National Energy Board

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Cumulative Effects

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.

58

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

Fisheries Act

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.