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National Energy Board Comprehensive Study Report

In the Matter of Trans Québec & Maritimes Pipeline Inc. PNGTS Extension

Application dated 30 April 1997 GH-1-97

Table of Contents

1.0 Summary

2.0 Project and Environmental Assessment Process
2.1 Overview of Project
2.2 Purpose and Need
2.3 Environmental Assessment Process
2.4 Other Assessment Processes
2.5 Scope of the Assessment
2.6 List of Activities, Location and Schedule
2.7 Routing and Site Selection
2.7.1 Routing Description
2.7.2 Above-Ground Facilities Site Selection
2.8 Alternative Means of Carrying Out the Project
2.9 Alternatives to the Project

3.0 Public Consultation Program
3.1 Introduction
3.2 TQM's Early Public Consultation Program
3.3 NEB Process
3.4 Analysis of Effectiveness

4.0 Environmental Assessment
4.1 Physical Environment
4.2 Soil and Agriculture
4.3 Vegetation
4.3.1 Rare, Endangered and Significant Plants
4.3.2 Revegetation and Seed Mixtures
4.3.3 Vegetation Management
4.4 Forest Communities
4.5 Hydrology
4.6 Fisheries and Fish Habitat
4.7 Wetlands
4.8 Wildlife and Wildlife Habitats
4.8.1 Mammals
4.8.2 Birds
4.8.3 Reptiles and Amphibians
4.9 Environmentally Significant Areas
4.9.1 île aux Fermiers
4.9.2 Bunker Hill
4.10 Air Quality
4.11 Acoustic Environment
4.12 Heritage and Archaeological Resources
4.13 Socio-Economic Matters
4.13.1Visual or Aesthetic Environment
4.13.2Hunting and Fishing Opportunities
4.13.3Construction Practices
4.13.4Effects of Trespass
4.14 Cumulative Environmental Effects
4.15 Effects of Accidents or Malfunctions
4.16 Sustainable Development
4.17 Commitments
4.18 Waste Management
4.19 Emergency Response Plan

5.0 Environmental Inspection, Monitoring and Follow-up Program

6.0 Conclusions and Recommendations

Chapter 1


Trans Québec & Maritimes Pipeline Inc. ("TQM" or the "Company") is proposing to construct and operate natural gas transmission facilities that would extend its current system from Lachenaie, located east of Montreal, to East Hereford, near the Canada-U.S. border between Quebec and New Hampshire. At that point, TQM would connect to the facilities of the Portland Natural Gas Transmission System ("PNGTS") to serve the markets of the U.S. Northeast. The facilities would also reach the existing market of Gaz Métropolitain Inc. ("Gaz Métropolitain") through a new delivery point at Waterloo, Quebec. TQM expects to be able to provide the new service effective 1 November 1998.

Because the project involves the construction of a pipeline more than 75 kilometres ("km") in length on a new right-of-way, and pursuant to a decision of the Responsible Authorities under the Canadian Environmental Assessment Act ("CEAA"), the project was made subject to a comprehensive study.

The National Energy Board (the "Board" or the "NEB") conducted an oral public hearing to obtain evidence and views of interested persons on TQM's application, pursuant to the National Energy Board Act (the "NEB Act"), in respect of the installation of the proposed facilities. The hearing also provided a forum for public participation in the comprehensive study. The hearing lasted 19 days, beginning on 17 November 1997 and ending on 17 December 1997, and was held in Montreal and Orford, Quebec.

Through the services of Urgel Delisle & Associés Inc. ("UDA") consultants, TQM carried out a study of the environmental and socio-economic impacts of the project. The environmental components studied by UDA were, among other things, agroforestry, archaeology and heritage, vegetation, wildlife, and watercourse crossings. The study also included the identification of mitigative measures to ensure that the project is not likely to cause significant adverse environmental effects.

In selecting the route it submitted for approval, TQM began by defining a study area and then identifying elements within that area that it considered environmentally sensitive. It then developed corridors, including sections where it was considered necessary to develop technically and economically feasible alternatives means to carry out the project. The last step involved selecting the route and identifying alternative routes. For instance, TQM asked the Board to approve, in addition to the proposed route, two alternative routes it suggested in the Memphrémagog MRC area.

Before filing its application, TQM undertook an early public consultation program, the primary objective of which was to inform and consult persons and groups likely to be affected by the project. Other objectives of the program were to enable the public to comment on and express concerns about the project, and to decide on measures to address those concerns and to ensure follow-up.

The NEB review process has also involved public participation. Thus, the public was consulted as part of the scoping exercise to determine the scope of the environmental assessment and was given the opportunity to express views and opinions in the public hearing.

During the NEB hearing, and with respect to the comprehensive study, intervenors focused on the following matters: agriculture; watercourse crossings; rare plant and wildlife; groundwater for domestic, agricultural and fish-farming-related use; wetlands; heritage resources; and project alternatives. Certain intervenors were concerned as well with the recreational, tourism and visual impacts of the project on the affected areas. Disruption of hunting activities and increased noise levels in areas adjacent to the proposed facilities were among the issues raised.

The NEB concluded that the PNGTS Extension project is not likely to cause significant adverse environmental effects, provided that the mitigative measures identified during the proceedings are implemented and enforced.

Should the Board find that the TQM project is required by public convenience and necessity, a series of environmental conditions would be included in the certificate.

Chapter 2

Project and Environmental Assessment Process

2.1 Overview of Project

On 30 April 1997, TQM applied to the Board for a certificate of public convenience and necessity under Part III of the NEB Act authorizing the construction of transmission facilities that would extend its existing system from Lachenaie, located east of Montreal, to East Hereford, near the Canada-U.S. border between Quebec and New Hampshire (Figure 2.1).

The facilities proposed in the first year of operation consist of approximately 213.2 km of 610 mm outside-diameter pipe, one 7.0 MW electric motor-driven compressor unit at Lachenaie and two meter stations, one at Waterloo and the other at East Hereford. In the second year of operation, one additional 3.2 MW electric motor-driven compressor unit would be installed at East Hereford and one gas aftercooler unit would be installed at Lachenaie.

The cost of the proposed facilities is estimated at $273.8 million in 1997, including the allocation for funds used during construction.

Through the services of UDA, TQM carried out a study of the environmental and socio-economic impacts of the project. The environmental components studied by UDA were, among other things, agroforestry, archaeology and heritage, vegetation, wildlife, and watercourse crossings.

UDA delimited a study area within which it gathered data from existing elements and on-site surveys. This approach made it possible to identify potentially sensitive elements in the environment. It then developed corridors, including sections where it was appropriate to identify alternative routes. Based on the selected corridor, TQM decided on a primary route. Over fifty route variations within the study area were examined until, finally, one route was submitted to the Board for approval, along with two alternative routes in the Memphrémagog MRC which TQM said it preferred.

The TQM application, exhibits and evidence filed during the hearing provide a complete environmental description.

2.2 Purpose and Need

The purpose of the TQM Extension is to provide TransCanada Pipelines Limited ("TransCanada") with natural gas transmission from western Canada to two pipeline systems. The first system is the gas pipeline proposed by PNGTS in the United States to serve the U.S. Northeast markets. The second is Gaz Métropolitain's, which would be accessed through a new delivery point at Waterloo. Figure 2.1 Study Area, Preferred Route and Alternative routes The TQM Extension would give western Canadian natural gas producers increased access to the New England market. It would also fulfil Gaz Métropolitain's needs in the Eastern Townships region.

The U.S. Northeast natural gas market is currently supplied in part by a converted oil pipeline for which the lease will expire on 1 November 1998 and will not be renewed. Indeed, the owners of the Canadian and U.S. sections of the pipeline Montréal Pipe Lines Limited and Portland Pipe Line Corporation intend to convert it back to transporting crude oil when the lease is over.

Effective 1 November 1998, TQM expects to deliver a volume of 4.31 million cubic metres per day (152.2 MMcf/d) to East Hereford and 0.96 million cubic metres per day (33.7 MMcf/d) to Waterloo. In the second year of operation, these delivery needs are expected to increase to 5.95 million cubic metres per day (210 MMcf/d) at East Hereford and 1.38 million cubic metres per day (48.7 MMcf/d) at Waterloo. Approximately 90% of the yearly volumes shipped through the pipeline would be exported to the United States.

2.3 Environmental Assessment Process

Because TQM's PNGTS Extension project involves the construction of a pipeline more than 75 km in length on a new right-of-way, it is subject to the Comprehensive Study List Regulations, specifically paragraph 14(a) of the Regulations, under the terms of the CEAA. Pursuant to paragraph 21(a) of the CEAA, therefore, the project would either have been subject to a comprehensive study to be conducted by the Responsible Authorities or referred to the Minister of the Environment for referral to a mediator or a review panel.

Pursuant to paragraphs 5(1)(c) and 5(1)(d) of the CEAA, it was determined that the Board, Environment Canada and the Department of Fisheries and Oceans (Canadian Coast Guard) were Responsible Authorities. The Responsible Authorities decided that a comprehensive study report would be prepared and filed with the Minister of the Environment and the Canadian Environmental Assessment Agency (the "Agency"). Environment Canada later indicated that it was considering carrying out its own environmental assessment of the effects of the project on île aux Fermiers.

On 10 October 1997, the Board decided to hold an oral public hearing in respect of TQM's application, not only to gather evidence and the views of interested persons regarding the certificate of public convenience and necessity, but also to promote public participation in the comprehensive study and collect information for the preparation of this report.

The NEB's GH-1-97 hearing began on 17 November 1997 and ended on 17 December 1997. It was held at Montreal and Orford in the province of Quebec. This comprehensive study report takes into consideration the environmental information filed by TQM in its application, as well as comments and additional information submitted by federal, provincial, regional and municipal departments, ministries and agencies, the public, intervenors and TQM itself during the GH-1-97 hearing.

2.4 Other Assessment Processes

Before the project was submitted to the Board, it was the subject of two proceedings conducted by Quebec government authorities, namely, the Commission de protection du territoire agricole du Québec ("CPTAQ") and the Bureau d'audiences publiques sur l'environnement ("BAPE").

CPTAQ is an organization that, by virtue of the Quebec Act to Preserve Agricultural Land, governs the use of land in agricultural zones for purposes other than farming; approximately 175 of the 213.2 km of right-of-way required by the TQM project is on agricultural land. CPTAQ held three days of public hearings in early September 1997 at Longueuil and Magog, and rendered its decision on 10 November 1997. It authorized the use of the land under its jurisdiction for non-agricultural purposes, subject to two modifications to the route originally proposed by TQM. Following the CPTAQ's decision, TQM modified its route accordingly.

BAPE's function is to inquire into and hold public hearings on any matter relating to environmental quality in Quebec entrusted to it by the provincial Minister of Environment and Wildlife and to report back to the Minister with its findings and analysis. The Minister then submits his proposal to the Conseil des ministres, which has final decision-making power. BAPE conducted 16 days of hearings from mid-June to early July 1997 in a number of municipalities along the proposed route. On 9 October 1997, it issued its report on the project.

The Conseil des ministres then authorized, by order, the issuance of a certificate of authorization approving the TQM project pursuant to the Quebec Environment Quality Act. The certificate contains a number of conditions dealing with, among other things, the width of the right-of-way, drinking-water supply, emergency measures, watercourse crossings and provisions relating to the route through the Memphrémagog MRC.

Still at the provincial level, TQM must obtain permits from the Ministère des Transports du Québec to cross highways under its jurisdiction.

The project would require crossing the St. Lawrence and Richelieu rivers, as well as using île aux Fermiers as an intermediate point for the directional drilling required for the St. Lawrence River crossing. As owner of île aux Fermiers located in the St. Lawrence River, Environment Canada, through the Canadian Wildlife Service, must authorize the disposal of any interests in this land, and, under the CEAA, an environmental assessment of the project is required before that power of authorization can be exercised.

The crossing of navigable waters requires authorization from Fisheries and Oceans Canada, Canadian Coast Guard, under the Navigable Waters Protection Act. Fisheries and Oceans Canada, Fish Habitat Management, has a role as well in the protection of fish and their habitat. Certain watercourse crossings may require an authorization under section 32 or subsection 35(2) of the Fisheries Act. If such an authorization were required, under the CEAA, an environmental assessment of the project would also be required before that power of authorization could be exercised.

Furthermore, the Canadian Transportation Agency may be called on to issue authorizations for crossings over national railways rights-of-way, but only if the national railways and TQM disagree with respect to the crossings. In such a case, under the CEAA, the issuance of a Canadian Transportation Agency authorization would have to be preceded by an environmental assessment of the project.

Finally, under the NEB Act, a certificate of public convenience and necessity must be issued in respect of the project, subject to the approval of the Governor in Council. Under the CEAA, an environmental assessment of the project is also required before the certificate can be issued.

2.5 Scope of the Assessment

The Board undertook a scoping determination process for the environmental assessment of the PNGTS Extension in accordance with the Regulations Respecting the Coordination by Federal Authorities of Environmental Assessment Procedures and Requirements in order to fulfil its obligations under the CEAA. Prior to making its final scoping determinations, the Board solicited comments from the public on a draft scope of the environmental assessment prepared in consultation with other federal departments and agencies.

The Board reviewed the comments it received following the public consultation and, in a letter dated 10 September 1997, provided the final scope of the environmental assessment of the PNGTS Extension project.

The scope of the project includes the activities and undertakings considered to make up the project. The factors to be assessed are those identified in subsections 16(1) and 16(2) of the CEAA. The scope of the factors includes a determination of the environmental components which are assessed, as well as the spatial and temporal boundaries associated with those components. The final scoping determinations provide a framework for the environmental assessment. For more information on the final scope of the environmental assessment, see Appendix II.

2.6 List of Activities, Location and Schedule

TQM proposes to construct the gas pipeline simultaneously over three work zones. The first zone would cover the first 15 km of the route, from Lachenaie to Boucherville, including Montreal Island and the surrounding area. The second zone would cover the next 88 km, from Boucherville to Waterloo. The third zone would cover the 110 km separating Waterloo from East Hereford.

The gas pipeline would be installed within the limits of a 23-metre-wide permanent right-of-way. To facilitate the construction work, a temporary ten-metre-wide right-of-way, adjacent to the permanent right-of-way, would be required along the entire route. Additional work areas would be required at more or less regular intervals along the route during the construction phase to account for soil-drainage systems and to facilitate the crossing of obstacles, like watercourses, highways, railways and other infrastructures.

The pipeline would be installed under a depth of cover of a least 1.2 m on agricultural land and 0.9 m in forested areas. Under watercourses, the pipeline would be installed 1.5 m below the prescribed profile, and a minimum cover of one m would be ensured beneath the improved bottom of boundary ditches or other large ditches.

Cathodic protection fields would be installed to protect the pipeline against corrosion. The exact location of these underground structures would be determined following analysis of the soil and a detailed engineering study.

The project would also require the construction and operation of above-ground facilities, namely, a compressor station, two metering stations and block valves in the first year of operation. In the second year, another compressor station and a gas aftercooler would be added.

In addition to these facilities, TQM plans to upgrade its Control and Communication System to enable it to monitor and control the new compressors and metering stations.

The project would also require: the construction and operation of a number of access roads and temporary work areas; the modification of existing TQM facilities so they can be connected to the new facilities; and other structures upstream of the TQM system (notably on TransCanada's system, for example) to enable TQM to receive the gas volumes required for the operation of its system, including the PNGTS Extension.

Directional drilling is planned under Highway 40, three major watercourses (Rivière-des-Prairies, the St. Lawrence River and the Richelieu River) and under a number of other smaller watercourses, such as the Yamaska and Magog rivers.

The construction of the proposed facilities is scheduled from April to October 1998, with operations commencing on 1 November 1998. The East Hereford Compressor Station and the gas aftercooler at the Lachenaie Compressor Station would be constructed from April to October 1999 and put into operation on 1 November 1999.

The start-up date of 1 November 1998 is the result of two constraints: the lease expiration date with Montréal Pipe Lines Limited and Portland Pipe Line Corporation; and the scheduled operation date of the project's American counterpart, i.e., the PNGTS gas pipeline in the United States.

2.7 Routing and Site Selection

2.7.1 Routing Description

TQM carried out a three-stage environmental assessment of the routing: the assessment of corridors within the study area; the assessment of alternative routes within the selected corridor; and the detailed assessment of the selected route, in which site-specific environmental effects and applicable mitigative measures were analyzed.

The overall study area (Figure 2.1) was delimited based on factors related to the project itself and the receiving environment. The principal technical and economic factors were the selection of the supply point in the municipality of Lachenaie northeast of Montréal, various potential natural gas delivery points such as East Montréal, Granby and Waterloo, and the interconnection point with the PNGTS pipeline in East Hereford on the Québec/New Hampshire border. Other significant factors were related to the receiving environment to be crossed or avoided, such as watercourses, hills and mountains, urban centres, and existing infrastructures.

TQM took a number of factors into consideration in formulating selection criteria for the location of the pipeline. The Company adopted the principle of following existing rights-of-way where available, technically possible, and economically feasible. The Company considered both paralleling and joint use of existing rights-of-way. In addition, TQM used the recommendations of the 1980 Quebec interdepartmental committee which developed a set of principles that, when applied to a linear development project, were meant to minimize adverse effects on the environment, agriculture and urban development. These recommendations include, but are not limited to, the following principles:

Table 2.1 provides a summary of the extent to which existing rights-of-way would be followed.

Of the 117 km of route adjacent to existing rights-of-way, approximately 50 km would be through forested area. Of the 96 km route in new right-of-way, approximately 25 km would be through forested area and would require removal of trees.

TQM divided its corridors into three sections (Figure 2.1): Lachenaie to Granby; Granby to Magog; and Magog to East Hereford. The following paragraphs discuss the general location of the route, land uses, key environmental constraints, and the rationale for the alternative corridors and routes that were considered.

Table 2.1 Approximate Percentage of Proposed Route Adjacent to Existing Rights-of-Way and in New Right-of-Way % of total route Route Adjacent to an Existing Right-of-Way Pipeline 20 Roads 20 Powerlines 15 Sub-total 55 Route in New Right-of-Way 45 Total 100 Total Length of Right-of-Way for Proposed Route 213 km The Lachenaie to Granby section commences in an agricultural area, crosses parklands in the northern part of the Montréal Island and île aux Fermiers, before reaching the south shore of the St. Lawrence River. Only a few hundred metres out of the 11 km traversed between Lachenaie and the south shore intersects built-up areas. However, the route intersects four major highways and involves four river crossings. From the South Shore of the St. Lawrence River to Sainte-Julie, a distance of some nine km, the corridor trends east-southeast through agricultural lands, small towns and satellite residential communities. Within the corridor, the route avoids residential areas and parallels a railway line and a Hydro-Québec right-of-way for part of the distance.

From Sainte-Julie to a point half way between Saint-Césaire and Granby, TQM studied two corridors over a distance of approximately 30 km. The east corridor is located north of Mount Saint-Hilaire and Mount Rougemont, and east of Mount Yamaska. The west corridor follows a valley between Mount Saint-Bruno and Mount Saint-Hilaire, and runs south of Mount Rougemont bypassing the urban settlements of Saint-Mathias-sur-Richelieu, Marieville, Sainte-Angèle-de-Monnoir, and L'Ange-Gardien.

TQM stated that it chose the west corridor on the basis that it was determined to cause the least overall impact. The west corridor took advantage of existing right-of-way for 80% of its length. It was judged preferable to the East corridor on the basis of a relatively lesser impact on agriculture, forestry, vegetation and wildlife, and length (seven km shorter). The eastern corridor was judged superior in that fewer aquifers and wells were encountered, and that it was marginally less likely to encroach on heritage and urban areas. TQM indicated that it was the balance of the above factors rather than any one or two specific factors which resulted in a decision. No specific weighting was given to particular factors and the decision was based on a qualitative assessment.

In the 60 km chosen corridor between Sainte-Julie and Granby, some 90% of the land use is agricultural. The selected route within the corridor is on cultivated lands for the most part, although the proportion of forested land crossed increases toward Granby. The route parallels the Montréal Pipe Line Limited and Gaz Métropolitain rights-of-way for 5 and 38 km, respectively.

The Granby to Magog section covers a distance of 53 km through a forested landscape. The route, which commences two km south of Granby, proceeds easterly through rolling topography for 13 km where it enters the rugged Appalachian region. From that point until Magog, some 40 km further on, the route crosses an area that is bordered by a chain of mountains creating a natural barrier, such that, according to TQM, only a few valleys allow for the construction of a linear infrastructure such as a pipeline or a highway.

Following TQM's routing criteria, TQM favoured twinning existing rights-of-way and, in particular, the Gaz Métropolitain pipeline right-of-way. TQM maintained that this routing posed a lesser degree of environmental impact than if the Company were to clear a new swath through forested area between Granby and Magog.

Given the physical impediments of the mountains, the presence of an existing pipeline right-of-way, and its assessment of a lesser adverse environmental effect, the Company elected not to identify any other alternative routes in this corridor.

The route passes just south of Waterloo where a delivery point into the Gaz Métropolitain system and a metering station are planned. At Lake d'Argent, midway between Waterloo and Magog, the initially preferred route turned south between Lake d'Argent and Lake Orford. However, following consultation with the MRC of Memphrémagog, an alternative route (i.e., Stukely-Sud and Austin route) was proposed, primarily to address concerns with potential adverse effects to the recreation and tourism vocation of the region. The alternative route turns south three km west of Lake d'Argent, crosses Highway 10 and then turns east about one km south of the Highway (Figure 2.2). At the south end of Lake Orford, the route parallels Highway 10 to Magog.

The section between Magog and East Hereford covers a distance of 81 km through hilly countryside with mixed forested and cultivated lands. Immediately north of Magog and for a distance of 11 km, TQM proposed an alternative route bordering Highway 55 in response to the MRC of Memphrémagog's requirement to take into account the visual impact of the route on the recreation and tourism vocation of the region. Rather than going cross-country as the initially-preferred route did, the alternative route is adjacent to Highway 55 (Figure 2.3). It rejoins the initially-preferred route south and east of Lake Massawippi, where it follows an abandoned Hydro-Québec right-of-way for about four km, to a point south of Ayer's Cliff. In this segment of the corridor, Bunker Hill is transected.

Two separate corridors were considered for the 65 km route between Ayer's Cliff and East Hereford. TQM chose the northern corridor over the southern one because, in its opinion, it had a lesser impact. It assessed the northern route as having a relatively lower potential impact on agriculture, forestry, watercourse crossings, heritage, and socio-economic considerations. According to TQM, the south route would have a clear advantage on the vegetation and wildlife criteria and a marginal advantage on the aquifers and wells criteria. Neither route was preferred from the point of view of the length of the route or the availability of existing rights-of-way.

The northern corridor runs from Ayer's Cliff for a distance of 45 km to a point east of Coaticook. The route follows municipal boundary lines for most of the distance, and a secondary roadway for 13 km. Two-thirds of this route passes through cultivated lands and one-third through forested lands. The corridor turns south at a point 22 km east of Coaticook, and follows valleys to join the New Hampshire connection point approximately five km south of the settlement of East Hereford. A compressor and metering station are located within one km of the connection point. The main land uses encountered in this area are agriculture (two-thirds) and forestry (one-third).

2.7.2 Above-Ground Facilities Site Selection

Compressor stations would be located at the initial and end points of the pipeline to facilitate the receipt and transmission of gas. The proposed Lachenaie Compressor Station would be situated on a 5 000 mý (255 m x 255 m) forested site north of Montréal Island and east of Highway 640. The site is zoned industrial with the nearest residential neighbourhood being approximately one km from the site.

The proposed site of the East Hereford Compressor Station is located on the east side of Highway 253, approximately five km south of the settlement of East Hereford and less than one km from the U.S. border. Neighbouring a local cemetery and a sawmill, the site is located inside a wooded area and surrounded by agricultural land. There are three residences approximately 200 m from the proposed station. The site, which is zoned industrial, would occupy 40 000 mý (200 m x 200 m) of land.

A metering facility would be constructed to measure the export gas flow. This facility would be placed within the limits of the East Hereford Compressor Station site to take advantage of economies of co-location and reduce potential environmental impacts.

Another proposed metering facility would be required at Waterloo for the delivery of gas to Gaz Métropolitain. The site would be located directly south of the proposed route in a densely wooded area. The site would require 2 500 mý of land (50 m x 50 m) and contain two facilities, a meter building, and a control building.

TQM indicated that sectioning valve sites would be located between eight and 25 km apart. The specific number and locations of valves have yet to be determined. Typically valves would be installed closer together in urban areas and further apart in rural areas. The valve sites would be built on the right-of-way. Valve sites would occupy approximately 25 m2 (5 m x 5 m) with the perimeter being fenced. Land for these valve sites would be purchased rather than leased. Figure 2.2 Preferred Route and Alternative Route - Stukely-Sud/Austin

Figure 2.3

Preferred Route and Alternative Route - Highway 55

2.8 Alternative Means of Carrying Out the Project

Paragraph 16(2)(b) of the CEAA provides that every comprehensive study of a project shall include a consideration of alternative means of carrying out the project and the related environmental effects. In the final Scope of the Environmental Assessment, the project was to start at Lachenaie and end at East Hereford. Therefore, alternative routes for carrying out the project are considered in this section as those routes starting at Lachenaie and ending in East Hereford. Potential routes involving different starting and terminal points are discussed in Section 2.9 - Alternatives to the Project.

"Alternative means" of carrying out the project within the CEAA refers to methods which are technically and economically feasible and must consist of methods that are within the scope and control of the proponent of the project under review.

TQM considered two alternative corridors, for a 30 km section of route from Sainte-Julie to Granby and for a 65 km section of route from Ayer's Cliff to the village of East Hereford. Factors taken into consideration were the physical environment, agriculture, forestry, river bank stability, vegetation and wildlife, archaeology and heritage, engineering, socio-economic matters, and technical and economic feasibility. In each case, the competing corridors were analyzed and ranked according to these criteria to arrive at an overall decision. Also considered was the use of existing rights-of-way. At the end of the process, TQM made a determination on the basis of a qualitative assessment as to which corridor, in its view, was preferable in the balance.

In terms of the routes within corridors, TQM proposed over 50 modifications, two of which received considerable attention during the hearing. These two route modifications are for Stukely-Sud and Austin and Highway 55 and were described previously.

In respect of this application, sufficient information was provided by TQM regarding alternative routes. Therefore, the requirement that there be evidence on alternative means of carrying out a project has been met.

2.9 Alternatives to the Project

The meaning of "alternatives to" in the context in which it is placed in the CEAA incorporates not only a functionally different method for the transportation of gas but also any other feasible method for the transportation of gas, including the option of not undertaking the project.

Alternatives to the project were included in the factors to be assessed in the final Scope of the Environmental Assessment.

The following potential alternatives to the project were considered: