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14 April, 1997

TransQuebec & Maritimes Pipeline Inc.
1 Place Ville-Marie
Bureau 2220
Montreal, QC H3B 3M4

To whom it may concern:

The purpose of this letter is to express my reservations concerning the routing of Trans Quebec & Maritimes Pipeline's proposed PNGTS natural gas pipeline project and the spirit in which TQM and its associates have carried out their early public notification (EPN) program.

Routing

The proposed corridor for the PNGTS project in Sector 3 of the Eastern Townships, the section extending from Autoroute 10 just north of Magog to East Hereford on the New Hampshire border, appears to be a hastily chosen and ill- conceived alternative to the failed routing attempt in northern Vermont. From the broad corridor choice to the proposed detailed routing there are many aspects which make little sense.

The corridor

The proposed corridor would take the pipeline right through the middle of the most picturesque area in the entire Eastern Townships: the area from Sherbrooke down to the Vermont border. Specifically, the proposed pipeline route cuts right across two ridges (Brown's Hill and Bunker Hill) just a stone's throw from the southern tip of Lake Massawippi.

The unspoiled Lake Massawippi stretches twelve miles from North Hatley at its northern end down to Ayer's Cliff at the south. Its beautiful shoreline is divided between rough wilderness, rolling farm lands, tastefully developed cottage country, and elegant, quality touristic attractions such as hiking, biking, and cross-country ski trail networks, and inns and hotels renowned worldwide for their beautiful surroundings.

The hills surrounding the lake afford truly breath-taking panoramic views of the area. From the top of Brown's Hill exactly where the pipeline is proposed to cross it one can enjoy a magnificent view of the lake to the north and the distant mountain ranges east to Maine and south to Vermont. The majesty of the neighboring ridge, Bunker Hill, is so highly regarded that in the late 70's the Quebec government proposed to create a provincial park overlooking Lake Massawippi on the very site where TQM is now proposing to route a natural gas pipeline.

This proposed routing is almost identical in nature to that which the PNGTS proponents originally proposed in Vermont. That plan had the pipeline crossing the US-Canadian border at Jay, Vermont and extending to the New Hampshire border. The plan was soundly rejected by both the people and government of Vermont due to its deleterious effects on the picturesque Vermont countryside.

Why then does TQM now propose routing their project through the heart of an area such as ours (an area, incidentally, shaped by glaciers and characterized by rugged, steep contours and an abundance of bedrock in close proximity to the surface) when there is an obvious alternative that would involve a fraction of the negative social, environmental, and economic impacts? I am talking about a routing that would follow the established Metropolitan Gas network (as other parts of the project do) as it skirts Sherbrooke to the west, the north, and east. East of Sherbrooke the route could take a direct route to the New Hampshire border through an area which is chiefly woodlot and whose already sparse population has been decreasing for many years. The cost of the slightly longer route would be at least partially offset by lower construction costs through a more conducive terrain.

The detailed routing

The detailed routing of the pipeline past the Ste-Catherine de Hatle/Ayer's Cliff area is no less difficult to understand: it is a graceless ramble through mature maple stands, farm land, and unspoiled wilds, whose sole purpose, evidently, is to avoid the rock along the eight kilometer section of autoroute between Katevale and Ayer's Cliff ? rock that is ubiquitous in the area and found abundantly along the "preferred" route anyway.

An even closer examination of the preferred detailed route reveals that TQM's engineers and environmental consultants: 1) prefer cutting mature maple stands to utilizing adjacent pasture land; 2) see nothing wrong with passing through natural, unexploited land in lieu of adjacent lots already scarred by virtual clear cutting and deeply-rutted logging roads; and 3) have no misgivings about routing a natural gas pipeline in the proximity of a major gravel quarry where heavy blasting regularly shakes the ground.

Early public notification

Commencing with the forth paragraph on the first page, the National Energy Board of Canada's Information Bulletin #1, "Pipeline Route Approval Procedures", reads:

"To ensure early, ongoing and full public disclosure of the nature of projects, the NEB has issued a memorandum of guidance to all companies under its jurisdiction."

"The memorandum requires companies to implement early public information programs that explain their projects, identify potential environmental and social effects and provide time and opportunity for public comment prior to the Board's dealing with the application. All relevant information gathered by a company in this process is reported to the Board as part of the project application."

In my opinion, "the company" has followed neither the letter nor the spirit of this directive. From the initial public meeting in Ayer's Cliff to dealings with individual landowners the main thrust of the "company" has been to isolate and control landowners, not inform them.

Early information programs

As an English-speaking citizen living in Quebec, am I a member of the public which is to be informed? Why then was I invited to a public meeting where all information, both written and spoken, was available only in French? Why did it take a full month for the written materials to be delivered to me when they were promised in one week?

Opportunity for public comment

As an affected landowner, to whom should I direct my comments? Trans Quebec & Maritimes Pipeline, the company regulated by the NEB and which apparently will file application with NEB for the project? Or Metropolitan Gas, Inc., a company not regulated by the NEB but that owns fifty percent of TQM and is actually responsible for the project. Perhaps Janin, Inc., the manager for the project? Or how about Urgel Delisle & Associes, Inc., the project's engineering and environmental consultants? Or perhaps Poisson, Bazinet et Associes, the evaluators who negotiate the right-of-way? Ummm. Maybe Forum Communications, the public relations firm provided with TQM letterhead, but whose employees TQM "has never heard of".

And what am I to make of the fact that I and other individuals who asked for the names and addresses of other affected landowners in our municipality were told repeatedly that our request would be granted, only to have the request turned down at a late date? We was told we could obtain the list from our municipality, but I am told that even the municipalities have not received the list.

Identification of potential environmental and social effects

As far as I am aware the company's representatives did not initiate any discussions concerning safety, environmental, or socioeconomic factors. According to my understanding, these subjects were glossed over at the Ayer's Cliff meeting, as they were in my face-to-face contacts with TQM's engineering consultants and chief right-of-way negotiator. For example, in response to my direct questions concerning the maintenance of the pipeline neither Claude Veilleux or Roger Senecal mentioned frequent, low-level helicopter over- flights. I had to discover this through my own research.

In response to my questions concerning alternative routing I was given extremely vague reasons why other routes would be unsuitable and told repeatedly that their "preferred" route would undoubtedly be approved by the NEB. The main thrust of the company's contacts was to discuss compensation.

Summary

In summary, I reject the TQM-PNGTS natural gas pipeline project as it is currently proposed. TQM has done a very poor job of explaining their project to the people affected by it. Perhaps this is because the project has been poorly conceived and designed and TQM is just counting on an apathetic public and unconcerned landowners to provide little or no resistance. If so, TQM should be aware that it has grossly underestimated the common sense, intelligence, and determination of myself and many, many other people in this region.

Sincerely,

Bruce Miller
Ayer's Cliff, QC


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