would be difficult to consider a river special if we are not careful to log or build corridors in a manner that protects landscapes.

The pipeline ROW will be mapped and described in detail in the Project Report. The impact of other activities such as logging are beyond the scope of this review.

a) S If there are overhead (pipeline) crossings, the scenic beauty of the Zymoetz, Clore, Skeena, Hasiks, Kitimat and Khyex rivers will be compromised.

MELP and DFO will require PAC-RIM to select the most appropriate form of stream crossing based on a detailed assessment of the potential impact of each method that may be considered for stream crossings such as aerial crossings, or directional drilling. Visual impacts will also be assessed (section A6).

a) S Cutting an 18 metre right of way through the Zymoetz Valley will have a negative environmental impact and alter the scenery.

This issue has been identified by MOF and SBTC and will be addressed in the Project Report (section A6).

a) S Pipeline construction in the Zymoetz Valley will create months of unrestricted access. Unpleasant construction noises and debris will be another result of the construction activities.

PAC-RIM will be expected to address these issues in the Project Report and to identify any potential adverse effects of construction, and identify measures to mitigate any adverse impacts.

a) S What consideration has been given to the impact of the project on sport fishing, scenic and tourism values?

The MOF and SBTC have included requirements to address this issue in the Specifications (section A6 and A7). SBTC also requires that the proponent work with tourism operators to document existing tourism business both along the pipeline route and, if applicable, in the vicinity of the processing plant (section 2.5).

a) S There has been a lack of consultation with SBTC about the impact of the project. The Zymoetz Valley and surrounding areas are important tourist areas that should be preserved.

The Ministry of Small Business, Tourism and Culture has provided comments on the Draft Project Report Specifications and is represented on the Project Committee.

A. CUMULATIVE EFFECTS

a) Who will address the potential cumulative effects of twinning the PNG pipeline?

PAC-RIM will be required to address the issue as part of its risk assessment (section F). The scope of, and requirements for, cumulative effects studies will be determined by the federal Responsible Authority if the CEAA is triggered.

APPENDIX 2

OUTLINE OF COMMENTS AND ISSUES

Identified By The Public, Interest Groups, Stakeholders, First Nations And Government Representatives

During

Consultations, Open Houses And Meetings And Discussions With PAC-RIM LNG Inc.

As part of its public consultation program and issues scoping, PAC-RIM LNG Inc. held extensive discussions with the public, stakeholder groups, representatives of First Nations, and provincial, federal and local government representatives. The results of these discussions are detailed in a document prepared by PAC-RIM LNG Inc. called "Summary Report on Public Consultation - Public Review of Stage One Application for a Project Approval Certificate" (December 8, 1995).

The following issues were identified in the course of these discussions. For more detail, please consult the PAC-RIM LNG Inc. report which is available at the EAO Public Registry and satellite repositories.

1 Environmental and Technical Issues

1.1 Creation of new access and management of access routes. Potential impacts of new access, such as poaching, improved access for logging and access to private property

1.2 Loss of windbreak due to clearing for the Right of Way (ROW)

1.3 Rehabilitation of the ROW after construction, use of appropriate seed mixes for restoration, measures to avoid introduction of noxious weeds, aesthetics

1.4 Routing and width of the pipeline ROW

1.5 Noise impact of compressor stations, utilization of heat generated from the stations

1.2 Forestry Impacts

1.2.1 Clearing of the timber from the ROW may amount to 10-15% of the total holdings of some woodlot license holders

1.2.2 Loss of productive forest land, potential impact on managed woodlots, specialty forest products, timber resources, pest control and fire

1.2.3 Loss of trees on private land as a result of clearing for pipeline ROW

1.2.4 Existing and future access requirements

1.3 Agricultural Impacts

1.3.1 Impact on grazing lands from construction and temporary loss of grazing land to the ROW; fences will be needed to prevent cattle from straying to other properties

1.3.2 Interruption of access

1.3.3 Control of noxious weeds

1.4 Water, Fish Impacts

1.4.1 Impact of pipeline on surface water quality, fish habitat and fish populations, particularly the impact of stream crossing on Salmon River, Zymoetz River, Telkwa Pass streams; Stuart River; Skeena River Copper River, Gitnadoix (Class A salmon stream)

1.4.2 Sediment control at Skeena River and Copper River crossings and impact of any increased sedimentation from construction

1.5 Wildlife Impacts

1.5.1 Deer and moose ranges and movement corridors

1.5.2 Noise from compressor stations

1.5.3 Effects of access road to the compressor station near Telkwa (and the pipeline ROW) on wildlife; noise; change in wildlife movement corridors and access (poaching)

1.5.4 Rare frog habitats and rare and endangered frog and toad species may be adversely affected by the pipeline where it crosses ponds

1.5.5 Impact on waterfowl and migratory birds

1.6 Air Impacts

1.6.1 Impact of burning green slash on air quality

1.6.2 Control of emissions from the compressor stations

1.6.3 Effects of emissions on ambient air quality

1.6.4 Greenhouse gas emissions

1.7 Public Health and Safety

1.7.1 Emergency plans to detect leaks in the pipeline and at the LNG plant

1.7.2 Contingency for earthquakes

1.7.3 Fire risk

1.7.4 High pressure pipeline and proximity to the highway

1.7.5 Traffic generated by construction and impact of trucks hauling pipe

1.7.6 Timing of construction to comply with road restrictions in winter

1.7.7 Marine vessel traffic safety

2. LNG Processing Plant, Storage Facility and Marine Loading Facility Issues

2.1 Reclamation of facilities after 20 years

2.2 Impact of tankers on marine traffic and fisheries, water quality and gillnet trawlers

2.3 Infrastructure requirements

3. Socio-economic and Community Issues

3.1 Accommodation requirements for construction crews and impact of construction during tourist season (traffic and accommodation) and facilities for construction crews

3.2 Procurement strategy to maximize benefits to local business

3.3 Opportunities for joint ventures

3.4 General employment opportunities, local hiring policy, and opportunities for training and skills development

3.5 Impact of project on consumptive resource use such as hunting and fishing (moose, deer) - gill netters use Stuart Lake; trapline compensation issues

3.6 Contract opportunities and contracts to manage compressor stations

3.7 Taxation to local communities

3.8 Land acquisition, land use competition

4. First Nation Issues

4.1 Employment opportunities for First Nations

4.2 Loss of traditional herbs and plants from pipeline construction/herbicides

4.3 Impact of project on traditional land and consumptive uses, such as

hunting, fishing, logging, trapping, harvesting (berry picking, medicinal)

5. Other Issues

5.1 Availability of gas reserves and project impact on domestic gas supply

5.2 Supply of gas to local areas

5.3 Avoid LRMP areas, rezoning and land use, PAS

5.4 Cumulative effects of PNG line, PAC-RIM LNG Inc. line, hydro lines and logging in Telkwa pass

5.5 Archaeological and heritage resources

5.6 PAC-RIM LNG Inc. to deal with license holders on a site specific basis

APPENDIX 3

SUMMARY OF REVIEW COMMENTS

MADE ON THE PAC-RIM LNG PROSPECTUS

SUBMITTED UNDER THE ENERGY PROJECT REVIEW PROCESS

June 5,1995

Mr. Wayne R. Stanley

Manager, Government Relations

PAC-RIM LNG Inc.

7th Floor - 1177 - 11th Avenue SW

Calgary, Alberta T2R 1K9

Dear Mr. Stanley:

RE: PAC-RIM LNG INC. (PAC-RIM) LIQUEFIED
______NATURAL GAS PROJECT - PROSPECTUS__

Selected government agencies and other stakeholders have reviewed the prospectus for the Liquefied Natural Gas project. Attached please find a summary of the comments and copies of the original correspondence received to date.

Comments have yet to be received from the:

Ministry of Attorney General: Provincial Emergency Program;

Canadian Coast Guard;

Environment Canada;

City of Terrace;

District of Houston;

Lhiet-Lit'en Nation;

Office of Wet'suwet'en Hereditary Chiefs; and

The following agencies indicated that they have no comments at this time:

Ministry of Energy, Mines and Petroleum Resources:

Petroleum, Engineering and Operations Branch;

Ministry of Municipal Affairs: Boiler and Pressure Vessel Safety;

Bulkley-Nechako Regional District;

District of Port Edward;

District of Vanderhoof;

Town of Smithers;

Village of Burns Lake;

Village of Fort St. James;

Village of Fraser Lake;

Village of Granisle;

Tsimshian Tribal Council.

Staff of the Environmental Assessment Office were also asked to review the Prospectus to see whether its contents fulfilled the information requirements of section 7 of the soon-to-be-proclaimed Environmental Assessment Act (EAA) and have concluded that it does not.

In addition, Chief Robinson of the Kitamaat Village Council stated that he is unable to provide comments due to a lack of resources and technical expertise. Depending on the final site selection and pipeline routing considerations, PAC-RIM will be required to facilitate Aboriginal participation in the review of the project. You should discuss this with staff of the Environmental Assessment Office.

In general, most of the review agencies require additional information before they can complete their review of the project. Several agencies included in their comments a list of permits, approvals and licenses that may be required. I encourage you to deal directly with the review agencies to clarify information requirements.

Given the range of outstanding technical issues and information requirements identified during the review of this Prospectus, the Energy Project Coordinating Committee will likely recommend that the project be placed at Stage 1 of the new EAA process. I will keep you apprised of progress in this regard.

If you have any questions or require additional information, please feel free to contact me at

604-952-0264 or Mr. Paul Wieringa, Senior Analyst, at 604-952-0268.

Yours sincerely,

Denise Mullen-Dalmer

Director

Power and Projects Branch

Summary of Reviewers' Comments
Provincial Agricultural Land Commission:

Although the sites proposed for the facility do not fall within the Agricultural Land Reserve, the pipeline is likely to cross areas within Reserve lands. Approval will be required under Section 44(f) of B.C. Regulation No. 313/78. The proponent should contact the Provincial Agricultural Land Commission at (604) 660-7000 to determine specific requirements for this application.

Ministry of Employment and Investment:

Further work on socio-economic impacts should not be submitted until a preferred location and route have been selected. Information to be provided once the site and route are selected include a "Base Case" profile of the region (including demographics, major economic sectors, social issues, etc.), impacts on the exercise of traditional Aboriginal activities, construction/operations workforce requirements (including how these can be filled from the local area), accommodation plan for construction workers, incremental demand for social services, plan for procurement of goods/services, and impacts and mitigation measures for transportation/ safety issues.

Ministry of Energy, Mines and Petroleum Resources, Land Management and Policy:

This branch had no concerns with the proposal.

Ministry of Environment, Lands and Parks:

The proponent is advised to contact staff in each program of each region to discuss details of information requirements, necessary permits and approvals, timing of applications for these permits and approvals and other technical details. Contacts and phone numbers are provided in the attached letter.

Insufficient information was provided to identify all requirements for a detailed impact assessment. To ensure sufficient time for review and planning, subsequent project documents submitted under either the Energy Project Review Process or the Environmental Assessment Act (EAA) should address the preferred site for the project and the analysis that led to this choice.

Concerns identified at this point include the source of the large volume of gas required and the potential upstream environmental impacts from obtaining, processing and transmitting this gas; environmental design and impact management along the proposed pipeline right-of-way; disposal of excess carbon dioxide; pollution control and emergency response plans at the LNG shipping facility; and selection of a site for the LNG plant and the potential for impacts, especially to the Kitimat River estuary. Specific details on these concerns are outlined in the attached letter.

Purchasing Commission:

The Purchasing Commission would like the opportunity to review the procurement plan once is it completed. The Purchasing Commission can also assist in arranging one or more "Supplier Days" for the exchange of information between Project Manager and potential suppliers. The proponent should try to debundle the project to create contracts manageable by B.C. suppliers.

Ministry of Forests - Prince George Forest Region:

To complete the review of this project, additional information is required on what steps are needed for Westcoast Energy Inc. to transport an additional 500 million cubic feet of natural gas on its pipeline and how much additional clearing is required along the existing Pacific Northern Gas right-of-way. A Licence-to-Cut is required for clearing of any merchantable timber. A Road Use Permit is required for any pipeline crossing of and any trucking of pipe on Forest Service roads. Additional cattleguards or fencing may be required for impacts to Range tenures. Documentation is required to show that the proposal was referred to affected First Nations and that meaningful input was sought regarding potential impacts of the project on traditional use activities. PAC-RIM should submit a map or plan at a scale of 1:10,000 or 1:20,000 showing the right-of-way and any timber to be harvested.

Ministry of Forests - Prince Rupert Forest Region:

A Licence to Cut and burning permits are required if timber is removed from Crown land. If the Bish Cove site is chosen, a Special Use Permit will be needed to build the access road to the site.

Ministry of Health:

The ministry identified a number of health and safety concerns for the construction and operation of the pipeline and plant. These are listed in the attached letter.

Ministry of Municipal Affairs, Planning Branch:

When the final site selection is made, a detailed socio-economic impact analysis of the project on that area is required. This analysis should include direct and indirect employment for construction and operation, recruitment from out of region and their settlement options, and impacts on the existing communities and services.

Ministry of Municipal Affairs, Engineering and Inspection Branch:

The ministry requires financial information indicating financial responsibility for the project before approving construction of the pipeline or plant. PAC-RIM must apply under the Pipeline Act for permission to construct both the pipeline and the LNG plant. The pipeline and LNG plant must meet the requirements of two standards: CSA-Z662-Oil and Gas Pipeline Systems and CSA-Z276-LNG-Production, Storage and Handling. For the siting of the LNG plant, Radiation Flux levels (fire) and vapour dispersion studies must be done and the exclusion distances (noted in CSA-Z276) met.

Ministry of Small Business, Tourism and Culture - Archaeology Branch:

Although heritage resources are noted in the terms of reference for the environmental protection plan, a general assessment of project impacts on archaeological site and historic sites was not provided. The proponent is advised to commission an archaeological overview assessment under section 3.4 of the British Columbia Archaeological Impact Assessment Guidelines and to report the results of this assessment to the Archaeology Branch before submitting further project documentation. Permits will be required under the Heritage Conservation Act to collect data from archaeological sites as well as for the alteration of any sites protected under this legislation.

Ministry of Transportation and Highways - Central/North East Region:

Any pipeline crossing of provincial roads or structures will require a permit from the Provincial Approvals Officer.

Ministry of Transportation and Highways - North West Region:

Comments cannot be provided until additional information is provided on the pipeline, including more detailed maps of existing works and geographical features and legal lot descriptions; details of the method(s) to be used for installing the new pipeline; and details of the method/procedure for any highway and secondary road crossing. The proponent must apply for permits in each Highway District for "Works Upon Crown Lands" and for each individual highway/road crossing.

B.C. Utilities Commission:

The Commission requires information as to whether the proponent is considering transporting gas to customers on a by-pass arrangement or whether any excess capacity would be used to transport gas for Pacific Northern Gas. The Commission also provided comments on the project rationale.

Department of Fisheries and Oceans Canada (DFO):

DFO believes that there may be some foreshore alienation with each of the proposed sites, which will require authorization under section 25(2) of the Fisheries Act and discussions on mitigative techniques to reduce impacts and on compensation. Once the final site is selected, DFO can provide information on streams and fish habitat in that area and the information required to address concerns about impacts to fisheries resources. More information is required on drainage, use of seawater for coolant water, waste water and storm drain systems within the plant site and for spill response. Concern was raised with the construction of the pipeline from Summit Lake to the plant site, particularly with plans to complete construction in one year given the number of stream crossings. Environmental monitors will be required for the construction of the pipeline. DFO suggests an arrangement similar to one used by Westcoast Energy in the northeastern part of B.C. More information is required on methods to deal with pollution issues associated with the special tanker traffic and shipping the LNG product.

City of Prince George:

The City has no concerns with the project provided that the pipeline is constructed within the existing Pacific Northern Gas Right-of-Way.

City of Prince Rupert:

This agency supports this project and has no concerns.

District of Kitimat:

The District provided a number of comments supporting the project, particularly a proposed location in Kitimat. If the selected site is on private or Crown lands, the project will be subject to municipal zoning and subdivision approvals.

Regional District of Fraser-Fort George:

The Regional District has no concerns with the project. The proponent is advised to contact the community of Summit Lake to inform them of this project.

Regional District of Kitimat-Stikine:

The Regional District requested information on a number of topics, including movement of LNG carriers and potential for interference with other marine traffic; peak and average employment numbers for the construction and operation phases; and income, employment and taxation impacts for the region. A public consultation program that includes media releases, informal information meetings and talks to key community groups is recommended. The Regional District also suggested that the proponent consider using the project as an opportunity to make natural gas available to the Hazelton region. A pipeline route map should be submitted to the Regional District.

Skeena-Queen Charlotte Regional District:

This agency supports the project and suggests that further study of sites in the Prince Rupert area would be useful. If a new pipeline is built along the Skeena corridor, some of the related facilities may require a zoning amendment to Bylaw 7.

Village of Telkwa:

This agency has no comments on the project.

Carrier Sekani Tribal Council:

The Carrier Sekani Tribal Council stated that the proposed pipeline would pass through territories which are the subject of treaty negotiations between the Council, at least some of its member nations and the governments of Canada and British Columbia. The letter includes an information request on the pipeline including precise location, tenure for right-of-way, corporate entities involved in the construction, construction schedule, employment and contracting policies, schedule of National Energy Board hearings and reasons to support this ministry's statement that the pipeline would be reviewed under a provincial process. The Council noted that receipt of the prospectus does not imply that there has been meaningful consultation.

APPENDIX 4

PERMITS AND LICENSES

Agriculture Land Commission:

· Pipeline crossings of land reserve needs a s. 44(f) of BC Reg. No. 313/78 approval. the Commission will require the submission of a separate Schedule '1' application for each local government jurisdiction where the Agricultural land Reserve is affected by the pipeline. Contact, Jim Gilliland, 604-775-1419.

B.C. Utilities Commission:

· May be responsible for issuing a Certificate of Public Convenience and Necessity.

Canadian Coast Guard

· Technical Review Process to Safeguard the Environment from Pollution and to Ensure the Safe Development and Operation of Marine Terminal Systems and Transportation Sites (TERMPOL) - this is a non-mandatory process used in determining the need for making or revising regulations, or for implementing special precautionary measures that may affect a ship's operation within a particular marine terminal system or transhipment site. Implementation of a TERMPOL Report's recommendations is the prerogative of applicable agencies performing regulatory functions or of the proponent.

The purpose of the TERMPOL review is to objectively appraise operational ship safety, route safety, management, and environmental concerns associated with the location, construction, and subsequent operation of a marine terminal system. The appraisal enables an inter-departmental committee to identify potential problems and to recommend appropriate ameliorative measures.

The TERMPOL can be initiated by either the CCG, the proponent or a recommendation by the standing committee which considers applications under the Navigable Waters Protection Act and can be done concurrently with the environmental assessment. PAC-RIM Inc. has indicated that it will request a TERMPOL review.

City of Prince Rupert:
Department of Fisheries and Oceans:

· s. 35(2) under Canada Fisheries Act

Department of Indian Affairs and Northern Development:
District of Kitimat
Kitimat-Stikine Regional District:

This office noted that the pipeline or ancillary facilities may be located where Regional District land use bylaws are in effect. A cursory review of our bylaws combined with more recent information on possible alignments suggest an amendment to bylaws may not be necessary. The company will need to contact our office as decisions on pipeline routing and ancillary facilities are made.

Ministry of Employment and Investment (formerly Ministry of Energy, Mines and Petroleum Resources):

PAC-RIM is encouraged to consult with the staff of the Oil and Gas Policy Branch and begin the application process as soon as practicable.

The project will require the following applications::

· Application for the LNG plant under section 116 of the Petroleum and Natural Gas Act

Any scheme to process natural gas requires approval from the Minister of Energy, Mines and Petroleum Resources. MEI advises PAC-RIM to consult with staff of the Engineering and Operations Branch and to obtain a copy of the guidelines (presently in draft form) that outline the requirements for this application. The application will require such items as a plant description and location map, construction plan, process description and flow diagram, emission control and monitoring measures, plant security and emergency measures.

· Application for the natural gas transportation facilities pursuant to the Pipeline Act

This application will require a pipeline routing map and a description of compliance with Oil and Gas Pipeline Systems standards published by the Canadian Standards Association: Information indicating financial responsibility for the project is required under the Pipeline Act before construction can be approved. PAC-RIM must apply for permission to construct both the pipeline and some components of the plant, which must meet the requirements of CSA-Z662-Oil and Gas Pipeline Systems, and CSA-Z276-Production, Storage and Handling. For siting of the LNG plant, Raditation Flux levels (fire) and vapour dispersion studies must be done and the exclusion distances met. Information indicating financial responsibility for the project is required under the Pipeline Act before construction can be approved.

· Application for an Energy Removal Certificate (ERC) under section 23 of the Utilities Commission Act, ERC Application Regulation (Reg.426/90)

In this application, PAC-RIM must provide a complete description of the proposed natural gas removal, identifying quantities to be removed, market(s) to be supplied, source(s) of supply, price and other prescribed information. MEI advises PAC-RIM to discuss this requirement with staff of the Oil and Gas Policy Branch and submit this application at the earliest possible time.

Information required by MEI under the Utilities Commission Act will include:

Ministry of Environment, Lands and Parks:

· The following Acts and Regulations have portions which are applicable to this project:

Environmental Management Act
Environmental Assessment Act
Litter Act
Waste Management Act
Open Burning Smoke Control Regulation
Ozone Depleting Substance Regulation
Return of Used Lubricating Oil Regulation
Special Waste Regulation
Spill Reporting Regulation
Waste Management Regulation
Public Notification Regulation

Petroleum Storage and Distribution Facilities Storm Water Regulation

B.C. Lands: One of the two sites at Kitimat is centered on the Bish Indian Reserve No 6. BC Lands would have no involvement with the establishment of a plant on the reserve lands. Surrounding the reserve is a BC Lands Notation of Interest (NOI) as described under file 6400903.

BC Lands will be establishing a NOI (in the Ministry's name) over the linear corridor for a two year term on behalf of PAC-RIM. PAC-RIM will be responsible for complete a status of the corridor at their expense to determine private and Crown parcels. BC Lands will provide status information on the Crown parcels once they are identified by PAC-RIM. In order to facilitate the establishment at this NOI, BC Lands requests that the linear corridor be plotted in 1:20,000 scale base mapping.

BC Water Management: Approval for the stream crossings will be handled in several ways. The Section 7 Regulations under the BC Water Act indicate in Section 44c) of the Regulation the following:

Authorization for changes in and about a stream

44. For the purposes of section 7.1 of the Water Act, the following changes in and about a stream may be made without the necessity of obtaining an approval or licence for that change, provided that the change is made in accordance with this regulation and in accordance with the terms and conditions, described in section 42, specified by a habitat officer

(c) the construction or maintenance of a pipeline crossing, provided that

(i) the pipeline and associated works are installed in a naturally dry stream channel at a depth so that the top of the pipe is at least 1 metre below the lowest elevation of the bed of the stream, and

(ii) in the case of an aerial crossing, the crossing is constructed in accordance with the requirements prescribed in paragraph (b) for clear span bridges.

Those crossings which cannot be constructed according to the Section 7 Regulations will require Formal Approval under the Water Act. Skeena Region will attempt to reduce the number of approvals required by possibly grouping the crossings by watersheds. The Formal Approval requires a $130.00 fee/application, supporting documents of drawings for the individual crossings, contingency plan should the flume, coffer dam, etc. fail and Water Managment would make all the necessary referrals to other agencies with a concern for the crossings. As these Approvals will be time consuming at least 60 days lead time will be required.

· Water Act approval or Water License for water use

BC Environment:

Ministry of Forests:

Some of the permitting by the Ministry of Forests is dependent on PAC-RIM obtaining other authorizations. For example, PAC-RIM would require authorization to occupy the pipeline ROW before the ministry could issue a license to cut. The timing around these required prior approvals must be kept in mind by PAC-RIM during the life of this project, especially should they decide to apply for concurrent permitting.

The ministry will require information on the effects of the project on other forest resources when granting approvals under the Forest Act and the Forest Practices Code of British Columbia Act.

PAC-RIM will require a number of regulatory authorizations from the Ministry of Forests to construct the pipeline. These include, but may not be limited to, licenses to cut, road use permits, special use permits and burning permits.

Ministry of Health and Ministry Responsible for Seniors

The Ministry has direct responsibility for issuing permits for drinking water, food handling and food service facilities, and sewage disposal systems under the capacity of 5,000 Imperial gallons per day. These responsibilities derive from the following sources:

Furthermore, MOH has overall responsibility for approving and inspecting sites such as mining camps, as well as addressing any situation potentially injurious to the public health. These responsibilities derive from the following sources:

Ministry of Municipal Affairs:
Ministry of Small Business Tourism and Culture:
Ministry of Transportation and Highways:

These permits must be dealt with on a site by site basis. Each situation will require site plans and the associated permits will include unique requirements and conditions as appropriate. If the proponent wishes to pursue permit approval concurrently with the Project Approval Certificate, details of each situation related to the project must be submitted. If the final site of the LNG terminal is not decided beforehand, detail for all permits required by both options will have to be submitted.

National Energy Board (NEB):

· Requirements for Export License - The following information is required by the NEB (Part XII, Guidelines For Filing Requirements): requirements include such information as the names of the exporter and importer, quantities, periods of contract, and status of regulatory authorizations.

The NEB must take into account section 118 of the National Energy Board Act which requires the Board to satisfy itself that the quantity of gas to be exported does not exceed the surplus remaining after due allowance has been made for the reasonably foreseeable requirements for use in Canada having due regard to the trends in the discovery of gas in Canada.

The NEB implemented the Market-Based procedure in 1987 in order to ensure that natural gas to be licensed for export is both surplus to reasonably foreseeable Canadian requirements and in the public interest. This procedure involves:

In its assessment of gas supply, the Board reviews the contractual arrangements pertaining to supply and the adequacy of both reserves and productive capacity. The Board expects applicants to demonstrate that established reserves are equal to or exceed the applied for volume and that productive capacity is adequate to meet the proposed annual export volumes. Each applicant is required to provide an estimate of established reserves which can be assessed against its requirements. The Board uses its estimate of reserves, along with basic deliverability data for each pool submitted, in preparing its productive capacity projections. Where an export is being supplied from a corporate pool, the board will examine the make-up of that pool, its established reserves and productive capacity, and other sales commitments to be served from the same pool. Similarly, where corporate warranties are used to backstop a supply arrangement, the Board will examine the likely availability of this supply, including any contractual commitments.

The Board also reviews the status of all upstream and downstream transportation arrangements, including transportation contracts and the term and contracted capacity of the transportation arrangements.

As far as upstream environmental effects of facilities and activities are concerned, the Board will consider them only when those facilities or activities are necessarily connected to the requirements of the export Licence. For the necessary connection to exist, the export Licence and new upstream facilities or activities must be integrated to the extent that they be seen to form part of a single course of action.

Skeena-Queen Charlotte Regional District:

· If a new pipeline is built along the Skeena corridor, some of the related facilities may require a zoning amendment to Bylaw 7.

APPENDIX 5

PAC-RIM PROJECT COMMITTEE

MEMBERS

Province of British Columbia:

· Project Committee Members (Project Committee Advisors listed in brackets)

· Environmental Assessment Office (EA Office) - Martyn Glassman, Project Assessment Director, Chair

· Agriculture, Fisheries and Food, Ministry of (MAFF),

Mr. Robert Kline, Soil Conservation and Management Specialist

(Peter Gubbels)

· Attorney General, Ministry of(MAG), Mr. Peter Whelan, Acting Director, Community Justice Branch

· Employment and Investment, Ministry of (MEI - formerly Energy, Mines and Petroleum Resources), Ms. Lynne Ewing, Senior Policy Advisor (Richard Keltie, Georgina Naismith)

· Environment, Lands and Parks, Ministry of (MELP), Garry Alexander, Senior Coordinator, Environmental Assessment (Ray Carrier, Karen Diemert, Robin Fairservice, Philip Ross, Terry Pratt/Ian Smythe, Lorne McIntosh, Uwe Finger, Dave King, Lorne Mcintosh, Al Phillips, Ruth Christensen, Debbie Cichowski, Rick Heathman)

· Forests, Ministry of (MoF), Mr. Richard Grieve, Sr. Policy Advisor (Neil Endacott, Prince Rupert Forest Region and Phil Zacharatos, Prince George Forest Region)

· Health, Ministry of (MoH), Mr. Terry Peace, Senior Scientific Technical Officer (Bruce Gaunt)

· Municipal Affairs, Ministry of (MMA), Mr. Ray Ghosh,

Senior Planner

· Transportation and Highways, Ministry of (MOTH),

Mr. Christopher Barlow, Environmental Coordinator (David Fisher)

· Small Business, Tourism and Culture, Ministry of

(MSBTC- archaeology), Mr. Al Mackie, Project Officer -Planning and Assessment, Archaeology Branch (Michael Riseborough)

· Social Services, Ministry of (MSS), Mr. Terry Feesey, Sr. Policy Analyst, Policy, Planning and Legislation

· Women's Equality, Ministry of (MWE), Ms. Joan Verwood, Policy and Planning Branch

Government of Canada:
· Project Committee Members

· Canadian Coast Guard, (CCG), Mr. Brain Balfe, Navigable Waters Protection Officer

· Environment Canada (EC), Mr. Bernie Claus

· Fisheries and Oceans Canada (DFO), Mr. Leslie Powell, Area Chief - Habitat Management, North Coast Division (Bruce MacDonald)

· Health Canada (HC), Mr. Jack Nickel, Occupational & Environmental Health

· Indian and Northern Affairs Canada (INAC), Ms. Ada Tuck, Manager. Environmental Protection and Natural Resources

· Natural Resources Canada, (NRC) Chris Reid, Natural Gas Division

· Transport Canada, (TC) Mr. Alan MacSween, Senior Ship Surveyor

· Observer Status

· Canadian Environmental Assessment Agency (CEAA), Mr. Paul Scott, Regional Director

· Canadian Heritage, Dr. Martin Magne, Senior Archaeologist

· Canadian Wildlife Service (CWS), Ken Brock

· Prince Rupert Port Corporation, (PRPC) Mr. David Woodman, Assistant Harbour Master

Local Governments:
· Project Committee Members

· Buckley-Nechako Regional District, Mr. Mark Andison, Principal Appointed Officer

· Burns Lake, Village of, Mr. Lonny Miller, Principal Appointed Officer

· Fraser-Fort George Regional District, Mr. Terry McEachen, Principal Appointed Officer

· Fraser Lake, Village of, Mr. Angus Davis, Principal Appointed Officer

· Houston, District of, Mr. Bill Beamish, Principal Appointed Officer

· Kitimat, District of, Mr. Trafford Hall, Principal Appointed Officer (Diane Hewlett)

· Kitimat-Stikine, Regional District of, Mr. Bob Marcellin, Principal Appointed Officer

· Port Edward, District of, Mayor Edward Wampler

· Prince George, City of, Mr. Bob Radloff, Supervisor, Environmental Services

· Prince Rupert, City of, Mr. Erminio Pucci, Department of Economic Development & Tourism

· Skeena-Queen Charlotte, Regional District of, Mr. Bryce Barnewell, Principal Appointed Officer

· Smithers, Town of, Ms. Terri-Anne Barge, Principal Appointed Officer

· Telkwa, Village of, Ms. Arlene deGelder, Principal Appointed Officer

· Terrace, City of, Mr. Robert Hallsor, Principal Appointed Officer

· Vanderhoof District of, Ms. Shirley Olm, Principal Appointed Officer

· Local Government Observers:

· Fort St. James Village of, Mr. Daniel Zabinsky, Principal Appointed Officer

· Granisle Village of, Mr. Robert Jackman, Principal Appointed Officer

First Nations:
· Project Committee Members

· Allied Tsimshian Tribes Association, Speaker James Bryant

· Broman Lake Indian Band, Chief Maureen Ogen

· Burns Lake Indian Band, Chief Robert Charlie

· Carrier-Sekani Tribal Council, Chief Lynda Prince

· Hartley Bay Indian Band, Chief William Clifton

· Kitasoo Indian Band, Chief Percy Starr

· Kitamaat Village Council, Chief Robert Robinson (Zeno Krekic)

· Kitkatla Indian Band, Chief Francis Lewis

· Kitselas Indian Band, Chief Melville Bevan/Glenn Bennett

· Kitsumkalum Band, Chief Steve Roberts (Alex Bolton)

· Lax-Kw'alaams Band, Chief Ben Hughes (Alex Campbell)

· Lheit Lit'en Nation, Chief Barry Seymour (Gary Jung)

· Metlakalta Indian Band, Chief Harold Leighton Jr. (Tara Leighton & Sharon Morren)

· Nadleh Whut'en, Chief George Lacerte

· Nak'azdli Band, Chief Harold Prince

· Sai'kuz First Nation, Chief Stanley Thomas

· Stella'ten First Nation, Chief David Luggi

· Tsimshian Tribal Council, Mr. Robert Hill

· Office of the Wet'suwet'en Hereditary Chiefs, Mr. Bernie Gellenbeck

(1) Names and addresses have been severed from the Appendices by the Environmental Assessment Office in order to comply with Section 22 of the British Columbia Freedom of Information and Protection of Privacy regulations.


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Last updated: 12/09/96