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Mémoire de Bruce Miller

Présenté aux membres de la commission du B.A.P.E.
Concernant le projet de prolongation du Gazoduc TransQuébec and Maritimes Août 1997

Table of Contents

1. The project

1.1. Synopsis

1.2. The Context

1.3. PNGTS Extension: the stand-alone version

1.4. PNGTS Extension: The Hub Concept

1.5. The Secondary Justification

1.6. Summary/Recommendations

2. The Qu?bec corridor

2.1. Synopsis

2.2. Border Crossing

2.3. Proposed Qu?bec Corridor

2.4. Alternative Qu?bec Corridors

2.4.1. Unstudied Alternative number one

2.4.2. Unstudied Alternative number two

2.5. Summary/Recommendations

3. Visual impact

3.1. Synopsis

3.2. Eastern Townships

3.3. Mitigation of visual impacts by the promoters

3.4. Summary/Recommendations

4. Environmental impacts

4.1. Synopsis

4.2. Soil

4.2.1. Microrelief

4.2.2. Soil constituency

4.2.3. Mechanical damage

4.2.4. Erosion

4.3. Wetland

4.4. Flora

4.5. Fauna

4.6. Summary/Recommendations

5. Company credibility

5.1. Synopsis

5.2. Private property and trespassing

5.3. Denial

5.4. Summary/Recommendations

6. Safety

6.1. Risk assessment study

6.2. The Magog liquid hydrogen plant and the pipeline

6.3. Emergencies in a Rural Environment

7. Conclusion

Appendix A: Supporting Documents

Appendix B: Emergency Response in the Rural Environment

Against time and the damages of the brain
Sharpen and calibrate. Not yet in full,
Yet in some arbitrated part
Order the façade of the listless summer.

James Agee
Let Us Now Praise Famous Men

1. The project

1.1. Synopsis

Currently there are many projects whose objectives are identical with the principal justification for the PNGTS Extension: the export of Canadian natural gas to New England. The relative merits of these projects must be understood in order to choose rationally between them. See The Context, Section 1.2.

As a stand-alone project to export Western Canadian gas to New England, the PNGTS Extension’s main justification makes small sense in light of the developing Canadian gas reserves at Sable Island and Hibernia. See PNGTS Extension: the stand-alone version, Section 1.3.

As one element of "the hub concept", PNGTS Extension is part of Hydro-Qu?bec’s (of whom the promoters are subsidiaries) strategy to become the hub of natural gas and electrical energy for Northeast America. Such a scenario does not appear to be in the good interest of Qu?bec society or gas consumers. See PNGTS Extension: The Hub Concept, Section 1.4.

The promoters say the second justification of PNGTS Extension is to service new Qu?bec markets and bolstering existing ones. It is a very wan attempt to make the PNGTS Extension project more palatable domestically. See The Secondary Justification, Section 1.5.

1.2. The Context

The PNGTS Extension is one of many projects and sub-projects currently being proposed to transport natural gas to the New England region. A summary of these projects appears in Table 1. All of these proposed projects have been projected to be in operation well in advance of any crucial New England energy shortage.

Promoters of these projects are responding to factors which are transitory and short-term:


Lack of transportation

High U.S. prices, low Canadian prices

Deregulation in the U.S.

It would be undesirable for too many of these projects to be approved, or the wrong ones. The result could easily be surplus gas in New England and an excess of environmentally unfriendly pipelines in Canada and the United States. At the BAPE hearings we understood that pipelines are not disposable items.


Table 1. Summary of pipeline projects aiming to deliver Canadian natural gas to the US.

Project Ownership Cost Transport: From-To Cu.Ft/Day By: Len.
TQM PNGTS Ext TQM (TCPL/Gaz Metro) $270-M Cdn (Western /Sable Island) to US N.E. Lachinie – East Hereford
11/98 213km
(Doc-3-1, Doc-4-1, Doc-5-1, Doc-6-1)
PNGTS (Bay State Gas/TCPL/Gaz Met/et al) $302-M
Cdn (Western /Sable Island) to US N.E. Pittsburgh NH – Portland ME 178-M
11/98 290mi.
TQM (TCLP/Gaz Metro) $305-M Cdn (Sable Island) – US N.E. St. Nicolas – NB Border
Nov 1999 262km
TransMaritime Gas Ltd TransMaritime (TCPL/Gaz Met/Consumers Gas)     Goldboro NS – NB/QC Border     638km
Maritimes & Northeast Pipeline (Doc-7-1) M&NE (Westcoast Energy(Cdn)/PanEnergy/Mobil Oil (US)) $583-M Cdn (Sable Island) – Eastern Canada /US N.E. Country Harbor NS – Portland ME     558 km
Tatham Offshore
(Texas)   Cdn gas (Sable Island/ Hibernia) – US N.E.     1999  
Alliance Pipeline Ltd (Doc-8-1) 18-company consortium $3.6-B Cdn gas (BC) Fort St. John BC – Chicago, IL 1.25-B 11/99 3000 km
Northern Border Pipeline (Doc-8-2) Northern Border Pipeline Co. (Enron/TCPL) $793-M
Cdn gas (SK) Monchy SK – Chicago, IL 2.4-B 11/98  
Northern Border Project (Doc-9-1,
Northern Border Pipeline Co. and Natural Gas Pipeline Co. of America   Cdn/US gas Canada/Montana/North Dakota – Chicago 1,226-M   478mi
Natural Gas Pipeline Co. (Doc-10-1) Natural Gas Pipeline Co. of Lombard, IL $1.4-B


(Cdn gas) Chicago – New York 500-M – 1-B 2000+ 1,350km
Alco/Shell   Cdn gas Alberta – New York via Chicago 1.2 B    


While reading the rest of this memorandum the reader should keep in mind this fact: unless recommendations and decisions for the PNGTS Extension and other projects are based on some understanding of their relative merits, there will already be too small a chance of avoiding long term environmental damage.

1.3. PNGTS Extension: the stand-alone version

The promoters represent PNGTS Extension as a stand-alone, self-sufficient project whose primary justification is the maintenance of exports of Western Canadian natural gas to New England.

Considering the nearby reserves of natural gas being developed at Sable Island and Hibernia, how can the stand-alone PNGTS Extension transport Western gas to New England on a competitive basis? Are any companies looking into transporting gas from Sable Island and Hibernia to the American Northwest?

Table 2 shows the distance Western Canadian gas must be transported to reach Portland using the TCPL/TQM/PNGTS route. It also shows the distances for Sable Island gas to reach Portland using two other proposed routes: Maritimes & Northeast (M&NE), and Tatham. Compared with Sable Island gas transported by the proposed M&NE route, TQM’s Western gas would have to be transported 5.5 times further to reach Portland. Compared with Sable Island gas transported by the proposed Tatham route, Western gas would have to be transported 7 times further to reach Portland.


Table 2.

Source Route Canadian






Western Canadian TCPL/TQM/PNGTS 2613 467 3080
Sable Island M&NE 300 258 558
Sable Island Tatham     440


Table 3 compares the kilometers of new construction necessary to transport Western gas to Portland using the TQM PNGTS Extension proposal with the kilometers of new construction necessary to transport Sable Island gas to Portland via the overland M&NE proposal and the undersea Tatham proposal.


Table 3.

Source Route New Canadian




New Total


Western Canada TCPL/TQM/PNGTS 213 467 680
Sable Island M&NE 300 258 558
Sable Island Tatham     440


The further gas is transported, the more it costs. The PNGTS Extension project is economically weak because its longer transport distance means higher costs of construction and operation.

1.4. PNGTS Extension: The Hub Concept

When the promoters described the benefits of the PNGTS Extension project they factored in the Sable Island pipeline project for which they have applied. Therefore, PNGTS Extension should be examined as part of the promoters "hub concept" as well as a stand-alone project.

In the comprehensive policy statement read by Mme. Sylvie Brochu the promoters claim that Qu?bec as a society has adopted an energy policy of which this project is part and parcel. I challenge this distorted view as a cynical, flag-waving attempt on the part of the promoters to validate their project.

Have Qu?becers really decided that they want a large provincial energy monopoly like Hydro Qu?bec aggressively expanding into gas energy and burying natural gas pipelines by the thousand kilometers around La Belle Province in order to become gatekeepers for a natural resource which is not even theirs?

And how would such a grandiose system be paid for? By spreading the construction and transportation costs across the Canadian national system say Gaz M?tropolitain representatives Thierry Vandal and Jean Trudelle.

PNGTS Extension promoters claim that their "hub concept" would provide a more secure supply and lower prices to Qu?bec consumers by providing two sources of gas. Even if this dubious claim could be substantiated, the promoters should be reminded that it is their Sable Island project, not the PNGTS Extension project, which would transport Sable Island gas to Qu?becers.

Or perhaps not. The National Energy Board may want to note the hypothetical scenario suggested by John Flumerfelt at the East Hereford BAPE hearings. Mr. Flumerfelt said that if M&NE were to be the "winning rabbit", then the PNGTS and PNGTS Extension could be used to transport Sable Island gas to Qu?bec. I was under the impression that the application for the PNGTS Extension project was based upon natural gas exports.

Questions of subsidies aside, just as the stand-alone PNGTS Extension transporting Western gas to Portland would compete poorly with gas transported directly from Sable Island or Hibernia, so too would the promoters’ contrived hub system.

Table 4 indicates that the promoters’ hub system would transport gas from Sable Island three times the distance required by the M&NE project and four times the distance required by the Tatham project. Where is the economic advantage?


Table 4

System Existing








TQM 200 1113 1313 467 1780
M&NE 0 300 300 258 558
Tatham     0   440


1.5. The Secondary Justification

The benefits to Qu?bec described by the promoters fall into the categories of nebulous market speculation and corrections of technical deficiencies in existing networks. Construction of a 910mm pipeline is not an economic approach to achieving any of the benefits cited.

While New England natural gas markets have at least been demonstrated to be real, the promoters have offered no hard evidence for what they claim to be vital markets in the Eastern Townships of Qu?bec. We are told that the pipeline could:

"meet current customer demand in the Eastern Townships"

respond to indications of "possible investments" by Magnola

be "a solid basis for future development"

"supply new markets with the additional compression stations, if required"

"foster the potential development of a co-generation project in the near future"

"ensure a better supply of gas to consumers in Qu?bec"

"improve the inter-connection of our energy carrier network"

"increase the potential use of natural gas here in Qu?bec"

serve "other potential markets, such as Coaticook…"

"allow TQM to supply the existing natural gas network that supplies the Eastern Townships and Mont?r?gie…"

provide "a synergy between the U.S. projects and also a consolidation of Gaz Metropolitain’s supply in the Eastern Townships…"

"be able to supply also a number of farmers"

"provide a more secure supply of gas to all gas consumers in Qu?bec"


The loosely-knit fabric we are offered unravels quickly under examination. Look at the promoter’s examples of Magnola and JB Asbestos as potential markets for which PNGTS Extension would be needed. The location of these two facilities, Asbestos, is literally surrounded by gas: clockwise, there is Drummondville, Victoriaville, East Angus, and Windsor, all served by the existing Gaz M?tropolitain network and as little as 22 kilometers away from Asbestos.

For another example, consider the Coaticook Market. The promoters brought up the Coaticook market ten times during the hearings and Jean Trudelle claimed that its loss would be one of two factors that would create a "major impact" on Gaz M?tropolitain should the PNGTS Extension be cancelled. Nevertheless, Mr. Trudelle was at a complete loss to name so much as one single company with whom discussions had been held, much less demonstrate a pent-up demand for natural gas in Coaticook.

If the promoters can truly demonstrate the necessity of a 910mm pipeline to service Saint-Basil le Grand, Sainte-Hyacinthe, Drummondville, Victoriaville, Asbestos, Windsor, Thetford Mines, East Angus and other centers in the northern industrial belt of the Eastern Townships, they have only to look at a roadmap of Qu?bec to see where to put it (see Map-1).

The southern part of the Eastern Townships is overwhelmingly touristic, recreational, and agricultural. It is not an area of expansive industrial development. An industrial project like this pipeline that would forever change the landscape of Qu?bec’s premier green zone is unneeded and unwelcome.

1.6. Summary/Recommendations

The economic justifications given for the PNGTS Extension as a free-standing, self-sufficient project are questionable because other projects could more efficiently provide the same results.

As one element of a huge, contrived, inefficient and expensive gatekeeping system the PNGTS Extension fares little better.

PNGTS Extension is the wrong rabbit for the carrot. Let the best rabbit win.

2. The Qu?bec corridor

2.1. Synopsis

The promoters of THE PNGTS Extension committed a grave, fundamental error in not closely coordinating with PNGTS in designing an overall corridor for the two projects. From a Qu?bec point of view, the revised choice of the PNGTS Extension’s ending point was arbitrary: it was established solely for American convenience. No advanced consideration was given, either by the American or Canadian promoters, to the impact of a revised route on Qu?bec soil. See Section 2.2, Border Crossing.

Once burdened with such an arbitrary ending point, the Canadian promoters designed an inflexible route within a narrow corridor which was bound to be problematic and controversial due to its physical geography and socio-economic characteristics. See Section 2.3, Proposed Qu?bec Corridor.

At least two alternative corridors are available that could accommodate the primary objective of this project. Both alternatives would avoid the southern part of the Eastern Townships where benefits from the project are nil and where negative impacts are the greatest. See Section 2.4, Alternative Qu?bec Corridors.

2.2. Border Crossing

The promoters nominate a method of routing determination which begins with a starting point and an ending point and then locates a route which best satisfies the applicable criteria.

However, in the case of PNGTS Extension and PNGTS, the paradigm should have been modified to include a third point – the border crossing between Qu?bec and the United States. The border crossing is most critical because while Lachenaie and Portland are givens which are fixed, the border-crossing is moveable, although once fixed it becomes a fixed point from two perspectives.

One would think that the decision on locating the border crossing would have been the subject of considerable discussion among the Canadian and American promoters, especially considering the opportunity afforded by their interlocking boards of directors. There was certainly time, the promoters have told us that preparations for PNGTS Extension have been underway for five years. It is a sort of negligence that there was no coordination:

En fait, c'est deux ?quipes compl?tement s?par?es. M?me si quand m?me les actionnaires du c?t? canadien, soit Trans-Canada PipeLine et Gaz M?tropolitain, sont aussi actionnaires du c?t? am?ricain, dans les d?tails de planification des trac?s, les deux ?quipes travaillent ? obtenir le trac? de moindre impact, chacun de leur c?t?.

Evidemment, lorsqu'il y a eu ce processus pour passer d'un trac? ? l'autre, il est certain qu'il y a eu des v?rifications de faites aupr?s du trac? canadien s'il n'y aurait pas de probl?mes majeurs ou s'il n'y aurait pas de blocage syst?matique, qui emp?cheraient d'aller livrer le gaz au point sp?cifique qu'ils nous demanderaient. Et ? ce moment-l?, bien, il n'y avait pas de ces obstacles vraiment incontournables. Alors, la modification du c?t? am?ricain a ?t? faite. Et par la suite, nos ?tudes d?taill?es ont eu lieu selon le trac? qui nous amenait au point de East Hereford.

Two completely separate teams working independently of each other. No substantial consultations about the effects of each other’s work upon the other. Is this the same TQM that says they will responsibly coordinate an effective emergency response program among forty municipalities?

After being presented with the revised border-crossing did the Canadian promoters see fit to do any sort of comparative study between the original route and the new "accidental" Canadian route?

Non, il n'y a pas eu d'?tude d?taill?e entre les deux trac?s, parce que lorsque la modification de point d'entr?e aux Etats-Unis a ?t? faite, on n'avait aucun mandat de donner d'?tude d?taill?e au niveau du trac? qui s'en allait ? Highwater. Alors, c'?tait simplement des trac?s pr?liminaires. Au niveau cartographique, il n'y avait pas eu d'inventaire ou d'?tude d'impact ou d'analyse des impacts.

Donc, on peut dire qu'il n'y a pas de comparaison d'impacts entre le trac? Highwater et le trac? East Hereford.

Mr. Trudelle says there was no mandate for doing a detailed comparison between the two corridors. Do not Qu?bec Environment Ministry guidelines include requirements for studies of alternative routes? Has the Ministry received any such studies?


We have seen how the border crossing was changed, the next question is why was the border crossing changed? The two reasons given by Mr. Flumerfelt were:

Lower environmental impact of the new route compared to the original one which was parallel to the existing Portland-Montreal pipeline.

Closer to prospective clients in New Hampshire.

Mr. Flumerfelt said that the new American route is improved in terms of environmental impact . Mr. Flumerfelt might take this view because the new American route is shorter while the new Canadian route is 84 kilometers longer. Nevertheless, it was clear that many New Hampshire citizens at the FERC hearings on the 9th of July, 1997 in Colebrooke felt that the new route presented serious threats to their environment.

A New Hampshire landowner, Claire Lamm, listed some of those threats in her presentation at the Colebrooke FERC hearings:

Passage through many wetlands.

Passage through many large and important sand and gravel aquifers.

Infringements upon a sector of the Connecticut River designated as "Natural" by the New Hampshire Rivers Management Protection Program.

Siting of the pipeline within twenty-five to fifty feet of 71 residences and within zero to twenty-five feet of 52 other residences.


And what abut the other reason? Jean Trudelle said PNGTS told him they moved the border-crossing in order to get closer to Wasau Paper in Groveton, New Hampshire.

"En fait, j'ai fait la demande aupr?s de la compagnie PNGTS. Alors les motifs sont effectivement le rapprochement des march?s, les compagnies de papier du New Hamsphire. On parle de Wausau Paper et Androscogin, deux compagnies ? fort volume dans le New Hamsphire. Donc, le gazoduc, actuellement, le trac?‚ passe directement pr?s de ces clients. Donc, il n'y a aucune lat?rale, si on veut, pour desservir ces deux clients du New Hamsphire, alors que le trac?‚ qui passait le long de la ligne de Portland PipeLine n?cessitait des lat?rales pour aller les desservir.

Donc, il y a effectivement, au niveau commercial, un avantage ? se rapprocher des march?s du c?t? am?ricain."

Now, the amended PNGTS application of May 30th 1997 states that there are three laterals along the new route:

about .7 mile (Groveton Lateral)

about 26.9 miles (Rumford Lateral)

about 16.6 miles ((Jay Lateral)

The Rumford and Jay laterals are unchanged between the original PNGTS route and the amended route. A lateral to Groveton from the original PNGTS route would have been about 11 miles. From the new route Groveton is .7 miles.

Are we to understand from this that 85 kilometers of 610mm (24") pipeline were added to the Canadian route to save 10.3 miles of 8-inch lateral in Groveton, New Hampshire?

When will the public find out the real reason behind the change in the original routing of the PNGTS Extension?

2.3. Proposed Qu?bec Corridor

After the promoters of the PNGTS Extension blindly accepted the East Hereford border crossing at American convenience, they compounded their first error by making a poor choice of corridor.

The promoters say they want to service clients in Qu?bec with the PNGTS Extension. Although nearly all of those clients are in a band along the northern part of the Eastern Townships, the promoters selected a corridor which takes the pipeline through the overwhelmingly non-industrial, scenic and recreational southern part of the Eastern Townships.

In addition, the southern corridor includes just about every imaginable natural barrier to a pipeline, including ubiquitous rock formations, mountains, wetlands, rivers, and lakes. In places the natural barriers constrict the corridor so severely that, as the promoters have acknowledged, it is difficult to find a good route.

A good example of this is in the Ayer’s Cliff area. Squeezed through a funnel-like corridor between Lac Memphremagog and Lac Massawippi, the route meanders across an exceptional eco-system and highly scenic hillsides before making a hazardous and scarring 200 meter descent of the Bunker Hill escarpment. At that point the pipeline would pass within eight-hundred to one thousand meters of the southern end of Lac Massawippi, a 300-site camp ground, and a boarding school with over a hundred children in residence.

2.4. Alternative Qu?bec Corridors

Given the strong and consistent public concerns voiced during early public notification meetings, BAPE informational meetings, and BAPE hearings why were there no serious studies done as required by the Minister of the Environment’s directives? Where are the real alternatives that were supposed to have been studied for this project?

2.4.1. Unstudied Alternative number one

Alternative number one must be the short and direct route to Portland: the originally proposed, but never studied route which follows the Portland-Montreal pipeline right-of-way.

The original Canadian route is fully compatible with the PNGTS Extension’s primary economic justification and it avoids nearly all of the major environmental and social impacts which plague the revised proposed corridor.

The promoters, Canadian and American, should re-examine the originally proposed route with an eye towards using it.

2.4.2. Unstudied Alternative number two

Alternative number two would be a slightly longer, more central trace which would end at a modified Quebec/New Hampshire border crossing. We shall refer to this route in this memorandum as the Central PNGTSE. See Map-1.

The Central PNGTSE route could roughly be described by a line connecting Lachenaie, St-Hyacinthe, Windsor, Cookshire, and a point somewhat to the west of East Hereford. The actual route would be south of that line.

Such a route would be marginally longer. Although longer routes mean greater impacts in general, this may be a case in which a slight increase in length could decrease the impact. The Central PNGTSE would:

Pass closer to the markets perceived by the promoters.

Avoid human settlement to a greater degree.

Utilize more low-impact cultivated agricultural land.

Reduce temporary negative impacts upon fauna.

Produce fewer negative effects upon future land development.

Use fewer areas of higher environmental sensitivity.

Cross fewer streams, although one additional river-crossing.

Greatly reduce negative impacts upon recreational and touristic areas.

2.5. Summary/Recommendations

The Canadian promoters used neither foresight nor hindsight during the initial stages of the project and, by this negligence, necessitated an additional 85 kilometers of pipeline construction in Canada.

Furthermore, more than half the pipeline route passes through the green, environmentally sensitive, non-industrial, scenic, recreational, and touristic southern Eastern Townships where benefits are essentially nil..

The route chosen by the promoters through Qu?bec’s green zone is unacceptable. Tell the promoters to study the alternatives.

3. Visual impact

It is all very well and good to speak, as the promoters did, of limiting the perspective of the pipeline in one small area of an autoroute where cars are passing at 140 kilometers an hour. But at the same time we must think about the impact of more than one hundred kilometers of pipeline running up and down the green hills of the Eastern Townships and of their visibility for kilometers around.

3.1. Synopsis

Because they are linear, pipelines create a high visual impact. Their visual impact is heightened by routing them through hilly and mountainous terrain such as those found in the touristic and recreational regions of the Memphremagog and Coaticook MRC’s. See section 3.2, Eastern Townships.

The promoters pay lip service to reducing the visual impact of their pipeline route and above ground facilities but as usual their actions do not measure up to their words. See section 3.3, Mitigation of visual impacts by the promoters.

3.2. Eastern Townships

Bunker Hill is a long, hilly ridge which begins at the southern tip of Lake Massawippi and extends nine kilometers to the northern end of Fitch Bay, an appendage of Lac Memphremagog. As the longest and second highest ridge in the vicinity of Lac Massawippi and Ayer’s Cliff, Bunker Hill has a characteristic form which is an integral and highly visible component of a dramatic panorama.

From the perspective of Mont Orford to the west, Bunker Hill presents a gradual ascent covered by a mixture of farms and woodlots. The east side of Bunker Hill descends precipitously and it is covered by mixed forests growing in a rich soil covering rock.

Viewed from Route 143 along the eastern shore of Lac Massawippi, Bunker Hill is part of a sweeping view of the lake and the hills on it’s western shore. See photos xxx and xxx.

Viewed from Route 141 between Coaticook and Ayer’s Cliff, Bunker Hill is prominent in a panoramic view of Mont Orford. See photos xxx.

Bunker Hill is viewed from as far away as Mont Orford to the west, and the Pinnacle in Baldwin’s Mills to the southeast.

Bunker Hill is visible from AutoRoute 55 which is a major thoroughfare for tourists entering Qu?bec from New England.

As can be seen in the accompanying photographs, the visual impact of the former Hydro right-of-way over Bunker Hill has been greatly attenuated by twelve years of growth since the last Hydro clear-cut. The former right-of-way is now just discernable as a shallow trough in the green hillsides. The PNGTS Extension threatens to open the wound again: this time in a much more menacing way.

Mr. Trudelle claims that the visual impact of pipelines is less than that of the Hydro-Qu?bec grid, but notwithstanding the invisibility of the pipeline itself, we could anticipate that the visual impact of its right-of-way would be more pronounced than the old hydro lines themselves:

Pipeline right-of-ways are clear-cut at more frequent intervals than those of hydroelectricity lines.

The uniformity of the terrain created by the construction of pipelines makes their right-of-ways stand out because they look unnatural.

The resulting pipeline scar would be visible for many kilometers in nearly all directions. The impact would be particularly pronounced from the perspective of Mont Orford because the pipeline route is a matter of just a few degrees from being perpendicular to the mountain.

3.3. Mitigation of visual impacts by the promoters

In a region such as the Eastern Townships, whose scenic nature is of paramount importance, one would expect that mitigation of negative visual impacts would be a high priority. Indeed, the promoters confirm this expectation in their representations before the BAPE commission:

"Alors, c'est une pr?occupation, particulierement dans les Cantons de l'Est, parce qu'il y a‚?videmment plusieurs points de vue, il y a plusieurs angles sous lesquels une emprise peut ?tre visualis?e, non seulement par les r?sidants qui ont, eux autres, ‚?videmment une vue tr?s ponctuelle, tr?s importante pour autant et puis, bien s?r, il y a les gens qui circulent sur les autoroutes, sur les routes r?gionales et on se doit de se pr?occuper de leur perception visuelle de l'emprise."

Urgel Delisle

"Effectivement, il y a soit des plantations similaires … ce qu'il y a autour, mais il y a toujours, dans l'implantation des postes ou des sites clotures, une harmonisation qui est faite avec le paysage environnant, la plupart du temps par des plantations autour de l'installation."

Jean Trudelle

Unfortunately, in this matter, as in so many others, the proponents have a great propensity for saying the correct thing and doing another. The photograph in Doc-21-1 illustrates one of the promoter’s past successes at mitigating the negative visual impact of their installations in the scenic Eastern Townships environment. Here is the view of Mont Orford from west-bound Autoroute 10 where it descends to the Orford exit. Even in a photocopy of a pathetic snapshot one can make out that absolutely nothing was done to mitigate the impact of this above-ground natural gas installation on the scenic view of which it became a part. The scrubby trees in the foreground grew by chance along the farm fence.

3.4. Summary/Recommendations

The corridor selected by the promoters takes the pipeline across 100 kilometers of an area whose geographical features bestow upon it exceptional grace and natural beauty.

While the promoters are always interested in cultivating an image of enlightened concern about the negative impacts of their projects, their actions speak louder than their words. The promoters have demonstrated insufficient commitment and responsibility towards the preservation of the scenic nature of the Eastern Townships. Their project would:

Deface land possessed of great aesthetic value.

Spoil and detract from other future opportunities for more aesthetic and economically-sustainable development in the region.

Devalue prime real estate.

Be in opposition with the principle developmental goals of the recreational and touristic region through which it passes.

There are at least several viable alternatives to the PNGTS Extension and its corridor. If the promoters are really serious about for the PNGTS Extension that would create lower impacts. TQM should start over and do its homework this time.

4. Environmental impacts

In these sections the focus will be upon Bunker Hill where the promoters want to play down the impact because the pipeline would follow a previously existing Hydro-Qu?bec right-of-way.

Actually, the Bunker Hill is an acknowledged exceptional forest eco-system and current commercial practices as well as the proposed pipeline are and would be responsible for destroying an important habitat.

4.1. Synopsis

Preservation of soil characteristics is extremely important in maintaining eco-systems. Soil is the foundation of life: soil supports flora, and flora supports fauna.

The discussions on microrelief (see Section 4.2.1, Microrelief) , soil constituency (see Section 4.2.2, Soil constituency) , and mechanical damage (see Section 4.2.3, Mechanical damage) will center on the sensitive eco-system found along the Bunker Hill right-of-way near Ayer’s Cliff.

A relatively small but important wetland along the Bunker Hill right-of-way is threatened by construction access to the Bunker’s escarpment. See Section 4.3, Wetland.

According to the Ministry of Natural Resources and the Ministry of the Environment and Wildlife, the rich soils of Bunker Hill support an exceptional forest ecosystem where there are "a lot of species" and "a lot of potential for rare species [of flora]". The PNGTS Extension promoters have made no provisions for preserving or protecting the flora in this area, they wish to replace it with non-indigenous varieties of grass. See Section 4.4, Flora.

The wide variety of flora found on Bunker Hill supports a varied and abundant fauna population. Commercial logging operations on the Bunker have been steadily reducing their available habitat. The PNGTS Extension would disturb and alter the remaining natural habitats at the western end of Bunker Hill. See Section 4.5, Fauna.

4.2. Soil

4.2.1. Microrelief

The microrelief of an area is composed of its individual cups, holes, grooves, heaps, ridges, and mounds, etc. Microrelief and wetlands are nature’s first line of defense against the destructive effects of soil erosion (also see section 4.2.4, Erosion ).

Microrelief is also what makes a terrain look "natural" (also see section 3, Visual impact). When man grades a terrain and removes the microrelief he has permanently destroyed a large component of nature.

Although construction of the former Hydro Qu?bec electrical transmission line across Bunker Hill entailed changes to flora along most of its right-of-way, it did not significantly alter the land’s microrelief. Here on the Bunker Hill and in many other locations along the pipeline, the PNGTS Extension would radically alter the natural microrelief and contour for all time.

4.2.2. Soil constituency

The natural constituency of a soil refers to the way various materials have been deposited by nature over time. If top-soil is replaced by inert soil from lower levels, the result is a serious negative impact upon cultivation or, in the case of the forested Bunker Hill, the native flora.

As with microrelief, construction of the former Hydro Qu?bec electrical transmission lines did not alter the natural constituency of the soil. Although pipeline construction attempts to avoid destruction of topsoil in cultivated areas, the standard pipeline construction method in forested areas replaces topsoil with inert subsoil.

TQM’s practice of "upside down soil" in forest areas will greatly inhibit the regeneration of native flora and encourage invasive and aggressive non-native species.

In any area where an attempt is made to separate topsoil and subsoil and return them to their natural levels, great care is required to ensure the success of the operation. The proponents of THE PNGTS Extension always claim that they preserve the topsoil in cultivated land but in responses to many concerns about this subject they never once mentioned specific and important points such as:

Stripping and stockpiling of topsoil during dry conditions to avoid mixing topsoil and subsoil.

Stabilization of topsoil piles using straw mulch or tackifier.

4.2.3. Mechanical damage

Beneath the topsoil of Bunker Hill lies limestone clay, hardpan, and slate ledge. All of these formations inhibit efficient drainage and make the soil structure extremely vulnerable to mechanical damage, such as rutting and compaction.

As in topsoil replacement, the PNGTS Extension promoters have made no reference to specific techniques and practices to avoid or mitigate these problems:

No alteration of the natural drainage in wetlands, directly or indirectly.

Suspension of construction during and after periods of rainfall and saturated soil conditions in order to avoid soil rutting, soil compaction, surface erosion, and mixing of topsoil and subsoil.

Not traveling heavy-equipment along the right-of-way any more than necessary to avoid soil compaction.

4.2.4. Erosion

Erosion induced by human activity is an extremely serious problem. Among the obvious effects of erosion are loss of topsoil, alteration of relief, and the many problems associated with the introduction of silt into wetlands and waterways.

A classic soil science treatise has this to say about erosion on slopes:

"On slopes with a gradient exceeding 20%, as well as on slopes of a southern and western aspect, which are vulnerable to erosion, clear felling is ruled out."

This recommendation was confirmed by Dr. Derek Booth, department head of Bishop’s University Department of Geography.

The PNGTS Extension has been designed to breach the Bunker Hill escarpment with a 200 meter linear descent at a point where the average slope is 30 to 40 degrees: extremely steep. Parts of the slope are 45 degrees or greater: precipitous.

In addition to the slope’s acute pitch, the proposed descent has a southerly exposure. This is significant with regard to erosion because southern slopes are more subject to pronounced washout than northern ones.

Furthermore, according to information included with the proponent’s environmental impact study, within the sector from Magog to East Hereford, the western zone (the zone in which Bunker Hill is situated) receives the greater amount of annual precipitation, both rain and snow.

One more potential problem is that the face of the escarpment is largely bedrock covered by a thin layer of soil. Standard methods employed by the proponents will destroy the terrain’s natural microrelief (also see section 4.2.1, Microrelief) and its natural fauna and microfauna. Microrelief is natures first defense against erosion; plants are the second.

Think about the potential problems that could stem from these combined conditions:

High levels of precipitation

Extreme slope

No natural microrelief

Bedrock close to surface

Thin soil layer

Southerly exposure

The promoters environmental assessment notes that Bunker Hill’s southern slope is a major descent and the steepest on the PNGTS Extension. Yet the promoters have not so much as looked at the site or considered the problems listed above, let alone thought about the logistical problems posed by the juxtaposition of a wetland, a stream, and the escarpment all on a 100 meter section of the pipeline route (also see section 4.3, Wetland).

4.3. Wetland

One-hundred meters north of the Bunker Hill escarpment, there is a long, narrow wetland just above a small stream. Although the old Hydro right-of-way bisects it, this area has never been subject to clear-cut because it is naturally open. It is populated by a wide variety of indigenous flora.

This wetland performs many useful and necessary functions, from filtration and attenuation of run-off from the surrounding hills to providing habitat and feeding areas to various mammals, birds, and amphibians, including the Dusky Salamander, (gyrinophilus porphyritlcus), which in Canada is found only in the southern-most part of the Eastern Townships. The proper functioning of this wetland is in danger of being severely damaged by the construction of the PNGTS Extension.

The wetland and the stream it feeds cut off the Bunker Hill escarpment from the rest of the right-of-way to the north. As previously noted, the escarpment is mostly underlayed with bedrock, therefore blasting would be required to lay the pipeline. This would necessitate removal of blasted rock from the trench as well as bringing in sand for back-fill around the pipeline.

The question which remains unanswered after the hearings is, would the blasted rock and sand be transported up and down the 200 meter escarpment with slopes between 30 and 45 degrees? That possibility would seem to be more than remote. Would the answer be that all those materials would be transported over the wetland?

Note the oft-repeated TQM mantra in MR. Barbeau’s response to the question during the hearings:

"Yes, Mr. Chairman, as far as the rock is concerned, unfortunately, I have not seen this specific spot that has been drawn by Mr. Miller. We would have to see what the slopes are, what the environment is. In any case, there are ways of taking out the rock without damaging an area which is, you know, broader than it would be."

"And when construction is completed, if there are other changes which have to be made in order to maintain the environment, this will be done, but nevertheless we would first have to look at the area to see which method should be used."

There are ways, this will be done.

(On earth as it is in heaven)

This is the descent the promoter’s environmental study describes as difficult and as the steepest one along the Canadian route and yet they haven’t even looked at it. Once again, the promoter is asking us to rely on vague assurances that they will study it, take care of it, and fix it up afterwards.

It is interesting to note that the one and only time I was approached by the promoters to discuss the effects of the pipeline on our land, they suggested draining this area. This would, no doubt be an economical and convenient solution.

4.4. Flora

We already saw in section 4.2 what drastic and permanent changes PNGTS Extension construction would make to terrain and soil. Now let us examine the effect of the construction upon flora.

As previously noted (section 4.3) one part of the old Hydro right-of-way on Bunker Hill has never been clear-cut because its characteristic humidity is not conducive to the growth of trees. This humid area supports a wide variety of indigenous flora which should be preserved and offers a potential habitat for threatened varieties. Is sowing non-native grasses a good environmental practice in this type of area?

At BAPE information meetings and hearings Urgel Delisle mentioned several times the theoretical possibility of preserving native habitats. However, when prompted by specific questions on this possibility at the BAPE hearings in Magog, he failed to describe, much less commit to, any specific techniques for the preservation of native habitats anywhere along the PNGTS Extension, including the Bunker Hill exceptional forest ecosystem.

When we speak of invasive, non-indigenous varieties of vegetation we are referring to the kind of aggressive and sometimes noxious varieties which are found along the edges of our Autoroutes. These plants spread rapidly along any type of corridor, hitch-hiking on cars, trucks, bulldozers, backhoes, recreational vehicles, etc. They are also introduced in trucked-in materials such as sand and gravel.

When asked if they would take measures to mitigate this problem, the promoters avoided giving an answer by speaking in generalities about an experimental program designed to find ground covers for pipeline corridors. Why are the promoters so unwilling to make a commitment to protect and preserve the exceptional forest ecosystem found on Bunker Hill? Why?

4.5. Fauna

The promoters have presented their project to the Minister of the Environment, to the BAPE commission, and to the National Energy Board without ever having made an inventory of fauna. Do the Ministry of the Environment’s guidelines specify that the promoters submit their inventories with their environmental assessment, or at the conclusion of the hearing process?

In response to one of my questions during the Magog BAPE hearings the promoters assured commissioners that the fauna inventory would be carried out during the month of July. At this writing it is the second day of August and since we have not been contacted for permission to enter our land for this purpose we assume that this inventory has still not been done. The question is, why?

Once again, the Ministry of Natural Resources designates Bunker Hill as an exceptional forest ecosystem. The wide variety of plants which are found in this ecosystem support a large and varied population of fauna as well.

Unlike the promoters’ methodology (if it is ever carried out), which accomplishes an inventory during an interval of perhaps a single morning or afternoon during the summer season, our own animal inventory has been made during all seasons and over many years. Currently, we are aware of many species of mammals, birds, amphibians, and reptiles on our 80-acre property on Bunker Hill.

The PNGTS Extension’s heavy construction will displace many of these creatures from the right-of-way and the adjacent woodlands. Leaving branches from trees felled during the winter on the ground was the only consideration suggested by the promoters during BAPE hearings to reduce the impact of their project upon the many forest creatures.

Do the promoters care that their Spring construction schedule will evict the vixens and their young kits from the fox dens scattered along our right-of-way? Do they suppose that the foxes and other displaced animals will find refuge in the "vieux ?rabli?re’ to which they keep referring and which they are so intent upon avoiding? Have they not yet understood that those maple trees exist only on the Environment Ministry’s maps? Have they not yet understood that those maples have been clear-cut and that the rest of the forest on the three properties adjacent to ours on two sides have, or are in the process of being reduced to slash and saplings for commercial gain?

Last Spring as I walked the perimeter of our land I was shocked to see only empty space on neighboring land where huge and healthy old maples once stood. I crossed over to explore and found the going difficult: the ground was scarred by three-foot deep ruts and covered with a thick layer of slash. I was filled with disbelief that this could happen on Bunker Hill.

It was then that I surprised a young porcupine. Instinctually it climbed the nearest tree: a mere sapling that had been broken off at six feet, but nevertheless the only tree within ten or fifteen meters. There he clung, regarding me with a forlorn look I shall never forget.

Will the last undeveloped, unexploited parcels of land at the eastern end of Bunker Hill be drawn and quartered? Where will the animals go when the din of the PNGTS Extension construction begins? Where, dear reader?

4.6. Summary/Recommendations

Although Bunker Hill is acknowledged by all to be an exceptional forest ecosystem, the promoters have done very little to study it and therefore lack understanding and appreciation of it.

This is consistent with what I perceive of as a general attitude on the part of the promoters to look at nature simply as an obstacle which can be overcome.

If they do-not know, they can-not act,

If they do-not know, they can-not act.

The promoters know the rules of the game and they have flaunted them. They have not done their studies. They did not do them in the beginning and they are not doing them now.

Someone must tell the promoters to do their studies in earnest:: study the alternatives; do their inventories. Do their homework.

5. Company credibility

5.1. Synopsis

From the beginning of their early public notification program right up until the present time, the promoters have demonstrated either an unwillingness or an inability to deal honestly and fairly with a large number of affected landowners.

There are many available examples of this, but the most celebrated is undoubtedly the issue of trespass of private property by employees of the promoters. See section 5.2, Private property and trespassing .

Along 100 kilometers of the pipeline route in the Eastern Townships, widespread organized opposition has sprung up due to grave environmental and socio-economic concerns shared by citizens, environmental organizations, and local governments. TQM continues to deny the existence and validity of this opposition. TQM’s failed attempts to act responsibly have only heightened opposition. See Section 5.3, Denial.

5.2. Private property and trespassing

During a private meeting representatives of the promoters stated categorically that, except in an emergency, TQM employees would never enter my land without my permission. Although I had knowledge that TQM employees had already trespassed on my land at least twice, the assurance was offered with such conviction and sincerity that I felt I should let bygones be bygones.

In the months that followed, much to the frustration of landowners, nothing was more clear than that trespassing on private land by TQM was widespread and systematic: unauthorized entry of private property by TQM employees was a very common event.

Despite numerous complaints from landowners and overwhelming evidence to the contrary, TQM continued to maintain the myth that permission was always sought before entering private property. Urgell Delisle suggested that landowners were simply not home when permission was requested.

After eight months of deception the promoters were finally forced to confront their trespasses in front of the BAPE commission. Characteristically, TQM subtly shunts company responsibility for flagrant disregard of landowners and private property onto subordinates:

"It is possible that even if we had given the instructions to our staff to ask for permission from the land owners, it is possible that it was not done. It’s possible. And if this is the case, on behalf of TQM, we would like to apologize for this, if the permission was not asked, requested."

Continuing, the spokesperson confirms company commitment and offers a second apology, one interpreted by Commission Chairman Camille Genest as an expression of goodwill.

"I would like to say, Mr. Chairman, that TQM Pipeline has given out very strict instructions to its staff since these incidents occurred. And these instructions are put in place to make sure that, in a systematic fashion, any person walking on a private property will request permission to do so. And once again, we apologize for the situation."

Good will or no, entering private property without permission by TQM employees went unabated for another eleven days. Then, promoters were forced to confront their trespasses in front of the BAPE Commission a second time. Again, promoters apologized and, this time, gave the Commission absolute assurance that the incidents would cease immediately.

In spite of those absolute assurances, trespassing continued for another two-and-half weeks until the promoters finally engaged its gears sufficiently to call landowners en masse and make a pro forma permission request.

Among members of the Coalition des Propri?taires Concern?s par un Gazoduc, none could be found who, prior to that date, had ever been approached by TQM for permission to enter their land for any purpose other than negotiating a settlement.

Did TQM act in bad faith? Or did TQM utterly fail for eight months to obtain compliance with company directives by its employees? Or both?

In any case, how could the BAPE Commission say that the promoters and their employees should be entrusted to carry out a massive construction project with a high potential for serious and permanent harm to environmentally sensitive areas? Such a recommendation would have to be based preponderantly on the promoters’ own claims to competency, responsibility, and good will and we have seen much evidence to the contrary.

5.3. Denial

Judging from citizens’ expressions of concerns at TQM public information meetings, as well as those from municipalities, MRC’s, and environmental groups, the promoters must have been aware from the very beginning that there was considerable opposition to the route taken by the PNGTS Extension, particularly from Stukely Sud to Ayer’s Cliff and the East Hereford area.

Instead of honestly addressing the concerns of citizens the promoters attempted to minimize them and deny the existence of opposition. To see how disingenuous the promoters can be, look at Section 9.0, the Conclusion to the "Summary of the Early Public Notification Program", a document deposited with the National Energy Board on the 24th of March 1997. Here the proponent’s state that there is little opposition to the PNGTS Extension apart from two individuals.

That surly came as news to landowners in Sainte-Catherine-de-Hatley who, before the 24th of March, had already met three times amongst themselves in groups of ten or more to discuss opposition to the proposed route in our area. We did invite the promoters to come back and talk with us but they did not respond. Similar meetings were also held by landowners in South Stukely. Cooperation was pledged between the two groups prior to the 8th of March. This was the cornerstone for what became the Coalition des Propri?taires Concern?s par un Gazoduc. The Coalition now has members from Granby all the way to East Hereford.

If the promoters want to quibble about a definition for "opposition", let me suggest that the members of the Coalition be polled to learn exactly how many are opposed to the PNGTS Extension as it is currently proposed.

Section 8 "Complaints to the NEB" of the same document is just one example of the systematic way in which the promoters have tried to portray opponents to their project as isolated and uncooperative individuals. The reader is cautioned that comments in Section 8 provided by the proponents "to clarify the situation" contain numerous falsehoods which are refuted by documentation being forwarded to the National Energy Board.

In Section 9.0 the promoters also state:

that the people living in the communities along the proposed pipeline had an opportunity to express their concerns;

that all stakeholders, whoever they might be, were able to express all their concerns, orally or in writing;

that all the concerns expressed were studied and, as far as possible, taken into consideration;

I disagree with all of these statements.

at the end of the EPN nearly none of the people living in the communities along the proposed pipeline were even aware of the project. Public awareness has only recently begun thanks to the BAPE Commission and, we believe, in no small part, the efforts of the Coalition des Propri?taires Concern?s par un Gazoduc.

from day one of the EPN, by word and deed the promoters did everything in their power to isolate landowners from each other and inhibit people from organizing together.

the promoters have studied precious little about their project, much less the concerns of landowners which were expressed from the very beginning of the EPN.

5.4. Summary/Recommendations

The promoters are responsible for the credibility gap between themselves and a large number of landowners.

The promoters at times have demonstrated themselves to be untrustworthy or incompetent and landowners have many good reasons to be worried about the preservation of their environment, their security, and their peace of mind if the PNGTS Extension is approved in its present form.

The promoters have not demonstrated sufficient responsibility to be allowed to proceed with the PNGTS Extension project on the basis of promises and assurances.

6. Safety

As someone greatly distressed by the prospect of having their level of personal security severely diminished, I am extremely concerned about pipeline safety. Nevertheless, out of a desire to not further burden the reader with this already lengthy memorandum, I shall restrict myself here to a few short observations.

6.1. Risk assessment study

As someone whose residence would be within sixty meters of the PNGTS Extension I am quite concerned by the rather ambiguous conclusions of the discussion that occurred between Mr. Bill Crocker, Mr. Charles Cloutier (Commissioner), Mr. Jean Trudelle, and Mr. Robert Lapalme on the 27th of June in Magog with regard to the MIACC standards for risk acceptability criteria and land use.

Also one wonders if the risk assessment is flawed when it states that a risk level of one in a million is achieved at a distance of only one-hundred-and-ten (110) meters from a metering station and yet states the same risk level of one in a million is achieved at a distance of three-hundred-and-forty (340) meters from the pipeline. Furthermore the assessment states that while reducing the distance from the metering station by forty-five (45) meters increases the risk level a hundred-fold to one-hundred in a million, the risk level for the pipeline increases only by a factor of ten even when the distance from the pipeline is reduced to zero. Something here is not adding up.

One also wonders of what use is it to do a risk assessment such as the one commissioned by the promoters if it is not even used in the design of the pipeline route?

6.2. The Magog liquid hydrogen plant and the pipeline

Commissioner Charles Cloutier’s question to Mr. Bill Crocker on the 26th of June in Magog concerning truck movements and daily operations at the Magog liquid hydrogen plant was extremely relevant. Looking at the hydrogen plant from Autoroute 55, one is immediately struck by the fact that the parking area for the fleet of transport tankers is located directly between the storage tank and the pipeline route: it is common to see a dozen or more trucks parked there.

We learned during the hearing that the person who analyzed this problem wasn’t even given the plans for the plant. The promoters’ study of this site was simplistic and unsatisfactory.

6.3. Emergencies in a Rural Environment

For the possible interest of the reader,

Appendix B. relates the writer’s one and only experience with obtaining an emergency service. The story is recounted not to blame individuals or organizations, just to illustrate that the randomness of the universe allows near-impossible events to occur all the time.

The tale also points up some problems particular to the rural setting:

Because jurisdictions in rural areas overlap they can become ill-defined or confusing: live in one jurisdiction, receive fire protection from another.

It is more difficult to pinpoint exact locations and residences can be in remote or secluded locations.

7. Conclusion

During the BAPE Commission’s hearings and in this memoire we have seen how this project, which we are told has been in planning for five years, is chiefly characterized by:

Out-dated concepts

No coordination between its partners during preliminary design

Extremely poor choice of corridor in Canada

No serious considerations given to alternatives

An incomplete and deficient environmental assessment

Total lack of good faith on the part of the promoters

Where is the "good" of this project? On a grand scale, this is a difficult and complex question. However, one thing is perfectly clear: it cannot with any honesty be said that any good will come of this project along its proposed one-hundred kilometer length through the Eastern Townships. Along the route in the Eastern Townships the economic good is nil and the certainty of environmental harm is incontrovertible.

Alternatives are available. Please tell the promoters to take their homework seriously and study them.

There can be no question of sacrificing the environment of the Eastern Townships for the aggrandizement of Hydro-Qu?bec’s CEO or any other reason.

The population of this region will not stand for it.

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