National Energy Board
Participants, including Kwantlen First Nation, Upper Nicola Band and Lower Nicola Band, expressed
concerns that existing cumulative eﬀects, from industrial and urban development, have resulted in
decreased ﬁsh abundance and health, and that Project construction would contribute to the total
cumulative eﬀects. Trans Mountain said that the total cumulative eﬀects for indicator species were
potentially signiﬁcant in watersheds where the aquatic disturbance threshold was exceeded.
Trans Mountain said that existing activities that have disturbed riparian and instream habitat include
agriculture, rural and urban residential and commercial development, transportation and infrastructure
development, utility activities, forestry, mineral resource exploration and development, ongoing recreational
activities, and oil and gas exploration and development. Trans Mountain indicated that the Project,
in combination with reasonably foreseeable developments, would increase cumulative eﬀects in all
watersheds. Trans Mountain said that the Project may contribute < 0.01 to 0.15 per cent, or an average
of 0.05 per cent, to total riparian habitat disturbance in RSA (See description of the spatial boundaries in
Appendix 11). Trans Mountain also said that the Project’s overall contribution to combined instream habitat
disturbance would be < 0.01 per cent in Alberta and 0.02 per cent in B.C.
Participants, including Metro Vancouver and Yarrow Ecovillage, said that substantial restoration activities
have occurred in watercourses crossed by the proposed pipeline and that Project construction could
potentially compromise the progress of habitat enhancement measures. The City of New Westminster
said that habitat enhancements in the upper reaches of the Brunette River, and associated oﬀ-channels,
have resulted in marked improvement in ﬁsh habitat quality. It said that the Project alignment adds risk to
the ongoing successful improvements and the positive trajectory of this recovering system as ﬁsh habitat.
The City of Coquitlam recommended that Trans Mountain avoid any disturbance to streams in Coquitlam,
or alternatively, to provide additional habitat compensation to enhance stream habitat. Trans Mountain
acknowledged the implementation of habitat enhancement measures completed by local stakeholders and
municipalities. Trans Mountain said that existing compensation areas within watercourses will be avoided
or minimized during construction and that any disturbance to compensation areas will be re-established
during the construction and reclamation phases. Trans Mountain also committed to implement additional
enhancement measures (e.g., boulder clusters, large woody debris) at watercourse crossings deemed high
risk by the self-assessment, and, in the event a
authorization is required, would implement
oﬀset measures to compensate for the serious harm.
Species at risk
Trans Mountain indicated that seven proposed watercourse crossing locations are within the proposed
critical habitat for Nooksack dace and Salish sucker. Trans Mountain proposed to cross six of these
crossings using an isolated trenched watercourse crossing method. Trans Mountain said that it had not
studied the possibility of trenchless crossings within critical habitat for these species. Trans Mountain said
that the proposed species-speciﬁc mitigation and construction timing would limit the potential for serious
harm to Nooksack dace and Salish sucker. Trans Mountain committed to obtaining the necessary permits
under SARA for the salvage of all relevant freshwater ﬁshes.
DFO said that the proposed mitigation measures may eﬀectively mitigate potential localized eﬀects on
Nooksack dace and Salish sucker, but that trenchless crossings are preferred methods for reducing impacts
on ﬁsh and ﬁsh habitat. DFO said that the enhancement of the speciﬁc habitat features and functions that
beneﬁt the Nooksack dace and Salish sucker may assist in furthering the recovery of these species. Metro
Vancouver recommended that Trans Mountain commit to using trenchless crossings within areas of critical
habitat, or re-route the pipeline to avoid impacts on critical habitat.
Trans Mountain indicated that no other ﬁsh species at risk have critical habitat identiﬁed within the pipeline
corridor and that, with the implementation of mitigation measures and appropriate watercourse crossing
methods, eﬀects on ﬁsh species at risk are anticipated to be low. Trans Mountain said that Athabasca
rainbow trout was recently uplisted by the Committee on the Status of Endangered Wildlife in Canada
to Endangered and that the publication of the
Alberta Athabasca Rainbow Trout Recovery Plan 2014-2019
suggests that Athabasca rainbow trout could likely be listed under the SARA before Project construction.
58 Sturgeon River, Lower and Upper North Saskatchewan River, Pembina River, Lower McLeod River, Athabasca River, Lower North Thompson River,
Thompson River, South Thompson River, Lower Nicola River, and Similkameen watersheds.