Comments on the proposed Coastal GasLink Pipeline Project

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Comments on the proposed Coastal GasLink Pipeline Project Application
Issue theme and section: Status of Oolichan. Section 7.4.2 Protection of
Recreationally, Commercially and/or Culturally Important Fish and Fish Habitat
Valued Component (if applicable):
Contact: Candice Wilson – Haisla Nation Council
Date of Comment: April 11, 2014
Comment # 1
Point of Clarification
Table 7-3: Confirmed and Potential Fish Species Presence in Watercourses within the
Aquatic Environment RSA lists oolichan (eulcachon – thaleichthys pacificus), a
significant cultural resource to the Haisla First Nation, as a historical presence within the
Kitimat River. The Haisla Nation Council Fisheries department actively samples the
Kitimat River on a yearly basis and for 2014 there was presence of oolichan in the
system.
Comments on the proposed Coastal GasLink Pipeline Project Application
Issue theme and section: Protection of Oolichan. Appendix 2G; Section 4.4.9 Eulachon
(Thaleichthys pacificus)
Valued Component (if applicable):
Contact: Candice Wilson – Haisla Nation Council
Date of Comment: April 11, 2014
Comment # 1
Point of Clarification/Issue
The statement that oolichan are unlikely to occur in the Kitimat River is not true and
every effort to protect the species is of the utmost concern for the Haisla First Nation;
therefore protection of the species and the spawning habitat needs to be a priority.
Comments on the proposed Coastal GasLink Pipeline Project Application
Issue theme and section: Terrain Integrity – Section 5.6 Terrain Integrity Effects
Assessment
Valued Component (if applicable):
Contact: Candice Wilson – Haisla Nation Council
Date of Comment: April 11, 2014
Comment # 1
Issue
Although the terrain integrity effects assessment resulted in no potential residual
adverse effects, the pipeline route through the Kitimat Valley and along the Kitimat River
is still a concern because of the disruption of the steep slopes during construction, the
need for temporary workspace for construction and the possibility of a rupture during
operation. Despite the mitigation measures that will be implemented there is always the
possibility of an accident due to unforeseen circumstances.
Comments on the proposed Coastal GasLink Pipeline Project Application
Issue theme and section: Acid Rock Drainage. Terrain Technical Data Report Section
5.2 Acid Rock Drainage
Valued Component (if applicable):
Contact: Candice Wilson – Haisla Nation Council
Date of Comment: April 11, 2014
Comment # 1
Request for Additional Information
The technical data report states that field assessments were not conducted to confirm
the desktop study. Have these field assessments been started and will Haisla Nation
Council be informed when they will occur?
Comment # 2
In a letter from the EAO addressed to Gillian Bakker dated February 27, 2014 it stated
more information would be provided from the BC OGC on how waste rock sites would
be assessed during permitting. This information has not been received yet and I would
like to be copied on this information when it becomes available.
Comments on the proposed Coastal GasLink Pipeline Project Application
Issue theme and section: Cumulative Effects Section 3.8.5 Existing Activities and
Events
Valued Component (if applicable):
Contact: Candice Wilson – Haisla Nation Council
Date of Comment: April 11, 2014
Comment # 1
Issue
Rio Tinto Alcan is currently modernizing their smelter in Kitimat and this major project is
not listed within the activities. Being a major project it has already impacted the
community on many levels and this project should have been included in all aspects of
this application.
Comments on the proposed Coastal GasLink Pipeline Project Application
Issue theme and section: Loss of Ecosystem Services
Valued Component (if applicable):
Contact: Candice Wilson – Haisla Nation Council
Date of Comment: April 11, 2014
Comment # 1
Issue
The current Environmental Assessment process does not have a comprehensive
method of accounting for the ecosystem services that are impacted or lost due to the
project footprint within our traditional territory.
Comment # 2
Another aspect of the services lost within the project footprint is the carbon sink
(vegetation) removal. How will this particular loss be accounted for?
Comments on the proposed Coastal GasLink Pipeline Project Application
Issue theme and section: Aquatic Environment
Valued Component (if applicable):
Contact: Candice Wilson – Haisla Nation Council
Date of Comment: April 11, 2014
Comment # 1
Depending on the stream crossing area, specific reclamation prescriptions may be
required in consultation with the Haisla Nation Council Fisheries department. Detailed
post-construction reclamation activities will ensure the protection of fish habitat using
local knowledge that is specific to this area.
Comments on the proposed Coastal GasLink Pipeline Project Application
Issue theme and section: Vegetation. Section 8.4.1 Ecological Communities of Concern
Valued Component (if applicable):
Contact: Candice Wilson – Haisla Nation Council
Date of Comment: April 11, 2014
Comment # 1
Request for Additional Information
Traditional Ecological Knowledge was briefly discussed in this section and more
information is requested regarding the area 34m north of KP 663 and 4m north of KP
620. These areas are not mentioned in Section 16 Traditional Land and Resource Use.
Will these areas be protected once construction starts? Are there mitigation measures
in place to protect these areas?
Comments on the proposed Coastal GasLink Pipeline Project Application
Issue theme and section: Atmospheric Environment.
Valued Component (if applicable):
Contact: Candice Wilson – Haisla Nation Council
Date of Comment: April 11, 2014
Comment # 1
Issue
The whole assessment of the atmospheric environment is based on the areas
surrounding the compressor stations when in fact the impact of constructing the pipeline
and the right of way includes the whole project footprint. The amount of materials
requiring transport to and from the project site can cumulatively add Criteria Air
Contaminant’s to our air shed therefore impacting various ecosystem services.
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