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Appendix II
Frou:NATURE CANADA 10:18772888803 0910812010 11:36 #354 P.002/005
Enbridge Northern Gateway Project
Joint Review PanelWritten Comment Form
The Joint Review Panel (the Panel), established tD review the Enbridge Northern Gateway Project (Project), has a broad mandate toassess the potential environmental effects of the Project and to determine if it is in the public interest.
As an initial step in the review process, the Panel is interested in receiving comments on the following three topics:
1. the draft List of Issues attached as Appendix I;2. additional information which Northern Gateway should be required to file; and3. location(s) for the oral hearings.
The Panel encourages Interested people to provide their comments in writing by using this form.
Contact information and written comments will be placed on the public registry.
Participants submitting written comments should provide the following information by noon (Mountain
Standard Time), Wednesday, 8 September 2010:U)
Hard copy filings may be made by mail, courier, hand delivery or fax at the address below ° r -
- . — ,, r,..Joint Review Panel — Enbndge Northern Gateway Project444 Seventh Avenue SW., 2nd floor mailroomCalgary, Alberta T2P 0X8 ‘
Facsimile: (403) 292-5503, or toll free at 1-877-288-8803 r 3”1-ri
0
Contact Information
Name
Carla SbertAddress
75 Albert Street suite 300rifle if applicable (optional): City:
Nate cs,, ‘—.oe. sccos •w” s .e C)ttavvaOrganization if Province:applicable (optional): Nature Canada and BC Nature OntarioTelephone (optional):613_ 562-3447 ext. 222 Postal Code: K1P 5E7
Facsimile (ootional): 613-562-3371 Email (optional): [email protected]
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Board de i’6n.rie (Danad • canadian Envworsmentai Aance c.nad.enneNatonei Ene’y Ollice h8Ii,ai
Assessment Aqeney d’evalueiion environnemenia]s
12
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Appendix II
List of Issues
Yes NOD
Please refer to the attached letter.
Additional informationiequfr4tofflepHoflo*e Pntsinbabpg1udti.ç
$ocedQmfvWfln tS3a*’flnYes NoD
Please refer to the attached letter.
Oral Hearing Locationfffiflaou$wdbOteaedrandih?
___________
Please refer to the attached letter.
AddEtional Enbridge Northern Gateway Project application information can be found at wwwgatewaypanel.review-examen.Qc.ca
OF-Fac-Oil-N304-2010-D1O113
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From:NATURE CANADA 10:18772888803 0910812010 11:38 #354 P.0041005
2BcnatureFEDERATION OF BC NATURALISTS
NC/10009020September 8, 2010
Joint Review PanelEnbridge Northern Gateway ProjectBy Facsimile: (403) 292-5503/ 1-877-288-8203
rr..&7’t-iYeCANADA
Nature Canada and BC Nature have received participant funding from the CEAA to act asinterveners in the JRP review of the Northern Gateway Pipeline Project (NGPP3. Nature Canadais the national voice of naturalists in Canada. Its mission is to protect and conserve wildlife andhabitats in Canada by engaging people and advocating on behalf of nature. BC Nature is aprovince-wide federation of naturalists and naturalists’ clubs, with approximately 4,500members. Its interest is the maintenance of the integrity of British Columbia’s wide range ofecosystems and rich biodiversity, and in related public education. Nature Canada is also a copartner in Canada of BirdLife International. As part of this partnership, Nature Canadaimplements the Important Bird Area (IBA) program in Canada. BC Nature coordinates the IBAprogram in British Columbia.
As we, and many other organizations, have noted, the extent of potential impacts of theProposed Project is considerably greater than the scope of the proposed review. The ProposedProject has long-term implications for the health of BC’s northern and central coastaiecosystems and communities, as well as for climate change mitigation and adaptation effortsthat confront Canada. While the effects of oil and condensate spills and chronic discharges onland and at sea are included in the list of issues and terms of reference, other issues - notablythe expansion of tar sand operations by an estimated 30% - are not. A comprehensive reviewrequires that the JRP carefully examine the Project with all its implications, under all relevantdomestic and international law and policy.
From the perspective of the environment and biodiversity, the current list is inadequate oroverly general. In addition to the issues currently included, the List of Issues should include orexplicitly note:
• The impacts (direct and from cumulative effects) of the expansion of tar sandsoperations related to the project, with respect to green house gas emissions and climatechange, air and water pollution, habitat destruction and impacts on wildlife and theirhabitat, including woodland caribou (of which herds in Alberta are particularlyendangered) and boreal birds.
• The impacts (direct and from cumulative effects) on protected areas and areas of highconservation value along the proposed pipeline route and in the Northern and CentralBC Coast like the Great Bear Rainforest, Gwaii Haanas National Park Reserve and
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BcnatureFEDERATION OF BC NATURALISTS
rr.%.ftjYeCANADA
National Marine Conservation Area Reserve, and 28 IBAs in the Charlotte Basin and 6IBAs along the proposed pipeline route.’The impacts (direct and from cumulative effects) on all federally and provincially listedspecies at risk, explaining how the project takes into account recovery and managementplans and how the proponent would avoid and monitor all impacts on these species.
• The impacts (direct and from cumulative effects) on streams and rivers in salmon-bearing watersheds, as well as on caribou, grizzly bears, wolves and boreal birds(including through habitat destruction and fragmentation).
In terms of the application submitted by the Proponent, Nature Canada and BC Nature considerit to be incomplete, and inadequate to enable an adequate assessment of the effects of theProposed Project.2 We support the view that the JRP should not proceed with a hearing orderuntil the Proponent has met their obligation of submitting a complete application.
Finally, with respect to the location for hearings, we believe that hearings should be held in (ornear) every community that has identified itself as affected by the project. In addition, at leastone hearing should be held in a major urban center in Alberta, British Columbia and EasternCanada to allow other interested organizations or persons to participate.
Sincerely,
Ian DavidsonExecutive DirectorNature Canada
On behalf of BC Nature and Nature Canada
I www.ibacanada.ca <http:I.?www.ibacanada.c&>2 Given that the numerous inadequacies of the Application have already been noted in detail by others,including Ecojustice (public registry #AIT3S7, under A25470), Michel FN (public registry #AJU2I1,under A26068), and Coastal First Nations Great Bear Initiative Society (public registry dec iA iT7WO,under A25752), we refrain from repeating them here.
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CANADA
F AXto: NGP .JRP From:Carla Sbert
Fax:1877 288 8803 Pages:4 not irici cover
Phone: Date:8 Sept 2010
RE:comments on list of issues
MessageWe submitted an earlier version with minor errors. Please consider this one as our commentsThank you
75, rue Albert St. Suite 300, Ottawa, Ontario, Canada 1(1 P 5E7 J 613-562-3447 [email protected] naturecanada.ca
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