RE: Bipole III Transmission Project Response Package #3manitobawildlands.org/pdfs/bp3cec/HY-BP3-MBHY-ResponsetoCECIRs...(204) 360-4394 [email protected] July 18th, ... Carry out

PO Box 7950 Stn Main Winnipeg, Manitoba Canada R3C 0J1

(204) 360-4394 [email protected]

July 18th

, 2012

Ms. Cathy Johnson

Secretary, Clean Environment Commission

305-155 Carlton St.

Winnipeg, MB R3C 3H8

Ms. Johnson

RE: Bipole III Transmission Project – Response Package #3

Please find enclosed responses to various Information Requests, which were submitted to

Manitoba Hydro on May 29th

, June 7th

, June 15th

and June 22nd

, respectively.

Please see the attached table for a complete listing of the responses enclosed.

We trust the enclosed responds appropriately to your requests. Should you have any questions

or require further clarification of our comments and information requests please do not

hesitate to contact us.

Regards,

Original Signed by Shannon Johnson

Shannon Johnson

Manager Licensing and Environmental Assessment Department

820 Taylor Ave (3)

Winnipeg, Manitoba

R3M 3T1

sj/tk

Enclosed:

CEC

Information

Request #

Information

Request #2

Information

Request #3

Information

Request #4

Information

Request #5

Date

Received

May 29th

June 7th

June 15th

June 22nd

MH

Response

Label

CEC/MH-III- CEC/MH-IIII- CEC/MH-IV- CEC/MH-V-

CEC/MH-II-

001a

CEC/MH-III-032 CEC/MH-IV-

128

CEC/MH-V-155

CEC/MH-II-

001c

CEC/MH-III-037c CEC/MH-IV-

131

CEC/MH-V-166

CEC/MH-II-

001e

CEC/MH-III-037e CEC/MH-IV-

133

CEC/MH-V-168

CEC/MH-II-

002b


138

CEC/MH-V-173

CEC/MH-II-

002g


143

CEC/MH-V-

174a

CEC/MH-II-

003a

CEC/MH-III-049 CEC/MH-V-

175a

CEC/MH-II-

003b

CEC/MH-III-050 CEC/MH-V-

175c

CEC/MH-II-

005a

CEC/MH-III-053e CEC/MH-V-177

CEC/MH-II-

005c

CEC/MH-III-058 CEC/MH-V-179

CEC/MH-II-

005d


CEC/MH-II-

005ei


CEC/MH-II-

005j


CEC/MH-II-

006a


CEC/MH-II-

006c

CEC/MH-III-072

CEC/MH-II-

006f

CEC/MH-III-073

CEC/MH-II-

007d

CEC/MH-III-082

CEC/MH-II-

007j

CEC/MH-III-089

CEC/MH-II-

007n

CEC/MH-III-092

CEC/MH-II-

009a

CEC/MH-III-093

CEC/MH-II- CEC/MH-III-094

CEC

Information

Request #

Information

Request #2

Information

Request #3

Information

Request #4

Information

Request #5

Date

Received

May 29th

June 7th

June 15th

June 22nd

MH

Response

Label

CEC/MH-III- CEC/MH-IIII- CEC/MH-IV- CEC/MH-V-

010a

CEC/MH-II-014 CEC/MH-III-095

CEC/MH-II-

019b

CEC/MH-III-096

CEC/MH-II-

019b (2)

CEC/MH-III-099


CEC/MH-II-022 CEC/MH-III-

101(2)1


CEC/MH-III-105

CEC/MH-III-107

CEC/MH-III-108

CEC/MH-III-112

CEC/MH-III-117

CEC/MH-III-117 1 CEC/MH-III-101 and CEC/MH-III-101(2) are resubmissions as the previous response did not include the

attachment

Clean Environment Commission

Bipole III Transmission Project

Package #3

July 18 2012


CEC/MH-II-001a

Date May 29, 2012

Reference Executive Summary and Introduction

Source CEC Information Request # 2

Question CEC/MH-II-001a

1

Question: 2

Reference: Executive Summary and Introduction – Volume 1 3

Please explain why the Environmental Protection Plan (EnvPP) filed in this application is 4

considered to be a draft version? 5

Response: 6

The Bipole III Transmission Project Environmental Protection Plan (EnvPP) is considered draft 7

as it does not contain any Clean Environment Commission, Manitoba Conservation and Water 8

Stewardship recommendations or Environment Act licence conditions for mitigation or 9

monitoring. 10

18/07/12 1


CEC/MH-II-001c

Date May 29, 2012



Question CEC/MH-II-001c

1

Question: 2


What mitigation efforts by species and issues in all Technical Reports has MH planned? 4

Response: 5

Response: 6

The approach to mitigation of potential project effects is addressed by: 7

The prescription and application of general environmental protection measures as 8

presented in the draft Environmental Protection Plan (EIS Chapter 11, Appendix 11-1); 9

The identification of Environmentally Sensitive Sites (ESS) and prescription and 10

application of site-specific mitigation measures; 11

The identification of issues or areas of potential risk addressing them proactively with 12

management strategies, and 13

The development and application of the Environmental Protection Program. 14

15

General Environmental Protection Measures 16

The environmental protection measures for the Bipole III Transmission Project are categorized 17

into five (5) major groups within which construction/maintenance activities/issues are identified 18

with specific mitigation measures. These are summarized in Table 1. 19

18/07/12 2


CEC/MH-II-001c

Table 1 Summary of Mitigation Measures 20

Category Activity/Issue # of Mitigation

Measures

Management Management 19

Project Activity Blasting & Exploding 21

Burning 14

Clearing 38

Demobilizing & Cleaning-up 9

Draining 14

Drilling 14

Grading 9

Grubbing 10

Rehabilitating & Re-vegetating 19

Stripping 11

Project Component Access Roads & Trails 22

Borrow Pits & Quarries 32

Construction Camps 32

Facilities and Buildings 17

Marshalling Yards 23

Potable Water & Wells 16

Power Supply Stations 16

Rights-of-Way 13

Stream Crossings 31

Transmission Towers & Conductors 20

Environmental Component Agricultural Areas 15

Built-up & Populated Areas 15

Fish Protection 13

Groundwater 6

Heritage Resources 15

Permafrost 11

18/07/12 3


CEC/MH-II-001c

Waterbodies 16

Wetlands 9

Wildlife 23

Environmental Issue/Topic Aircraft Use 5

Emergency Response 18

Erosion Protection Sediment Control 14

Hazardous Substances 31

Petroleum Products 41

Health & Safety 9

Soil Contamination 12

Treated Wood 11

Vehicle & Equipment Maintenance 12

Waste Management 13

Total 688*

*Includes overlap/duplication of some mitigation measures. 21

Environmentally Sensitive Sites (ESS) 22

Through the course of the Site Selection and Environmental Assessment (SSEA) studies, a total 23

of 2970 ESS have been identified of which 1218 are intersected by the project footprint. Those 24

in proximity to the project footprint (1752) have also been identified to afford them protection 25

from unforeseen activities (e.g. slight route adjustment, equipment operation outside of 26

footprint, etc.). In most cases ESS are afforded protection under the General Environmental 27

Protection Measures (GEMP) (e.g. stream crossings, fish habitat protection, water quality, 28

erosion, hazardous materials spills, heritage resources, etc.). 29

The ESS are spatially identified as points or polygons in the draft Environmental Protection Plan 30

(EnvPP) for the project. They are identified in an interactive map program provided with the EIS 31

Each ESS has applicable mitigation measures listed. A summary of ESS by category, group, 32

type, # of type sites and mitigation measures are provided in Table 2. 33

18/07/12 4


CEC/MH-II-001c

Table 2 Bipole III Project ESS Type and Mitigation Summary 34

Category Group Type # of

Type

Sites*

Environmental Effect Mitigation

Ecosystem Habitat Dry Upland Prairie 61 Potential loss of plants of conservation

concern and grassland

species/communities from clearing,

construction, maintenance and

decommissioning activities.

Carry out construction activities on frozen or dry ground

to minimize surface damage, rutting and erosion;

Use existing access roads and trails to the extent

possible;

Remove trees by hand or other low-disturbance methods;

Confine vehicle traffic to established trails to the extent

possible; Stabilize sites immediately after construction

and re-vegetate disturbed areas in accordance with site

Rehabilitation Plan.

Ecosystem Habitat Patterned Fen 28 Potential loss of previously known plants

of conservation concern from clearing,






possible;






18/07/12 5


CEC/MH-II-001c


Type

Sites*


Ecosystem Habitat Salt Marsh/ Flat 4 Potential loss of plants of conservation

concern and habitat disturbance from

clearing, construction, maintenance and



to minimize surface damage, rutting and erosion; Use

existing access roads and trails to the extent possible;

Provide 5 m vegetated (shrub and herbaceous) buffer

around site; Remove trees by hand or other low-

disturbance methods; Manage surface runoff to minimize

erosion and direct drainage from construction sites into

vegetated areas; Confine vehicle traffic to established

trails to the extent possible; Install erosion protection and

sediment control measures in accordance with

Erosion/Sediment Control Plan; Stabilize sites

immediately after construction and re-vegetate disturbed

areas in accordance with site Rehabilitation Plan.

Ecosystem Species of

Concern

Plant - various 55 Potential loss of previously known plants

of conservation concern from clearing,






possible;

18/07/12 6


CEC/MH-II-001c


Type

Sites*







Heritage Archaeological Abandoned Building 2 Potential disturbance to Heritage

Resources


to minimize surface damage, rutting and erosion; Identify

and flag prior to start of work; Conduct site investigation

with Archaeologist prior to construction; Minimize surface

disturbance around the site to the extent possible;

Inspect excavated materials or surface disturbance for

heritage resources and report any finds to Environmental

Inspector; Implement additional mitigation from site

investigation.

Heritage Archaeological Infrastructure 1 Potential disturbance to Heritage

Resources






18/07/12 7


CEC/MH-II-001c


Type

Sites*





investigation.

Heritage Archaeological Landscape Feature 2 Potential disturbance to Heritage

Resources









investigation.

Heritage Archaeological Potential Archaeological

Site

13 Potential disturbance to Heritage

Resources






18/07/12 8


CEC/MH-II-001c


Type

Sites*





investigation.

Heritage Archaeological Registered

Archaeological Site


Resource









investigation.

Heritage Archaeological Trail 1 Potential disturbance to Heritage

Resources






18/07/12 9


CEC/MH-II-001c


Type

Sites*





investigation.

Heritage Archaeological Trees 3 Potential disturbance to Heritage

Resources









investigation.

Heritage Archaeological Waterbody/

Watercourse


Resources






18/07/12 10


CEC/MH-II-001c


Type

Sites*





investigation.

Land Use Crown Land

Encumbrance

DU Canada Project 4 Potential disturbance effects to

conservation land

Notify Crown Lands and permittee with respect to

clearing and construction schedules; adhere to Manitoba

Hydro’s standard environmental protection practices in

wetland areas; Clearing and construction to occur in the

winter months; install bird diverters if a waterfowl

sensitive area; adhere to seasonally limited maintenance

times.

Land Use Crown Land

Encumbrance

Trapper Cabin 2 Potential disturbance effects to trapper

and resource use

Manitoba Hydro has a compensation policy in place for

reimbursement to trapline holders for fur harvest losses

during clearing and construction. Trappers will be

notified as to the schedule for clearing and construction

activities in advance; Maintain an adequate buffer;

consider route adjustment and/or tower placement to

minimize visual / aesthetic effects from presence of

towers.

18/07/12 11


CEC/MH-II-001c


Type

Sites*


Land Use Residential Home 1 Potential disruption to rural residential

development; aesthetic, property value

and/or EMF concerns (negative

perception)

Observe municipal and local protocols and by-laws,

including work scheduling; minimize dust and other

emissions from work activities and maintain appearance

of work site; ensure public safety from equipment

operation by placing warning signs; Conduct EMF

measurements at properties for those homeowners

requesting an assessment.

Land Use Water River Crossing 1 Potential aesthetic concerns with

presence to canoe route traffic;

disruption from operational activities

Review transmission line design crossing with MC;

consider tower placement to minimize visual presence /

aesthetic effects of crossing towers; notify MC and user

groups of operational activities.

Resource

Use

Forestry Plantation 84 Removal in area of ROW intersect;

Potential for additional damage outside of

ROW

Complete Forest Damage Appraisal and provide

compensation to Manitoba Conservation; Carry out

construction activities on frozen or dry ground to

minimize surface damage, rutting and erosion; Use

existing access trails, roads or cut lines whenever

possible as access routes; Burn clearing debris during

winter months only and ensure that all fires are

extinguished prior to spring break-up; pile debris 15m

18/07/12 12


CEC/MH-II-001c


Type

Sites*


away from ROW edge;

Resource

Use

Forestry Shelterbelt 125 Removal in area of ROW intersect Carry out construction activities on frozen or dry ground


and flag prior to start of work; Burn clearing debris

during winter months only and ensure that all fires are


away from ROW edge; Notify landowner regarding

construction activities and schedule, and address

concerns prior to start of work; Where applicable, ensure

compensation agreement is in place prior to start of

work; Use existing access trails, roads or cut lines

whenever possible as access routes; Limit all equipment

to project footprint only, where possible.

18/07/12 13


CEC/MH-II-001c


Type

Sites*


Resource

Use

Forestry Woodlot 3 Potential for additional damage outside of

ROW



and flag prior to start of work; Burn clearing debris

during winter months only and ensure that all fires are


away from ROW edge; Notify landowner regarding

construction activities and schedule, and address

concerns prior to start of work; Where applicable, ensure

compensation agreement is in place prior to start of

work; Use existing access trails, roads or cut lines

whenever possible as access routes; Limit all equipment

to project footprint only, where possible.

Soils and

Terrain

Soils Eolian 105 Loss of topsoil due to wind erosion (e.g.

creep, saltation, suspension) on disturbed

surfaces.

Carry out construction activities on frozen ground to


existing trails, roads or cut lines whenever possible as

access routes; Identify and flag prior to start of work;

Avoid dry soil conditions with high and severe wind

erosion risk to the extent possible; Maintain shrub and

herbaceous vegetation to the extent possible; Remove

18/07/12 14


CEC/MH-II-001c


Type

Sites*


trees by hand or other low-disturbance methods; Confine

vehicle traffic to established trails to the extent possible;

Implement erosion protection before commencing

construction in accordance with Erosion/Sediment Control

Plan.

Soils and

Terrain

Soils Water Erosion Risk 11 Loss of topsoil due to water erosion (e.g.

sheet, rill, gully) on disturbed surfaces.





Avoid moist soil conditions with high and severe wind







Plan.

18/07/12 15


CEC/MH-II-001c


Type

Sites*


Soils and

Terrain

Soils Wind Erosion Risk 4 Loss of topsoil due to wind erosion (e.g.

creep, saltation, suspension) on disturbed

surfaces.





Avoid dry soil conditions with high and severe wind







Plan.

Soils and

Terrain

Terrain Enduring Features 5 Impairment or loss of approximately 16

ha (0.63 %) of rare occurrence PAI

enduring feature from right-of-way

establishment.




access routes; Avoid development of new borrow areas,

access routes and other activities within enduring

features; Maintain 100m setback around feature outside

of ROW; Minimize movement of vehicles, machinery and

18/07/12 16


CEC/MH-II-001c


Type

Sites*


equipment during construction; Excavate and stockpile

topsoil and subsoil separately where excavations are

required; Replace topsoil and subsoil in excavations to

restore natural conditions to the extent possible; Confine

vehicle traffic to established trails to the extent possible.

Soils and

Terrain

Terrain Steep Slopes 5 Loss of topsoil due to water erosion (e.g.

sheet, rill, gully) on disturbed surfaces;

mass-movement due to slope

destabilization.


minimize surface damage, rutting and erosion; Avoid

construction on steep slopes or the creation of steep

slopes to the extent possible; Maintain shrub and

herbaceous vegetation to the extent possible; Adhere to

DFO Operational Statements for Ice Bridges and Snow

Fills in areas with steep slopes; Confine vehicle traffic to

established trails to the extent possible; Implement

erosion protection before commencing construction in

accordance with Erosion/Sediment Control Plan; Stabilize

sites immediately after construction and re-vegetate

disturbed areas in accordance with the site Rehabilitation

18/07/12 17


CEC/MH-II-001c


Type

Sites*


Plan.

Water Fish Habitat High Fish Habitat

Sensitivity

8 Habitat loss & contamination from

structure foundations & installations;

Increased erosion & sedimentation of

streams; Damage to stream banks; Loss

of riparian vegetation; Fish habitat

disturbance & impeded fish movement.

Where possible, installation of overhead lines over

watercourses and poorly drained habitats such as bogs

and fens will be conducted under frozen conditions or

aerially; Where possible, transmission line approaches

and crossings will be perpendicular to the watercourse

and will avoid unstable features such as meander bends,

braided streams and active floodplains; All structures

(temporary and permanent), will be placed above the

ordinary high water mark (HWM); A machine free zone

(MFZ) of 7 m will be established from the HWM where

harvesting or clearing machinery will not enter other than

to cross the stream; A riparian buffer (RB) of 30 m will be

18/07/12 18


CEC/MH-II-001c


Type

Sites*


established from the HWM where ground disturbance is

minimized, all shrub and herbaceous vegetation is

retained and all trees that do not violate Manitoba Hydro

vegetation clearance requirements are retained;

Vegetation will be retained for as long as possible prior to

construction; Clearing limits and sensitive areas will be

clearly marked prior to vegetation removal; Clearing will

be conducted under favourable weather conditions.

Operations will be postponed under adverse weather (i.e.

storm events), to minimize potential sediment

introduction into the aquatic environment; In riparian

areas, vegetation will be maintained in a way that leaves

root systems intact; Riparian vegetation maintenance

within 30 m of the HWM will affect a maximum of 1/3 of

woody vegetation (e.g. trees and shrubs) within the

RoW; Riparian vegetation maintenance will be conducted

by the method that minimizes stream bank disturbance.

If rutting or erosion is likely, appropriate bank protection

measures will be implemented prior to machinery use; All

18/07/12 19


CEC/MH-II-001c


Type

Sites*


waste materials (slash) will be stabilized well above the

HWM to mitigate entry into the watercourse; Application

of herbicides will adhere to appropriate best management

practices. All chemical applications will be conducted by a

certified applicator; Disturbed areas will be re-vegetated

following completion of works; Appropriate erosion and

sediment control measures will be implemented to

mitigate sediment introduction into watercourses;

Temporary stream crossings will be constructed only

where existing crossings do not exist or are not practical

for use; Temporary stream crossings consist of bridges,

ice bridges, snow fills, dry streambed fords or a one-time

ford in flowing waters; Whenever possible, existing trails,

roads and cut lines will be used as access routes;

Crossings will be constructed on a straight section of the

watercourse, perpendicular to the channel; Clean

materials will be used in the construction of temporary

crossings. All materials will be removed upon project

completion or prior to freshet (whichever occurs first);

18/07/12 20


CEC/MH-II-001c


Type

Sites*


One-time fording of flowing streams and temporary

bridge construction will only occur where the channel

width is less than 5 m (from HWM to HWM); No in-

stream work or fording from September 15 to June 30;

Fording will occur under low flow and favourable weather

conditions and will avoid known fish spawning areas;

Where necessary, measures to protect the streambed

and banks will be in place prior to fording (i.e. pads,

swamp mats). Protection measures will not impede fish

passage, or constrict flows; If fording will likely result in

erosion and degradation of the streambed and banks, a

temporary bridge will be constructed; At ice bridges

water withdrawal will not exceed 10% of instantaneous

flow and water flow beneath the ice bridge will be

maintained; Clearly mark unstable banks and avoid

vehicle crossing.

18/07/12 21


CEC/MH-II-001c


Type

Sites*


Water Fish Habitat Low Fish Habitat

Senstivity


























18/07/12 22


CEC/MH-II-001c


Type

Sites*





















18/07/12 23


CEC/MH-II-001c


Type

Sites*





















18/07/12 24


CEC/MH-II-001c


Type

Sites*









maintained.

18/07/12 25


CEC/MH-II-001c


Type

Sites*


Water Fish Habitat Moderate Fish Habitat

Sensitivity


























18/07/12 26


CEC/MH-II-001c


Type

Sites*





















18/07/12 27


CEC/MH-II-001c


Type

Sites*





















18/07/12 28


CEC/MH-II-001c


Type

Sites*









maintained; Clearly mark unstable banks and avoid

vehicle crossing.

Water Fish Habitat Waterbody/Watercourse 33 Increased erosion and sedimentation,

Rutting of floodplains, Loss of riparian

vegetation

Riparian Buffer of 7m established surrounding the

riparian zone, where all shrub and herbaceous vegetation

will be retained and all trees that do not violate Manitoba

Hydro vegetation clearance requirements will be retained.

Water Ground Aquifer 11 Potential groundwater contamination

from a contingency event (e.g., spill)

Marshalling yards will be located on upland sites where

possible; An Emergency Preparedness and Spill Response

Plan will be developed and an emergency response spill

kit will be kept on-site at all times in case of fluid leaks or

18/07/12 29


CEC/MH-II-001c


Type

Sites*


spills from machinery.

Water Ground Artesian Area 5 Potential increase in salinity of soils and

surface water in case where aquifer is

saline and groundwater discharges to the

surface; Also, wetting the surficial

environment (ground saturation)

Qualified driller with appropriate experience will be

contracted to work in areas affected by artesian

conditions; Emergency response plans for

sealing/grouting and pumping will be implemented as

required; Follow up inspections of installed foundations

will be undertaken to monitor for excess moisture.

Water Ground Freshwater Artesian

Area

5 Wetting the surficial environment near

potential discharge from tower

foundation drill hole (ground saturation);

Also, potential level drop in the aquifer.





required; Follow up inspections of installed foundations


Water Ground Saline Artesian Area 6 Increase in salinity of soils and surface

water in case of potential groundwater

discharge to the surface. Also, wetting

the surficial environment (ground





18/07/12 30


CEC/MH-II-001c


Type

Sites*


saturation); affect on local vegetation required; Follow up inspections of installed foundations


Water Waterbody/

Riparian

Buffer

Waterbody/

Watercourse

58 Increased erosion and sedimentation,

Rutting of floodplains, Loss of riparian

vegetation

Riparian Buffer of 7m established surrounding the

riparian zone, where all shrub and herbaceous vegetation

will be retained and all trees that do not violate Manitoba

Hydro vegetation clearance requirements will be

retained.

Wildlife Birds and

Habitat

Bird Colony 11 Higher risk of wire collision, Disturbance

during breeding and nesting, Risk of wire

collision is localized to the right-of-way

while construction disturbance can effect

colonies up to 1000 meters away

Adhere to timing windows for protection of birds

(Appendix F); Maintain Xm setback during timing

window; Conduct priority assessment for bird diverters

and other measures prior to transmission line stringing;

Install bird diverters or other measures at high priority

sites; Monitor bird density and mortality/injury in

accordance with Biophysical Monitoring Plan and adjust

mitigation accordingly.

18/07/12 31


CEC/MH-II-001c


Type

Sites*


Wildlife Birds and

Habitat

Bird Colony/Staging

Area

1 Higher risk of wire collision, Disturbance






(Appendix F); Maintain 1000m setback during timing

window; Conduct priority assessment for bird diverters






Wildlife Birds and

Habitat

Feeding Area 1 Higher risk of wire collision, Risk of wire



(Appendix F); Conduct priority assessment for bird

diverters and other measures prior to transmission line

stringing; Install bird diverters or other measures at high

priority sites; Monitor bird density and mortality/injury in



Wildlife Birds and

Habitat

Waterbird Sensitivity

Area







window Conduct priority assessment for bird diverters


18/07/12 32


CEC/MH-II-001c


Type

Sites*


colonies up to 1000 meters away Install bird diverters or other measures at high priority




Wildlife Birds and

Habitat

Waterbody/Watercourse

Crossing

50 Higher risk of wire collision, Risk of wire



(Appendix F);; Conduct priority assessment for bird

diverters and other measures prior to transmission line

stringing; Install bird diverters or other measures at high

priority sites; Monitor bird density and mortality/injury in



Wildlife Birds and

Habitat

Waterfowl Sensitivity

Area



collision is localize to the right-of-way





window Conduct priority assessment for bird diverters






18/07/12 33


CEC/MH-II-001c


Type

Sites*


Wildlife Mammals and

Habitat

Caribou 1 Habitat loss and fragmentation.

Disturbance and displacement affecting

calving habitat. Predation pressure

resulting from increased access.


to minimize surface damage, rutting and erosion; Adhere

to timing windows for protection of Woodland Caribou

calving sites (Appendix F); Maintain shrub and

herbaceous vegetation to the extent possible;

Decommission and rehabilitate access routes immediately

following construction in accordance with Access

Management Plan; Limit any access from PTH 6 including

winter.

*Includes on-footprint ESS.35

18/07/12 34


CEC/MH-II-001c

Risk Management 36

Management involves the control or organization of activities and resources to resolve or 37

respond to environmental problems, issues or concerns. Management plans provide reasoned 38

course of actions to achieve pre-defined goals or objectives. Management strategies are 39

identified, compared and analyzed, and preferred courses of action are implemented and 40

evaluated. 41

The following management plans will be developed for the project to address areas of potential 42

risk: 43

Access 44

Blasting 45

Decommissioning 46

Emergency preparedness and response 47

Erosion protection and sediment control 48

Site rehabilitation 49

Remediation 50

Solid waste/recycling 51

Vegetation management 52

Environmental Protection Program 53

The Environmental Protection Program defines how Manitoba Hydro is organized and functions 54

to deliver timely, effective, and comprehensive solutions and mitigation measures to address 55

potential environmental effects. Roles and responsibilities for Manitoba Hydro employees and 56

contractors are defined, along with management, communication and reporting structures for 57

implementation of the Program. The Environmental Protection Program includes the what, 58

where and how aspects of protecting the environment during the pre-construction, 59

construction, operation and decommissioning of the Project. 60

18/07/12 35


CEC/MH-II-001c

For a detailed description of the Environmental Protection Program see EIS Chapter 11, 61

Attachment 11-1, Section 2. 62

18/07/12 36


CEC/MH-II-001e

Date May 29, 2012



Question CEC/MH-II-001e

1

Question: 2


Please provide an overall view as to the level of acceptance and stakeholder approval of the 4

Bipole III transmission project as a result of the consultation process. 5

Response: 6

The Environmental Assessment Consultation Program (EACP) aimed to provide a venue to 7

present the project, to receive comments for routing options and to address any concerns 8

related to the project. The goal for the EACP was not to gauge public acceptance but to ensure 9

that the feedback received would result in a project which would have minimal impact on 10

people and the environment. 11

While the intent was not to gauge public acceptance, it was noted that many participants were 12

generally accepting of the need for the project. Factors which appeared to influence 13

individuals’ acceptance included: location, level of interest, and perceived impact of the project. 14

Manitoba Hydro has considered the concerns raised through the public engagement process in 15

the planning and development of the project. 16

Manitoba Hydro has and will continue to engage with First Nations, Northern Affairs 17

communities, and the MMF to review the concerns raised during and subsequent to the EACP 18

and to discuss site specific environmental protection measures that will be incorporated into the 19

construction phase of the environmental protection plan. 20

The summary of stakeholder consultation is contained in Chapter 5 of the EIS and also in the 21

Bipole III Environmental Assessment Public Consultation Report. In terms of stakeholder 22

18/07/12 37


CEC/MH-II-001e

approval, the responses varied with location and level of interest in the project. Location of the 23

transmission line was a major topic of discussion with many indicating their preference for 24

another location in the Province east of Lake Winnipeg. Please see section 5.5.2.1 of the EIS. 25

18/07/12 38


CEC/MH-II-002b

Date May 29 2012

Reference Draft EPP


Question CEC/MH-II-002b

1

Question: 2

1. Reference: Draft Environmental Protection Plan 3

What transpires should the monitoring indicate a problem that requires mitigation effort? Is this 4

a case of self-monitoring or does MB Conservation handle this? Does MB Conservation have the 5

resources necessary to adequately review monitoring results and the conduct of ground 6

truthing? 7

Response: 8

Chapter 11 (Environmental Protection, Follow-up and Monitoring) of the EIS outlines the 9

framework for implementing, managing, monitoring and evaluating environmental protection 10

measures consistent with regulatory requirements, corporate commitments, best practices and 11

public expectations. The chapter outlines how Manitoba Hydro will implement, manage and 12

report on environmental protection measures, monitoring and other follow-up actions as well as 13

regulatory and policy requirements and other commitments identified in the Project EIS. Figure 14

1, below, is an excerpt from Chapter 11. 15

16

Following an adaptive management approach, if monitoring indicates an issue, Manitoba Hydro 17

staff, and where applicable Manitoba Conservation and Water Stewardship (MCWS), affected 18

parties and specialist consultants will evaluate monitoring results and where warranted 19

prescribe new/revised mitigation measures which will be further monitored for performance. 20

21

Manitoba Hydro cannot comment if MCWS has the necessary resources to review monitoring 22

results or conduct ground truthing. 23

18/07/12 39


CEC/MH-II-002b

24

Figure 1. Environmental Protection Program Organizational Structure 25

18/07/12 40


CEC/MH-II-002g

Date May 29 2012

Reference Draft EPP


Question CEC/MH-II-002g

1

Question: 2

Reference: Draft Environmental Protection Plan 3

Under what circumstances will regulators such as MB Conservation be notified or involved? 4

Response: 5

Manitoba Conservation and Water Stewardship (MCWS) staff will have many points of contact 6

with Manitoba Hydro staff throughout pre-construction, construction and operation phases of 7

the Project. 8

Notifications and collaboration with regulators are discussed in Chapter 11 of the EIS as they 9

relate to the development of protection and monitoring plans, implementation of the plans, 10

acquiring necessary approvals, and ongoing reporting. 11

In situations where there could be or there is an inadvertent deviation from the Environmental 12

Protection Plan, regional MCWS staff will be notified as soon as possible to discuss and 13

determine the next course of action. In the event of an unintended release of a controlled 14

substance, Manitoba Hydro recognizes that spills must be reported to MCWS in accordance with 15

the Notice and Reporting regulation (MR 126/2010) under the Environment Act. Spills and 16

accidents with dangerous goods must also be reported under the Environmental Accident 17

Reporting regulation (MR 439/87) under the Dangerous Goods and Transportation Act. 18

Manitoba Hydro is committed to compliance with these regulations, and will use the 19

Environmental Emergency Response number to report spills of hazardous materials that are 20

likely to have a significant adverse effect on the environment, or exceed reportable quantities 21

as defined in the Environmental Accident Reporting regulation. 22

18/07/12 41


CEC/MH-II-002g

It is also anticipated that monitoring observations and results will be summarized in an annual 23

project monitoring report that will be submitted to MCWS as part of the anticipated terms and 24

conditions of the licence. Please see MH/CEC-II-002a. 25

As stated in CEC/MH-II-002jk Manitoba Hydro and regional MCWS staff are presently working to 26

establish communication linkages. The intent of these semi-regular meetings is to update 27

MCWS Regional Directors as to the status of the Environmental Protection Plan (EnvPP) and to 28

communicate how Manitoba Hydro environmental inspection and monitoring will be undertaken 29

with the objectives of being proactive in dealing with potential environmental issues that may 30

arise, and ensuring compliance with the Environment Act licence. 31

Manitoba Hydro anticipates frequent and ongoing collaboration with MCWS (and other relevant 32

regulatory bodies) leading up to and throughout the life of the BPIII project. 33

18/07/12 42


CEC/MH-II-003a

Date May 29 2012

Reference Chapter 7



1

Question: 2

Reference: Preliminary Preferred Route/Final Preferred Route – Chapter 7 3

Please describe how the parameters used to evaluate the route segments were determined and 4

how the ranking was decided upon. 5

Response: 6

The parameters chosen to use in the alternative route evaluation process were developed by 7

discipline specialists and members of the project environmental assessment team. A route 8

selection matrix (RSM) was developed to identify all the parameters or factors used in the 9

alternative route evaluation. A complete description of the process and the results are recorded 10

in the RSM and can be found in Appendix 7a, Chapter 7 of the EIS. 11

The first part of the RSM reading from the left, lists 23 parameters (out of 27 listed in the RSM) 12

which are categories of biophysical, socio-economic, land use, and technical factors. Evaluation 13

was based on ranking the level of constraint that a particular segment represented for a given 14

factor or category. Each route segment was evaluated using a low to high or very high rating 15

(e.g the constraint for Birds was rated as VH (very high) for segment c21 in Section 8). 16

Discipline specialists developed constraint criteria based on available data, field studies, and 17

their personal knowledge, experience and professional judgment. 18

An additional criterion was added in the RSM for Aboriginal Traditional Knowledge (ATK) in the 19

first section. If there was a concern expressed from ATK for a particular segment and area, it 20

could raise the constraint level for any criteria mentioned by that source. It was indicated in the 21

RSM by adding a pattern to the cell for the particular segment and criteria of concern. 22

18/07/12 43


CEC/MH-II-003a

The second part of the RSM was developed to include input from the environmental assessment 23

consultation program. The data collected from the program was reviewed for specific input. 24

Data was not available for all groups in each section as illustrated in the RSM (Appendix 7a). 25

Ratings were developed for each of the four response groups (Aboriginal Communities, 26

Municipalities, Stakeholders, General Public) based on the interpretation of the input. The RSM 27

then provided rating for 28 factors with the addition of the four response groups and a 28

consideration of ATK information. 29

The results of the previous two sections of the RSM were reviewed and rated by an expert 30

panel to select an initial preferred route segment in each of the 13 sections. This is shown in 31

the final part of the RSM where summary ratings are indicated for five overall categories 32

including biophysical, socio-economic, land use, technical, and stakeholder response. The intent 33

was to consolidate multiple inputs into a decision framework that provides a more 34

comprehensive level of route segment assessment than specialist input or consultation alone. 35

18/07/12 44


CEC/MH-II-003a

An excerpt from Appendix 7a: Table 7A-1: Note that ATK information is displayed as varied cell pattern 36

37

18/07/12 45


CEC/MH-II-003b

Date May 29 2012

Reference Chapter 7



1

Question: 2

Reference: Preliminary Preferred Route/Final Preferred Route – Chapter 7 3

Please explain what ecological parameters were used to assist in the determination of the final 4

preferred route. 5

Response: 6

The ecological parameters for selecting the Final Preferred Route (FPR) remained the same 7

through the Site Selection and Environmental Assessment (SSEA) process (See EIS Chapter 7 8

Appendix 7A). The objective for ecological considerations in route selection was to minimize the 9

effects of the project on the environment. Out of a total of 28 route evaluation and selection 10

criteria, nine (9) are ecologically based. These include: 11

Vegetation – considered listed species and their habitats, important habitats (particularly 12

remnant habitats) and protected areas; 13

Birds – considered the range of bird species within the project study area, rare and endangered 14

species, habitat availability and quality, proximity to known high use/nesting/staging areas, 15

migration corridors, core habitat, fragmentation and protected areas. 16

Mammals – considered the range of mammal species, habitat availability, critical habitats, 17

population densities, concentrations, ecological reserves, parks and conservation areas. 18

Boreal woodland caribou - considered historic and present use, calving habitat availability, 19

seasonal life history requirements, core use areas (including winter) and core habitat. 20

18/07/12 46


CEC/MH-II-003b

Core communities – considered primarily those species within the community that have small to 21

moderately-sized home ranges. The objective of the evaluation was to select route segments 22

which avoid areas of contiguous core communities. 23

Fragmentation - independent analysis that considered “the lowest threshold at which the most 24

sensitive species and population may begin to decline as a result of additional linear feature is 25

>0.16 km/km²”, and median and maximum habitat patch sizes. 26

Soils and Terrain - considered soil and terrain sensitivities, steep/unstable slopes, extensive 27

organic deposits, permafrost, vulnerable aquifers and enduring features identified by the PAI. 28

Aquatics - considered fish habitat, water quality, high value fish habitat areas, the number of 29

crossings, crossings with spans greater than 500 m and crossings within 500 m of a confluence 30

(stream-stream or stream-lake). 31

Amphibian, reptile and terrestrial invertebrate - considered protected species and the 32

environments in which they are most likely to be encountered and presence of at-risk species. 33

In addition, the above (excluding core communities and fragmentation) focused on discipline 34

specific valued ecosystem components that were identified by all study specialists at the outset 35

of the SSEA process. 36

The approach leading to the selection of the Preliminary Preferred Route (PPR) involved the 37

analysis and evaluation of alternative routes by study specialists at the landscape level. The 38

refinement of the PPR into the FPR involved the same ecological parameters but at the local 39

study area level and site type level to identify environmentally sensitive sites. This enabled 40

further route adjustments to avoid some sensitivities and develop project specific mitigation 41

measures where required. 42

18/07/12 47


CEC/MH-II-005a

Date May 29 2012

Reference Right of Way



1

Question: 2

Reference: Right of Way 3

Is it necessary to clear a straight line with squared off edges along the line? Could the edge be 4

more irregular thus providing for a more diverse and sustainable habitat. Also do the service 5

roads/trails within the ROW have to be straight? Could they be more sinuous with at least 6

vegetative patches that would cut down on the line of sight and reduce the “chasing” distance 7

for predators including humans? Could the roads be removed, disrupted or otherwise altered to 8

limit access? 9

Response: 10

With respect to the right-of-way please also see CEC/MH-II-005c 11

Service paths and access points to the ROW during the construction phase generally develop 12

along the lay of the land, however straight paths where possible along the centre of the ROW 13

are required for traffic safety and conductor stringing. These access points will then be used for 14

the life of the facility for maintenance access. Any roads or access points that are not required 15

for line maintenance activities will be decommissioned as per the access management plan (i.e. 16

ingress points will be broken up to discourage vehicular traffic such as ATVs/snowmobiles). 17

Vegetative patches could be included but are limited by mature height of the particular species, 18

line clearances, and access requirements to the facility. 19

18/07/12 48


CEC/MH-II-005c

Date May 29 2012




1

Question: 2


Reference NYRI diagram (will be forwarded shortly)– Please provide comments on MH’s 4

consideration of designing the ROW similar to that shown in the NYRI diagram, including 5

Blowout concerns when stated minimum sag is approximately 43’, particularly in northern 6

boreal forest. 7

Response: 8

There is little opportunity to vary the width of clearing along the ROW during the construction 9

phase as full width clearing is required at mid-span for blowout (conductor swing out from 10

wind). Full width clearing is also required at the tower sites for the guys and anchors that are 11

part of the tower design in forested areas. The size of the ROW is a function of: 12

• conductor clearance to vegetation under operating conditions (blowout); 13

• tower and guy wire clearance at the tower sites; 14

• danger tree removal for operational reliability (NERC); 15

• construction access; and 16

• access for inspection, maintenance, and emergency restoration by helicopter in remote 17

areas. 18

19

The ROW width for Bipole III was determined to be 66 m to meet the above criteria. 20

The minor narrowing of the ROW that could be achieved by using a design like the NYRI 21

figures, is a function of topography and therefore would vary from span to span making design 22

difficult. Once designed, the irregular shape would be impractical to layout in the field and 23

18/07/12 49


CEC/MH-II-005c

clear around. Consistent width ROW is therefore the only feasible option in the construction 24

phase. Once cleared of tall growing tree species in the construction phase, selective regrowth of 25

fringe areas of the ROW with low shrubs and grasses is a desirable and beneficial vegetation 26

management goal for the operational phase. 27

18/07/12 50


CEC/MH-II-005d

Date May 29 2012



Question CEC/MH-II-005d

1

Question: 2


What is the maximum height of vegetation that would not interfere with the line operation? 4

Response: 5

It is not possible to provide a set maximum height for vegetation. Manitoba Hydro has to 6

ensure the reliability of the operation of the transmission line as per the North American Electric 7

Reliability Corporation (NERC) standards. NERC reliability standard FAC-003 dictates that 8

vegetation management must account for local and species specific future growth for all 9

possible locations of the conductor (i.e. maximum sag; blow out). Vegetation cannot come 10

within the flash over air gap to prevent flash over. Height will vary along the line due to a 11

variety of factors such as terrain, structure height, span length, conductor sag, design criteria 12

(related to weather conditions - i.e. wind; temperature; ice). 13

18/07/12 51


CEC/MH-II-005ei

Date May 29 2012



Question CEC/MH-II-005ei

1

Question: 2


Please outline, for each transmission line section, what the intended clearing and management 4

scheme will be. 5

What effect will the intended clearing and management scheme have on the contiguity of the 6

forest/landscape and the surrounding area. What alternatives are available? Have they been 7

considered? If not, why? 8

Response: 9

The clearing process for each of the transmission line sections will be similar. Firstly, the right-10

of-way (ROW) center-line and boundaries will be established (surveyed) in the field and 11

marked. The line will then be cleared of trees using a combination of the following methods: 12

• General Clearing – trees will be sheared at ground level by dozers equipped with KG 13

blades; the ROW area is not grubbed, except at tower footprint locations. 14

• Selective Clearing (Mechanical) – in environmentally sensitive areas, where good snow 15

cover and frozen ground conditions allow, feller-bunchers are used to cut the trees; 16

shrubs and herbaceous vegetation is maintained; there is no soil disturbance. 17

• Selective Clearing (Hand) – again in environmentally sensitive areas, and also for 18

“danger trees”, chain-saws will be used to cut the trees; all shrubs and herbaceous 19

vegetation is maintained; there is no soil disturbance. 20

• Discontinuous Clearing – in specific areas where there is stunted tree growth, these 21

trees may be left in place except for those on the path of the ROW access road. 22

18/07/12 52


CEC/MH-II-005ei

All clearing activities are governed by the conditions of the Environmental Protection Plan. North 23

American Electric Reliability Corporation (NERC)/Federal Energy Regulatory Commission (FERC) 24

operational requirements for continuous operation of the line will also dictate which trees are 25

cut down. 26

Where economically feasible, contractors will salvage timber from the ROW. Also a portion of 27

the timber will be processed (i.e. de-limbed and cut to standard lengths) so that it can be used 28

for firewood by members of local communities. Otherwise it will be disposed of on-site by cut, 29

pile and burn methods. 30

Clearing the ROW for the transmission line will affect the contiguity of the landscape to varying 31

degrees across the Project Study Area. Where possible, routes were chosen to minimize these 32

effects by taking advantage of areas with existing anthropogenic disturbances (e.g. routing 33

parallel to existing roads, transmission lines, through forestry developments, etc.). Specific 34

fragmentation sensitivities have been identified along the route and mitigation measures 35

developed to address them (e.g. wildlife corridors, line of sight buffers, discontinuous clearing, 36

access management, etc.). As discussed above, areas of specific sensitivities are identified and 37

addressed through the design and application of mitigation measures. 38

18/07/12 53


CEC/MH-II-005j

Date May 29 2012



Question CEC/MH-II-005j

1

Question: 2


It is stated that the method of tower construction and erection will be under control of the 4

individual contractors. Will the proposed method of erection be reviewed and approved by MH 5

depending upon the terrain, access and ecological dictates at the site(s)? Will a set of 6

guidelines be available to determine the most appropriate methods depending upon the 7

situation? How will this be monitored? 8

Response: 9

Typically, two methods of tower erection have been used on recent Manitoba Hydro 10

transmission line projects – erection by crane or erection by helicopter. Both approaches are 11

acceptable to Manitoba Hydro and will have minimal incremental impact on the tower site as 12

anchors and foundations would have already been installed on the site. 13

The contractor will make the decision on how to erect towers in accordance with the 14

Environmental Protection Plan and the specific site conditions for each tower location. A specific 15

written set of guidelines is not required for each tower installation. 16

Structure erection activities will be monitored on a regular basis in the field by Manitoba Hydro’s 17

on-site team of construction supervisors and environmental inspectors and through weekly 18

planning/coordination meetings. 19

18/07/12 54


CEC/MH-II-006a

Date May 29 2012

Reference Vegetation



1

Question: 2

Reference: Re-vegetation 3

Please provide a re-vegetation plan and include planned frequencies of re-vegetation, and 4

sourcing of native species. 5

Response: 6

Manitoba Hydro’s approach to re-vegetating areas where construction or maintenance activities 7

have been undertaken is to allow the area to naturally re-vegetate. Typically, re-vegetation will 8

only occur when the site may have been graded too deeply or in instances where re-seeding is 9

required in agricultural areas. If upon later inspection vegetation is found not to be naturally re-10

establishing, Manitoba Hydro may consider additional re-vegetation measures. There is no 11

planned frequency for re-vegetation as the rate of natural re-vegetation and need for further 12

action will be evaluated on a case–by-case basis. Re-vegetation methods and species will be 13

contingent upon the location (e.g., northern Manitoba vs. southern Manitoba). Manitoba Hydro’s 14

objectives for re-vegetation are to develop low growth plant/shrub communities wherever 15

possible. These low growing communities may be comprised of grasses, forbs, and shrubs that 16

will provide competition to tree species trying to re-establish, which in turn will reduce the 17

amount of subsequent maintenance required. 18

Native species will be sourced through local vendors and established seed mixes will be used as 19

appropriate (e.g. Manitoba Infrastructure and Transportation’s seed mixes). 20

18/07/12 55


CEC/MH-II-006c

Date May 29 2012

Reference Re-vegetation



1

Question: 2


Please explain who will choose the species for re-vegetation. Please provide a summary 4

explanation applicable to each ecozone. 5

Response: 6

Manitoba Hydro’s approach to re-vegetating areas where construction or maintenance activities 7

have been undertaken is to allow the area to naturally re-vegetate. When additional measures 8

are required, MH retains silviculture expertise within the corporation to determine which species 9

should be utilized for re-vegetation purposes dependent upon the location. 10

The appropriate time to determine precisely what type of vegetation will be required is in the 11

spring after construction has been completed. Vegetation species type will be based on what is 12

appropriate to the location and its ecozone. 13

18/07/12 56


CEC/MH-II-006f

Date May 29 2012

Reference Re-vegetation – P. 8-276


Question CEC/MH-II-006f

1

Question: 2


It is stated that extra care will be taken with adjacent vegetation when dealing with plants of 4

significance to Aboriginals. Shouldn’t the same care be taken for all plants in respect of the 5

environment? 6

Response: 7

The statement in the EIS is a mitigation measure to deal with valued plants in areas of use by 8

domestic resource harvesters. Manitoba Hydro anticipates consulting with First Nations, the 9

MMF, and Aboriginal communities on the Draft Environmental Protection Plans with the 10

intention of reviewing mitigation in areas of interest. As such mitigation is developed where 11

potential issues or interests are identified though consultation or assessment. Mitigation 12

measures are provided in the EIS for plants, where needed, based on their protected status or 13

societal value. 14

18/07/12 57


CEC/MH-II-007d

Date May 19th 2012

Reference Agriculture Technical Report


Question CEC/MH-II-007d

1

Question: 2

Reference: Agriculture – Volume 10.0 3

It was indicated that the disturbance provided by the line on low quality agricultural lands may 4

be an improvement. This will be a detriment to the environment – how will the competing 5

purposes be balanced. Will these lands include Crown Lands, and what are they coded for? 6

Response: 7

The siting of the Bipole III Final Preferred Route (FPR) is the result of a comprehensive Site 8

Selection and Environmental Assessment (SSEA) process with government, municipal leaders, 9

stakeholders, First Nation and Northern Affairs community leadership and members, the 10

Manitoba Metis Federation, Aboriginal Traditional Knowledge studies, all available constraints 11

data, multi-disciplinary biophysical and socio-economic studies and technical (including cost) 12

considerations. Twenty-eight evaluation criteria were used in the process (see EIS Chapter 7 13

and supporting appendices). Manitoba Hydro recognizes the fact that the greatest opportunity 14

for mitigating potential Project effects is through avoidance at the routing stage of Project 15

planning. As a result all larger blocks of crown lands (e.g. WMAs, community pastures) that 16

could be avoided were avoided during the routing stage of the Project. In areas of private lands 17

Manitoba Hydro is also sensitive to existing land use practices and seeks to minimize Project 18

effects on them while considering all other values. Alternative routing was reviewed extensively 19

in the SSEA process. The SSEA process showed a clear preference from numerous perspectives 20

in this area for the route that was chosen. For more details concerning the route selection 21

process and influences, please see the Bipole III EIS Chapter 7, Appendix 7a, Table 7A-1, 22

Section 8. 23

18/07/12 58


CEC/MH-II-007d

From an agricultural productivity perspective the clearing of wooded lands that are currently 24

pastured will generate more grass growth and therefore have an increased carrying capacity for 25

livestock. The Project is therefore considered a compatible land use with that of 26

grazing/ranching. 27

Although clearing the ROW through these lands west of Lake Manitoba will contribute to 28

fragmentation, this effect is not considered significant in a landscape that is naturally diverse in 29

land cover of alternate low wooded ridges and grass/shrub wetland swales. Project effects on 30

the grass and shrub wetlands are expected to be limited and short-term in nature from clearing. 31

These sites will recover within 2 to 3 years. The effects of fragmentation (ROW clearing across 32

woodland ridges) are minimized in this type of landscape and were mitigated for in the route 33

selection process. Potential fragmentation effects from the transmission line are also expected 34

to be minimal in agricultural areas due to the existing extent of anthropogenic development, 35

including yard sites, pastures and related infrastructure (e.g., roads). The wildlife community 36

that persists in this diverse landscape of low wooded ridges and grass/shrub wetland swales are 37

adapted to this environment. 38

In Environmental Assessment studies transmission lines generally are considered low impact 39

developments to the environment. Following construction there is very little activity associated 40

with a transmission line. Visual inspections are conducted once or twice annually by air or from 41

the ground. Vegetation management cycles are dependent on the rate of growth of tall growing 42

species on the ROW. These species may be restricted in areas of livestock grazing which is a 43

prominent land use practice in this region. 44

Although the ROW specifically is altered during the construction phase in forested/wooded 45

areas, grass, shrub and wetland environments see very little, if any, change over the long term. 46

The creation of additional grass/shrub environments may benefit some species, particularly 47

birds that have seen much of their grassland habitats disappear (e.g. Sprague's pipit (Anthus 48

spragueii), loggerhead shrike (Lanius ludovicianus). Others take advantage of the additional 49

edge effect created by the ROW (e.g. sharp-tailed grouse (Tympanuchus phasianellus), golden-50

winged warbler (Vermivora chrysoptera). Some interior forest species may be negatively 51

affected (e.g. ovenbird (Seiurus aurocapillus), pileated woodpecker (Drycopus pileatus). 52

18/07/12 59


CEC/MH-II-007d

The Project ROW traverses both Crown and private lands within the agricultural zone west of 53

Lake Manitoba. Both Crown and private lands are coded into two catergories where “Category 54

1” are limited agricultural use areas. Most of these lands are located in areas that are generally 55

wooded, intermixed with wetlands and lakes where there is little or no agricultural activity. 56

Where the land is being used for agriculture, the main activity is native grazing and native hay 57

production with small amounts of land in cultivation. Many areas consist of a ridge and swale 58

topography with small amounts of developed crop land. Soils are mostly bogs or glacial tills that 59

have thin surface soil horizons, are stony, and have limited agricultural potential. These soils 60

are generally found north of PTH 16 from the east side to the center of the Westlake area, 61

north past the north side of Rorketon, south and east of Winnipegosis, southeast and north of 62

Cowan, northeast and north of Lenswood, and Bellsite to The Pas. Some “Category 2” lands are 63

suitable for mixed farming purposes. These lands are more productive than “Category 1” lands 64

and are generally found intermixed with the latter in pockets between PTH 16 and Eddystone, 65

Rorketon north, southwest of Winnipegosis, east of Cowan, the Swan River Valley, Bellsite east, 66

at Mafeking and The Pas. Most of these lands are in native grass and trees while some lands 67

have been broken and are in tame forage and cereal crops. Some poorer lands are reverting 68

back to native forage. Farmers in the area produce crops and livestock on cultivated and native 69

hay and pasture lands. Many of these areas are high lime glacial till plains in the eastern and 70

central part of the study area. These soils have limited agricultural capability for crop 71

production. 72

18/07/12 60


CEC/MH-II-007j

Date May 29 2012

Reference Agriculture Technical Report (P. 67 and Section 9.8.3)


Question CEC/MH-II-007j

1

Question: 2


Tower Interference with Aerial Spraying (P. 67 and Section 9.8.3): 4

Response: 5

No question. 6

18/07/12 61


CEC/MH-II-007n

Date May 29 2012

Reference Agriculture Technical Report


Question CEC/MH-II-007n

1

Question: 2


Please clarify the monitoring plans after construction. What is to be monitored, why and by 4

whom? Are there any lessons learned from Bipole I & II that should be applied here. 5

Response: 6

As per Appendix H of the Draft Environmental Protection Plan for the Bipole III Transmission 7

Project, Manitoba Hydro plans to monitor agriculture capability by conducting semi-annual 8

monitoring of crops using aerial or ground patrols for two years following construction on 9

agricultural lands. The rationale for monitoring agriculture capability is to be responsive to 10

concerns from participants during the Environmental Assessment Consultation Process for the 11

Bipole III Transmission Project regarding the potential loss of agricultural land in Agro-Manitoba 12

due to soil compaction from construction and maintenance activities. 13

One lesson learned from Bipole I and II that was applied for Bipole III was a design change 14

from guyed towers to self supporting towers to reduce the footprint by removing less farmland 15

from production and reducing the chance of inadvertent contact from farm equipment. 16

18/07/12 62


CEC/MH-II-009a

Date May 29 2012

Reference Converter Stations/Towers and Conductors/Ground Electrode for Bipole I

and Bipole II



1

Question: 2

Reference: Converter Stations/Towers and Conductors/Ground Electrode for Bipole 3

I and Bipole II 4

Please provide some background in the form of an Executive Summary with reference to any 5

incidents that occurred during commissioning of and post operation, including frequencies of 6

typical monopolar operations due to maintenance activities of the existing converter stations, 7

Bipole I and Bipole II and the Ground Bed Electrodes. 8

Response: 9

Monopolar operation is required when a pole outage occurs as a result of an equipment 10

malfunction (forced outage), is planned for maintenance purposes or is required to complete 11

station life extension equipment upgrades (planned outage). Bipole I and Bipole II are designed 12

with multiple valve groups per pole, thus the probability of a pole outage is reduced. 13

Forced Outages: 14

Historically there have been approximately 16 forced pole outages per year with an average 15

duration of less than two hours per outage. Additionally, there are approximately 6 pole forced 16

outages per year attributed to transmission line events with a shorter duration of 0.86 hours per 17

outage. 18

18/07/12 63


CEC/MH-II-009a

Planned Outages: 19

One 48 hour pole outage per year is required to complete planned maintenance. These outages 20

are planned on weekends, in off peak seasons. 21

Other Maintenance Related Planned Outages: 22

Additional pole outages necessary to address operational issues to prevent forced outages that 23

cannot be deferred to planned maintenance outages has historically resulted in approximately 24

12 outages a year with duration of 8.5 hours per outage. These outages are planned in off peak 25

hours, evenings and weekends. 26

Outages are also required as equipment ages and pole level equipment requires upgrading. 27

These types of outages are required after approximately the 25 to 30 years of operation. 28

Commissioning and Start of Service: 29

In 1979 during Bipole II development and prior to having two valve groups per pole in-service, 30

transformer issues resulted in monopolar operation for approximately eight months. No unusual 31

operating experiences or difficulties were encountered during this time. 32

For commissioning purposes it is necessary to operate in monopolar for various test conditions 33

and sequences. The duration and timing can be controlled to a certain extent, as commissioning 34

procedures are developed. Additionally, as new stations are developed, equipment can be 35

placed into service in phases that may result in single valve group per pole operation for a 36

limited period of time. In this mode pole outages may be more frequent. 37

Over the 40+ years of HVdc operation, Manitoba Hydro has not had significant requirements to 38

operate in monopolar for long durations. When required to operate in monopolar, performance 39

has been positive with no public or technical issues encountered. 40

18/07/12 64


CEC/MH-II-010a

Date May 29 2012

Reference Reference: Mammals Volume 3



1

Question: 2

Reference: Mammals Volume 3 3

There were many assumptions made about marten movement patterns, use of brush piles and 4

use of ROW without references to support these assumptions. There is no discussion on how 5

or if there will be verification of these assumptions. Please provide additional information 6

Response: 7

Based on published findings documenting marten use of forestry areas, it is assumed that 8

marten will travel through and across habitats associated with the Bipole III ROW. 9

In addition to the information provided in the EIS, resting and denning sites are described as 10

key features for the survival of American marten (Heater and Grande, 2000). Clearing and 11

construction will result in downed woody debris, and as vegetation regenerates naturally in the 12

ROW, marten foraging and travel will not be negatively impacted. Slash piles have been 13

documented to be used as resting areas and natal/non-natal denning sites by marten (Heater 14

and Grande, 2000) as well as for foraging (OMNR, 1986). Recently disturbed forests containing 15

sapling and shrub vegetation are not ideal marten habitat although are used to a certain extent 16

(Poole et al, 2004). With the regeneration of deciduous or coniferous vegetation and brush, 17

marten become more likely to forage in clear-cuts (Steventon and Major, 1982). Gyug (1994) 18

found that marten use of clearcuts was correlated with the volume of slash piles from the clear 19

cut and slash piles located near forest edges were most regularly used by marten. Similarly, 20

slash piles laid out in a continuous pattern and allowing for continuous movement between piles 21

were more regularly used than piles spaced further apart (Gyug, 1994). Marten were also 22

shown to use debris piles in recently cleared areas (Gyug, 1994). With respects to crossing 23

18/07/12 65


CEC/MH-II-010a

events, marten were found most frequently cross cleared distances between 50 and 100 m and 24

cleared areas which contained slash piles (Gyug, 1994). 25

Manitoba Hydro will conduct monitoring of marten activity along the ROW with trappers by 26

assessing the effects of ROW construction and operation on marten abundance and trapping 27

success. 28

References: 29

Gyug, L.W. (1994). Wildlife use of logging debris piles in clearcuts. Final Report. B.C. Ministry of 30

Environment. Penticton, B.C. 45 p. 31

Heater, T. W.-, & Grande, L. (2000). Resting Sites of American Martens in Northeastern and 32

Denning Oregon. Northwest Science, 74 (3). 33

OMNR (Ontario Ministry of Natural Resources). (1986). Guidelines for Providing Furbearer 34

Habitat in Timber Management .MNR # 51601. 35

Poole, K. G., Porter, A. D., Vries, A. D., Maundrell, C., Grindal, S. D., Cassady, C., & Clair, S. 36

(2004). Suitability of a young deciduous-dominated forest for American marten and the effects 37

of forest removal. Canadian Journal of Zoology, 435, 423-435. doi:10.1139/Z04-006 38

Steventon, J.D. and J.T. Major. 1982. Marten use of habitat in a commercially clear-cut forest. 39

Journal of Wildlife Management. 46: 175-182. 40

18/07/12 66


CEC/MH-II-014

Date May 29 2012

Reference CEC Information Request #2


Question CEC/MH-II-014

1

Question: 2

The provincial Protected Area Strategy and those areas designated as protected areas have 3

prohibitions on development and some have specific clauses to prevent hydro related 4

developments. The line routing intrudes on several protected areas, have alternative routing 5

been investigated? If so what were these alternatives and why were they rejected? Have there 6

been any discussions with MCWS regarding alternatives? 7

Response: 8

The proposed Bipole III transmission line route traverses the following Wildlife Management 9

Areas (WMA) and Areas of Special Interest (ASI): 10

Churchill WMA - intrudes on the far southwest corner of the WMA; this is unavoidable as the 11

WMA boundary extends to the Nelson River. Alternative route options were investigated both 12

north and south of the current location but were determined not suitable due to terrain and 13

large wetlands in the area. The final preferred route was selected to minimize stream 14

crossings, the size of streams crossed by selecting crossings at headwaters, and to provide the 15

most suitable soils and terrain for transmission tower footings. The route was also selected for 16

reliability purposes by meeting separation distances between Henday and Radisson Converter 17

Stations and Bipoles I & II. 18

Stephens Lake ASI – the preferred route traverses the east, south-central and southwest 19

portions of the ASI; unavoidable without significant technical challenges including increased line 20

length, foundation issues and compromising reliability. Other routing options were examined 21

south and north of the ASI. Going south would place Bipole III adjacent to other major 22

Manitoba Hydro infrastructure, including Henday and Radisson converter stations and Bipoles I 23

18/07/12 67


CEC/MH-II-014

& II compromising reliability. Going north around the ASI would entail considerably increased 24

line length, increased number of angle towers, challenging terrain conditions, and construction 25

access difficulties. This was also contrary to input provided by Tataskweyak Cree Nation 26

through their ATK study. 27

Tomb Lamb WMA – traverses along northwest boundary and west-central portion before 28

crossing the Saskatchewan River; unavoidable as there is no space between Clearwater Lake 29

Provincial Park and Tomb Lamb WMA. Alternative routing options were examined in this area 30

but proved very challenging given the number of land use constraints located in the area 31

surrounding The Pas. Routing south around the WMA is not an option because of Tomb Lamb 32

Addition ASI, proposed Summerberry WMA and Cedar Lake. Routing north of Clearwater Lake 33

Provincial Park and west of The Pas then involves routing through the Saskeram WMA and has 34

further downstream ramifications as well. 35

Proposed Summerberry WMA – traverses the northwest and southwest corners. Routing south 36

of The Pas took advantage of the existing transmission line running north-south by paralleling 37

next to it. This was done to minimize the effects of habitat fragmentation. Alternative options 38

were examined further away from the existing feature before moving it adjacent to the existing 39

line. 40

Red Deer Lake ASI (Proposed Red Deer River WMA) – traverses along southeastern boundary; 41

unavoidable given all existing constraints. Alternative routing options were also examined in the 42

Red Deer Lake ASI area. Routing further east was not an option due to the proximity of Lake 43

Winnipegosis, First Nation Lands, Treaty Land Entitlements and the Lake Winnipegosis Salt Flats 44

Ecological Reserve. Routing west of the ASI has both upstream and downstream ramifications 45

as well as wildlife disturbance and habitat fragmentation issues associated with it in an 46

otherwise minimally disturbed landscape that includes The Bog woodland caribou herd. 47

Manitoba Hydro engaged Manitoba Conservation and Water Stewardship (MCWS), Protected 48

Areas Initiative (ASI) in discussions throughout the routing process. Data were exchanged 49

between the two parties to facilitate a comprehensive routing review by both parties. Manitoba 50

Hydro made significant effort first, to avoid protected areas and PAI areas of interest and 51

second, to minimize project effects where avoidance was not possible. In areas of specific 52

concern by PAI, rationale was provided to support the decisions made. The rationale was 53

18/07/12 68


CEC/MH-II-014

ultimately accepted by PAI. In some cases, PAI has requested site specific mitigation measures 54

to address issues of concern (e.g. Lake Winnipegosis Salt Flats springs). These will be 55

implemented along with all other Manitoba Hydro mitigation measures detailed in the draft 56

Environmental Protection Plan (EIS Chapter 11, Attachment 11-1). 57

18/07/12 69


CEC/MH-II-019b

Date May 29 2012

Reference Resource Use Technical Report



1

Question: 2

Reference: Resource Use Technical Report 3

Please file the trapper’s compensation policy and explain how the policy will be applied. 4

Response: 5

The Trappers Notification/Compensation Policy is comprised of two components, the Notification 6

Program and the Compensation Program; further detail is provided below in text taken from the 7

policy brochure. 8

9

In the case of the Bipole III Transmission Project, the implementation of the Policy will include 10

discussions with individual registered trappers, users of Open Trapping Zones, and Manitoba 11

Local Fur Councils. Manitoba Hydro has begun direct engagement with trappers, trapping 12

associations, and some Fur Councils whose trapping activities may be affected by the Bipole III 13

Transmission Project. Manitoba Hydro’s objective is to reach agreements with eligible holders 14

of registered traplines in the vicinity of the project prior to the start of construction. 15

18/07/12 70


CEC/MH-II-019b

Trappers Notification/ 16

Compensation Policy 17

for New Transmission Development 18

19

At Manitoba Hydro, our job is to provide a secure and reliable supply of energy for the people of 20

this province. At times, this responsibility requires us to design and build new facilities, such as 21

transmission lines, to meet Manitoba’s energy needs. 22

With almost two-thirds of the province divided into registered trap lines it is almost certain that 23

a trap line will be traversed when these new developments occur. Manitoba Hydro recognizes 24

that resource users, such as trappers, rely on wildlife for commercial and personal use and we 25

are committed to considering the interests of all those who may be affected by our actions. We 26

want to work with trappers at every stage of development to obtain information that will assist 27

in assessing locations for future development and reducing project related effects. And, we 28

want to ensure those trappers impacted by our developments are compensated. With these 29

aims in mind, Manitoba Hydro developed two trapper related programs, the Notification 30

Program and the Compensation Program. 31

32

The Notification Program 33

The Trappers Notification Program was developed to allow for input from local trappers during 34

development stages of new major transmission projects. 35

36

Initial and Intermediate 37

Notification 38

Manitoba Hydro will ensure that well in advance of any activity, the users of any registered trap 39

lines in the vicinity are made aware of the proposed development. When a preferred route or 40

location has been selected, there will be two notifications that provide an opportunity to: 41

• Review project plans 42

• Record additional trapper information 43

• Discuss any trapper related employment or business opportunity 44

• Explain the timing of the project activities on their trap line 45

• Discuss and finalize any settlement agreement 46

18/07/12 71


CEC/MH-II-019b

Pre-construction 47

Notification 48

Prior to construction activities, a fair and reasonable amount of compensation will be 49

determined with eligible holders of registered trap lines. If acceptable to both parties, monetary 50

settlements for the disturbance period will be offered to eligible trappers and a release 51

agreement signed. In addition, trappers will be: 52

• Updated on project schedules 53

• Advised to remove trapping equipment as required. 54

55

Participation 56

Manitoba Hydro may also ask for the assistance of trappers in gathering trapping related 57

information for new transmission projects. That assistance may include the documentation of 58

specific data and traditional knowledge regarding the trap lines in the vicinity of proposed 59

development sites. 60

61

The Compensation Program 62

The trappers compensation program is intended to provide compensation to holders of 63

registered trap lines whose lines are affected by the construction of transmission facilities that 64

are 115 kilovolts or greater. 65

66

That compensation may include: 67

• Trap line improvements, 68

• Employment opportunities 69

• Equipment replacement 70

• Monetary settlement. 71

72

Trappers may be compensated for any damage during construction activities to equipment, 73

buildings, and trails used for trapping. 74

18/07/12 72


CEC/MH-II-019b

Monetary settlement 75

In situations where there may be a reduction of trapping income due to activities related to 76

transmission construction, Manitoba Hydro may provide settlement packages for the 77

construction disturbance period only. 78

79

Settlement Agreement 80

Once an understanding on compensation is reached, including the basis for determining 81

compensation amounts, holders of affected registered trap lines will be asked to sign a release 82

agreement. 83

18/07/12 73

Trappers Notification/Compensation Policyfor New Transmission Development

At Manitoba Hydro, our job is to provide a steady and reliable supply of energy for the people of this province. At times, this responsibility requires us to design and build new facilities, such as transmission lines, to meet Manitoba’s energy needs. With almost two-thirds of the province divided into registered trap lines it is almost certain that a trap line will be traversed when these new developments occur.

For more information:For more information regarding Manitoba Hydro’s Trappers notification and compensation programs for new transmission development, please contact:

Marc WanklingProperty DepartmentManitoba Hydro at:Ph. (204) 360-4462Fax. (204) 360-6184E-mail. [email protected]

Duane HatleyCommunity Relations DepartmentManitoba Hydro at:Ph. (204) 360-4414Fax. (204) 360-6128E-mail. [email protected]

Manitoba Hydro recognizes that resource users, such as trappers, rely on wildlife for commercial and personal use and we are committed to considering the interests of all those who may be affected by our actions. We want to work with trappers at every stage of development to obtain information that will assist in assessing locations for future development and reducing project related effects. And, we want to ensure those trappers impacted by our developments are compensated. With these aims in mind, Manitoba Hydro developed two trapper related programs, the Notification Program and the Compensation Program.

Our Environmental Management PolicyManitoba Hydro is committed to protecting the environment. In full recognition of the fact that corporate facilities and activities affect the environment, Manitoba Hydro integrates environmentally responsible practices into its business. This includes considering the interests and utilizing the knowledge of our customers, employees, communities, and stakeholders who may be affected by our actions.

18/07/12 74

The Notification ProgramThe trappers notification program was developed to allow for input from local trappers during development stages of new major transmission projects.

Pre-construction NotificationPrior to construction activities, a fair and reasonable amount of compensation will be determined with eligible holders of registered trap lines. If acceptable to both parties, monetary settlements for the disturbance period will be offered to eligible trappers and a release agreement signed.

In addition, trappers will be:•Updated on project schedules•Advised to remove trapping

equipment as required.

ParticipationManitoba Hydro may also ask for the assistance of trappers in gathering trapping related information for new transmission projects. That assistance may include the documentation of specific data and traditional knowledge regarding the trap lines in the vicinity of proposed development sites.

The Compensation Program The trappers compensation program is intended to provide compensation to holders of registered trap lines whose lines are affected by the construction of transmission facilities that are 115 kilovolts or greater.

That compensation may include:•Trap line improvements,•Employment opportunities•Equipment replacement•Monetary settlement.

Trappers may be compensated for any damage during construction activities to equipment, buildings, and trails used for trapping.

Monetary settlementIn situations where there may be a reduction of trapping income due to activities related to transmission construction, Manitoba Hydro may provide settlement packages for the construction disturbance period only.

Settlement AgreementOnce an understanding on compensation is reached, including the basis for determining compensation amounts, holders of affected registered trap lines will be asked to sign a release agreement.

Initial and Intermediate NotificationManitoba Hydro will ensure that well in advance of any activity, the users of any registered trap lines in the vicinity are made aware of the proposed development. When a preferred route or location has been selected, there will be two notifications that provide an opportunity to:•Review project plans•Record additional trapper

information•Discuss any trapper related

employment or business opportunity

•Explain the timing of the project activities on their trap line

•Discuss and finalize any settlement agreement.

18/07/12 75


CEC/MH-II-021

Date May 29 2012




1

Question: 2

With regard to accidents and malfunction, please identify and assess worst case scenarios. 3

Response: 4

With regard to accidents and malfunctions, the worst case scenarios for converter stations, 5

construction activities and transmission line operation are summarized below. Preventative 6

measures are undertaken to reduce the probability of accidents and malfunctions occurring, 7

barriers are incorporated (i.e. containment systems) to prevent released materials or fires from 8

spreading to the surrounding environment, and finally spill response plans and associated spill 9

response materials are relied upon should a malfunction or accident occur and threaten to 10

introduce hazardous materials to the surrounding environment. 11

Converter Stations: 12

Worst Case Scenario: in-service failure of a converter transformer and potential release of 13

insulating oil. 14

As indicated in Section 3.5.2.3 of the EIS, the 14 converter transformers are filled with 15

approximately 115,000 litres of insulating oil. A failure could result in a fire or release of oil. 16

This risk is considered low. 17

Prevention and Mitigation: 18

To reduce the risk of a transformer tank breach and oil release, pressure release devices are 19

installed on each converter transformer, which are designed to release internal tank pressure 20

following a fault before a tank breach occurs. 21

18/07/12 76


CEC/MH-II-021

As well, the following measures will be put in place to reduce the risk to the environment: 22

The converter station is designed to minimize the spread of fire, 23

A fire suppression system as outlined in Section 3.5.2.1; 24

A oil containment system as outlined in Section 3.5.2.1; and 25

A spill response plan will be developed for each individual site and spill response 26

materials will be available on each site. 27

The potential impacts to the environment without the measures outlined above would be the 28

spread of the fire to other components of the converter station and potential contamination of 29

the surrounding environment (land or water). 30

31

Transmission Line Construction and Operation: 32

Worst Case Scenario: Fuel releases and forest fires. 33

Fuel Release 34

Fuel releases could occur as a result of: improper or inadequate fueling techniques by 35

construction contractors or Manitoba Hydro staff, improper or inadequate storage of fuel or 36

release of hydraulic oil from compromised equipment. 37

Prevention and Mitigation 38

Releases that do occur are prevented from entering the environment with the following 39

measures: procedures for fueling that clearly indicate precautions to be taken, fueling away 40

from water bodies, the use of portable containment for fueling points, and the requirement for 41

regular inspection of hydraulic hoses. 42

Should a release occur the magnitude of the event is mitigated through the requirement to 43

have a spill kit on site at the various locations where fueling activities are undertaken; Manitoba 44

Hydro staff and contractor staff are trained on how to activate and utilize the spill kits; the spill 45

response plan is reviewed with all Project personnel; and all releases, no matter the quantity or 46

type, are reported to the Manitoba Hydro construction supervisor and/or the Manitoba Hydro 47

environmental inspector. 48

18/07/12 77


CEC/MH-II-021

Forest Fires 49

Forest fires can result from transmission line clearing and construction activities, and operation 50

of the transmission line in the following ways: 51

burning of brush piles (clearing and construction only) 52

the use of machinery undertaking right-of-way (ROW) clearing or travelling the corridor 53

during maintenance activities (i.e., sparks from contact with rock outcrops, catalytic 54

converters) 55

operations: infrastructure failure (e.g. structural failure of a tower or line blow out ) in a 56

remote location. 57

58

To reduce the likelihood of forest fires igniting along the ROW the following precautions are 59

taken: 60

Bipole III line design has adopted a high reliability level (1 in 150 year) accepted by 61

the industry to design its transmission towers. This means that a tower may fail once 62

in a 150 years for expected ice and wind conditions in Manitoba. This is a marked 63

improvement in comparison to the existing Bipole I & II tower design that 64

incorporated an approximately 1 in 50 year failure rate. The Bipole I & II towers 65

have only experienced one catastrophic failure in their life time. Some portions of 66

the Bipole III line will be designed with an expected 1 in 500 year failure rate. 67

Attempt to undertake the majority of burning during the winter months. 68

Ensure all burn piles do not exceed the fire loading and are located at a minimum 69

distance of 15m away from standing timber, as per provincial regulations. 70

Fire suppression equipment on site at all times (contractors and MH staff are 71

required to carry fire extinguishers in all equipment (i.e., bulldozers, track hoes) as 72

per safety and health regulations). 73

Obtain a burning permit if any burning is to occur between April 1st and November 74

15th. 75

Regular inspections to enable early identification and mitigation of risks for 76

transmission line infrastructure failure. 77

18/07/12 78


CEC/MH-II-021

In the event that a line goes down, the systems operator would transfer power to adjacent lines 78

reducing the potential for a live line to ignite a fire. 79

18/07/12 79


CEC/MH-II-022

Date May 29 2012




1

Question: 2

What are the effects of a newly cleared ROW with respect to local residents, eg. country food 3

production? 4

Response: 5

The effects of right-of-way clearing on domestic resource use are discussed in section 8.3.2 of 6

the EIS. See pages 272-273 for specific discussion of the potential effects of construction on 7

Aboriginal domestic resource use. 8

18/07/12 80


CEC/MH-II-024

Date May 29 2012




1

Question: 2

Please indicate how the multiple criteria (biophysical, socio-economic, technical, costs) were 3

combined to determine the best route within each line segment. Please define what your cost 4

requirements are. 5

Response: 6

The siting of the Bipole III Final Preferred Route (FPR) is the result of a comprehensive Site 7

Selection and Environmental Assessment (SSEA) process that included government, municipal 8

leaders, stakeholders, landowners, First Nation and Northern Affairs community leadership and 9

members, the Manitoba Metis Federation, Aboriginal Traditional Knowledge studies, all available 10

constraints data, multi-disciplinary biophysical and socio-economic studies and technical 11

(including cost) considerations. Twenty eight (28) criteria that represent the biophysical, socio-12

economic, land use, technical, ATK, and public input considerations were used in the SSEA 13

process to select and assess the Preliminary Preferred Route (PPR) and the Final Preferred 14

Route (FPR). These criteria and their more specific considerations are discussed in EIS Chapter 15

7, Appendix 7A. 16

Study team specialists were responsible for each criteria and to conduct evaluations on all of 17

the alternative route segments independently. Specialists rated segments based on criteria 18

explained in Appendix 7A. These ratings were collated in the Route Selection Matrix (EIS 19

Chapter 7, Appendix 7A) at which point a committee of experts reviewed stakeholder input 20

(including ATK) and the evaluations conducted by the discipline specialists on a section by 21

section basis. Preference was recorded based on all of the information available. Consideration 22

was made for continuity between sections. 23

18/07/12 81


CEC/MH-II-024

For a more detailed description of the route selection process see EIS Chapter 7, including the 24

supporting appendices 7A, 7B and accompanying maps. 25

Project cost considerations, as part of the route selection process, are part of the technical 26

criteria group, specifically as it pertains to foundations, angle towers, line length and 27

construction access (See Appendix 7A, Chapter 7 of EIS). Cost was not viewed specifically in 28

monetary terms (i.e. amount of dollars) rather in relative terms when comparing segments. As 29

an example, if segment A traverses poorer terrain conditions (requires more complex tower 30

foundations), requires more angle towers (larger than in-line towers), is longer in line length 31

and more difficult to access for construction purposes than segment B, then segment A would 32

receive a less favourable rating (greater constraint) for those criteria over segment B. These 33

criteria capture the cost consideration in the route selection approach. 34

18/07/12 82


CEC/MH-III-032

Date June 7th 2012

Reference P.15 ATK Technical Report #2

Source CEC Information Request #3

Question CEC/MH-III-032

1

Question: 2

Please provide an update on the status of the conduct of an archaeological assessment 3

raised by SLFN 4

Response: 5

Manitoba Hydro continues to meet with SLFN regarding conducting an archaeological 6

assessment of portions of the Bipole III route which are of interest to the First Nation. 7

18/07/12 83


CEC/MH-III-037c

Date June 7 2012



Question CEC/MH-III-037c

1

Question: 2

Please comment on the impact of the following analyses as a result of lack of field 3

studies: 4

c) Animals, plants, fish, birds, weather, lakes and river information are only 5

technical. 6

Response: 7

Please refer to the response provided for CEC/MH-III-038 8

18/07/12 84


CEC/MH-III-037e

Date June 7 2012



Question CEC/MH-III-037e

1

Question: 2

Please comment on the impact of the following analyses as a result of lack of field 3

studies: 4

e) Please provide clear information as to the variance possible in their 5

conclusions given the lack of fieldwork to support conclusions in the EIS. 6

Response: 7

Please refer to the response provided for CEC/MH-III-038 8

18/07/12 85


CEC/MH-III-038

Date June 7th 2012




1

Question: 2

As noted in Manitoba Wildlands March 16, 2012 Comments on the EIS: “The fact of the 3

matter is that much of Manitoba, particularly the northern two-thirds of the province, 4

have only had limited field studies performed. Relying on sparse data could result in 5

erroneously drawing the conclusion that no species of concern will be impacted, when in 6

fact the truth may be that the species are there and they have never been recorded.” 7

This statement is also equally true for archeology studies. Please comment. 8

Response: 9

The use of available information and desktop analysis is appropriate for initial study area 10

delineation and characterization as discussed in Chapter 4, Section 4.2.3.1. Further, the 11

identification and gathering of available information (as described in Section 4.2.7) is the 12

appropriate and responsible starting point for all environmental assessments. All 13

available information was identified and evaluated for applicability to the Project. Further 14

data needs were then identified and pursued, including field studies. Field data was then 15

again applied to habitat models for environmental assessment purposes and the 16

identification of ESSs. 17

The Site Selection and Environmental Assessment (SSEA) approach does not 18

“erroneously” lead to conclusions on the occurrence or non-occurrence of species of 19

concern or VECs in the local study area of the preferred route. Where specific field 20

studies do not cover a particular area, habitat and heritage resource models are used to 21

determine the potential for occurrence of VECs and species of concern. This is also 22

18/07/12 86


CEC/MH-III-038

supplemented with local knowledge, where available, from ATK studies or consultation 23

input. 24

In summary, the broad study area delineation and identification of the alternative routes 25

relied substantially on available constraints data, field investigations and consultation 26

input. The next step was the evaluation of the alternative routes and selection of the 27

preliminary preferred route (PPR) which relied on the evaluation of available data 28

assembled and customized for the Bipole III Transmission Project study area, field 29

studies, study specialist knowledge and expertise and consultation input. The last step 30

was the refinement of the PPR to a Final Preferred Route (FPR) and FPR specific 31

environmental assessment which was based on field studies, data analysis, modeling 32

and additional consultation. 33

Manitoba Hydro expended considerable resources to acquire available data relative to 34

the Project study area with the objective of enabling a thorough route selection process 35

and comprehensive environmental assessment on a final route. Input was also obtained 36

from knowledgeable people on the land such as Aboriginal leaders and members 37

(through consultation and ATK studies), Manitoba Conservation and Water Stewardship 38

and Manitoba Hydro regional staff and landowners, among others. Data collected 39

included reports, documents, tabular and spatial data (e.g. soils, surficial geology, 40

topography, hydrology, Manitoba’s ecological land classification system, Manitoba 41

wetland classification, forest resource inventory, the Landsat derived Landcover 42

Classification (LCC), forest fire history, forest depletion and renewal, cadastral, 43

infrastructure, Provincial Heritage Inventory, Manitoba Conservation Data Centre, Ducks 44

Unlimited Canada, Manitoba Wildlife Federation, Manitoba Habitat Heritage Corporation, 45

etc.) that was combined in a Project specific GIS database for study purposes. Where 46

possible data sets were updated to more closely reflect current conditions and to 47

customize it for Project purposes (e.g. the integration of forest fire history, forest 48

depletion and renewal data, soils data, ecological land classification system data with 49

the LCC to create the Landcover Classification Enhanced for Bipole (LLCEB)). 50

With a comprehensive database at hand, Manitoba Hydro’s well established SSEA 51

process uses a step wise coarse to fine filter approach to identify and evaluate potential 52

18/07/12 87


CEC/MH-III-038

alternative routes. A very broad spectrum of criteria was used to guide route 53

identification and eventual evaluation. The initial study area delineation, characterization 54

and identification of alternative routes was based on the review of available data (e.g. 55

soils, surficial geology, land cover/habitat, socio-economic, heritage data, etc.) coarse 56

scale constraints data (e.g. parks, ASIs, WMAs, etc.), air photo interpretation and aerial 57

reconnaissance in the north. In agro-Manitoba this was supplemented with ground 58

truthing and adjusting draft alternative routes based on constraint findings. 59

Broad study area-wide field studies were undertaken at the alternative route stage to 60

augment available baseline information (e.g. bird, caribou, wolf, wolverine studies, 61

archaeological field studies, etc.) where population based information was required 62

primarily for far-ranging species. 63

Most biophysical studies are habitat/ecosite driven where land cover data (e.g. forest 64

resource inventory, LCCEB, wetland classifications, hydrology, etc.) are interpreted and 65

evaluated by experienced biologists as habitat for valued environmental component 66

(VEC) species (plants and animals). Models further ranked habitat for quality relative to 67

each VEC species across the study area. 68

Such habitat/ecosite analysis was further used to identify potential locations of rare and 69

uncommon ecotypes as well as those vegetation communities that may harbour rare, 70

threatened or endangered species. This information, supplemented with aerial photo 71

interpretation and Manitoba Conservation Data Centre data (existing) was then used to 72

plan targeted field studies (e.g. bird, aquatics, amphibian, reptiles, herptiles, vegetation) 73

relative to the Preliminary Preferred Route (PPR). This latter stage, representing the fine 74

filter aspect of the assessment, identified and deals with many small and point specific 75

values, including heritage resources. Terrain and soils followed a similar approach 76

focusing on rare and single enduring features in ASIs and sensitive site types (e.g. steep 77

slopes, fine erosion prone mineral soils, permafrost) for field examination and sampling. 78

This approach also led to the identification of a multitude of site-specific environmentally 79

sensitive sites (ESS) each of which are addressed with mitigation measures in the draft 80

Environmental Protection Plan (EIS Chapter, Attachment 11-1). 81

18/07/12 88


CEC/MH-III-038

Manitoba Hydro’s SSEA coarse to fine filter approach is a well-tested and proven 82

approach to linear utility corridor routing and environmental assessments. While taking 83

advantage of available data, it also allowed for the customization of data for Project 84

purposes as well as the targeted acquisition of new field data, where required. Data 85

were used to construct and run habitat models for VECs and to assist in identifying ESSs 86

so that proper mitigation measures can be applied. 87

For more details on field studies conducted refer to the Bipole III Transmission Project 88

technical reports for: 89

• Aquatics; 90

• Birds; 91

• Caribou; 92

• Heritage resources; 93

• Mammals; 94

• Terrestrial invertebrates, amphibians and reptiles; 95

• Groundwater; 96

• Terrain and soils, and 97

• Vegetation. 98

Note that the field work conducted to date includes general sampling and has 99

specifically targeted habitats in which the discipline specific VECs have a reasonable 100

probability of occurring. 101

Additional field work will be undertaken in advance of project construction to locate and 102

protect sensitive sites (e.g. nests, dens, mineral licks, listed species, heritage resources, 103

etc.). Such sensitive sites are mostly point based (or small polygons) with provisions in 104

the Environmental Protection Plan to protect them when such are encountered. 105

The approach by Manitoba Hydro is not to assume that species of concern are not 106

present. While the focus remains on species of concern, a next level up approach is 107

taken to protect ecosites identified as potential habitats for such species as loss of 108

habitat remains the primary threat to species and sites of heritage resources. This 109

18/07/12 89


CEC/MH-III-038

approach has also enabled Manitoba Hydro to avoid sensitive habitat ecosites and 110

heritage resources during the routing process. 111

18/07/12 90


CEC/MH-III-044

Date June 7th 2012

Reference Chapter 8 – 102-4



1

Question: 2

The EIS states (Ch. 8 – 102-4): “Transmission lines are expected to have little impact on 3

habitat availability for Moose.” but identifies potential negative effects of poaching, ATV 4

use, predation and disease. The EIS asserts that the majority of potential negative 5

effects were “mitigated during the planning and routing process.” Mitigation measures 6

include restricting hunting and firearm access among on work camps, performing 7

construction in winter to avoid construction during calving season, pre-construction 8

surveys to identify and locate “mineral licks” and other important habitat areas. Please 9

elaborate on the proposed mitigation measures 10

Response: 11

A number of mitigation measures were included in the Bipole III EIS to reduce the 12

impact of transmission line development on moose populations. Routing of the Bipole III 13

Final Preferred Route (FPR) avoided the majority of remote and unfragmented high 14

density moose areas with routing preferentially occurring in areas with pre-existing 15

linear features and existing anthropogenic disturbance. To minimize construction 16

activities impacting on moose during critical periods, for example in springtime when 17

parturition and early developmental stages are occurring, clearing and construction 18

activities will occur in the winter. Prior to clearing and construction, pre-construction 19

surveys will identify potentially sensitive sites such as mineral licks. Mineral licks (if 20

found) will be clearly marked, with a minimum buffer of 120m, to ensure that they are 21

avoided during construction. Other protection measures will be based on site specific 22

factors and environmental conditions. 23

18/07/12 91


CEC/MH-III-044

During construction of the Bipole III transmission line, riparian area buffers will be 24

applied to serve as habitat protection for many terrestrial wildlife species including 25

moose. Riparian area buffers will be 7, 15 or 30m, with all shrubs and herbaceous 26

vegetation being retained. A full description of riparian buffer guidelines is available in 27

the Aquatic Environment Technical Report (North/South Consultants Inc., 2011). 28

With respect to hunting, possession of firearms will be prohibited at work camps and at 29

active construction sites. Access along the right-of-way will be monitored during 30

construction. An access management plan is being developed by Manitoba Hydro which 31

will be reviewed by Manitoba Conservation and Water Stewardship. 32

Please also see response provided for CEC/MH-III-121 related to access management 33

and CEC/MH-II-003d. 34

18/07/12 92


CEC/MH-III-049

Date June 7th 2012

Reference Chapter 8



1

Question: 2

Thermal cover and other means to mitigate heat stress is particularly important to 3

moose, as the species begins to expend energy to thermo regulate at -5 C in the winter 4

and 14 C in the summer. A recent publication in relation to a significant moose decline 5

in Minnesota implicated warm temperature, and expressed concern over the potential of 6

global warming to impact on the viability of moose populations (Lenarz et al. 2010. 7

J.Wildl.Manage). Please explain why the importance of thermal cover received little to 8

no attention within Chapter 8. Why was thermal cover not considered in the context of 9

cumulative effects in those areas where forestry development has occurred. 10

Response: 11

The area of the 66m wide ROW will not affect the current supply of area for thermal 12

regulation, but rather will contribute to increasing edge effect and subsequently provide 13

a potential high quality forage source in proximity to adjacent cover. The Project Area 14

contains a total of approximately 1,099 km2 high quality moose habitat based on the 15

results of habitat modeling (see Appendix B Mammals Technical Report for modeling 16

details), of which approximately 22 km2 (<5 %) will be affected/removed by the Project 17

and its ROW (Mammals Technical Report, p. 105). Based on this relatively small 18

removal of habitat, spanning over 254 kilometres within moose range, the impact on 19

thermal cover availability in any one moose home range is considered negligible. 20

Cumulative effects of Bipole III on thermal cover in consideration of forestry are 21

negligible. In the context of forestry, Manitoba’s Forest Management Guidelines for 22

Riparian Management Areas and for Terrestrial Buffers provides guidelines for habitat 23

18/07/12 93


CEC/MH-III-049

retention in Riparian Management Areas with specific requirements for moose as 24

riparian areas are important micro-habitats for cooling. The Forest Management 25

Guidelines for Wildlife in Manitoba also define a minimum distance of 200 meters to 26

thermal cover with a minimum of 20% cover being retained in operating areas. If less 27

than 50% cover is maintained, an adjacent leave area of equivalent size is required and 28

the operating area is not to exceed 5 km2 (Manitoba Conservation 1989), ensuring 29

adequate thermal cover retention. 30

Other Rationale: 31

The Lenarz et al. (2009) article examines the potential effects of warming climate on a 32

species at the southern edge of its distribution, affecting mortality and reproductive 33

rates that ultimately result in a shift in distribution (Humphries et al. 2004). Moose in 34

Minnesota have experienced decline in recent years due to cumulative processes that 35

include heat stress (Lenarz et al. 2009). This author identified thresholds of heat 36

tolerance based on metabolic research conducted by Renecker and Hudson (1986) as 37

indicated above. Moose within the Bipole III study area are not at their southern edge 38

of distribution, and mean annual temperatures during the annual life cycle are not 39

comparable to the area studied in Minnesota. Based on the temperature thresholds 40

described, moose require a source of water and cool dense conifer lowlands that provide 41

microhabitats for cooling and energy conservation (Thompson and Stewart, 1997, 42

Dussault et al. 2004). Protection of riparian habitats along the FPR was considered in 43

developing the Bipole III ROW where buffers will be applied to maintain forested stands 44

adjacent to waterways (see response to CEC-MH-III-044). 45

Hundertmark (1998) summarized that the size of a moose’s home range varies from 3.1-46

3.6 km2 in northwestern Minnesota and 14 km2 in northwestern Ontario, although a 47

range of 4 to greater than 250 km2 have been documented elsewhere. The exact size of 48

a moose home range varies with sex, age, season, habitat quality and weather. The 49

area of the ROW traversing through any moose home range will be a small percentage 50

of the overall area utilized. 51

18/07/12 94


CEC/MH-III-049

Moose also require a combination of habitat components throughout the year (Peek, 52

1997). In summer, moose require areas of high quality terrestrial forage, usually a 53

young forest stand (Saether and Anderson, 1990), aquatic feeding areas, mineral licks 54

(Peek, 1997; KBM, 2006), During early winter moose require high quality forage in 55

proximity to dense coniferous or mixed wood forest that provides “edge” between these 56

ecotones (KBM, 2006). Increased edge density provides food in proximity to cover, 57

increasing the habitat quality for moose (KBM, 2006). During late winter, when warming 58

trends occur, moose seek dense conifer stands to minimize energy due to snow crusting 59

and for thermal regulation to reduce heat stress (Thompson and Stewart, 1997; Welsh 60

et al. 1980). However it is noted that conifer stands are used in all seasons as they 61

provide natural cover (Peek, 1997). The spatial arrangement of food and cover (thermal 62

and protection from predators) is a key component of high quality moose habitat (KBM, 63

2006; Thompson and Stewart, 1997). 64

A total of approximately 22 km2 (Mammals Technical Report, p. 105) of high quality 65

moose habitat will be removed by the project, part of this will be thermal cover; 66

however this represents a small proportion of the total available high quality habitat 67

(<2%) and thermal cover for moose. The ROW will provide high-quality forage for 68

moose, in close proximity to thermal cover, located on the edge of the ROW. Individuals 69

feeding on abundant, high-quality forage may have a higher tolerance towards thermal 70

stress compared to individuals feeding on low-quality food (Jensen et al., 1999). Also; 71

B.C Ministry of the Environment (2006) recommends that thermal cover be present 72

within 200m of forage, making the Bipole III ROW of 66m well within the recommended 73

distance. 74

References: 75

B.C. Ministry of Environment. (2006). Identification and Management of Moose Winter 76

Habitat in the Cariboo Region: Literature Review and Mapping Pilot Study. Keystone 77

Wildlife Research Ltd. White Rock, BC. 78

18/07/12 95


CEC/MH-III-049

Dussault, C., J-P. Ouellet, R. Courtois, J. Hout, L. Breton and J. Larochelle. (2004). 79

Behavioural response of moose to thermal conditions in the boreal forest. Ecoscience. 80

11(3): 321-328 81

Hundertmark, K. J. (1998). Home range, dispersal and migration. In Franzmann, A. W. 82

and C. C. Schwartz, editors. (Eds.). Ecology and management of the North American 83

moose. Smithsonian Institution Press. Washington, D.C., USA. pp. 305–335. 84

Humphries, M. M. (2004). Bioenergetic prediction of climate change impacts on 85

northern mammals. Integrative and Comparative Biology, 44(2), 152-162. 86

Jensen, P.G., P.J, Pekins and J.B. Holter. (1999). Compensatory effect of the heat 87

increment of feeding on thermoregulation costs of white-tailed deer fawns in winter. 88

Canadian Journal of Zoology. 77:1474-1485 89

KBM Forestry Consultants Inc. (2006). A pilot moose habitat model for the mid-boreal 90

uplands ecoregion of the Manitoba Model Forest. Manitoba Forest Network. 91

Lenarz, M.S., M.E. Nelson, M.W. Schrage and A.J. Edwards. (2009). Temperature 92

Mediated Moose Survival in Northeastern Minnesota. The Journal of Wildlife 93

Management . 73(4): 503-510 94

Lenarz, M.S., J. Fieberg, M.W. Schrage, and A.J. Edwards. (2010). Living on the Edge: 95

Viability of Moose in Northeastern Minnesota. Journal of Wildlife Management. 74 (5): 96

1013-1023 97

Manitoba Conservation (1989). The Forest Management Guidelines for Wildlife in 98

Manitoba. Government of Manitoba. pp 1-14. 99

Manitoba Conservation. (2010). Manitoba’s Forest Management Guidelines for Riparian 100

Management Areas and for Terrestrial Buffers [online]. 101

http://www.gov.mb.ca/conservation/wildlife/mbsp/fs/moose.html. Accessed July 3, 102

2012. 103

18/07/12 96

http://www.gov.mb.ca/conservation/wildlife/mbsp/fs/moose.html


CEC/MH-III-049

Peek, J. (1997). Management of Moose Habitat. In A.W. Franzmann, and C.C. Schwartz 104

(Eds.), Ecology and management of the North American moose. Pp.351-375. Wildlife 105

Management Institute, Washington, D.C. 106

Renecker, L. A., & Hudson, R. J. (1986). Seasonal energy expenditures and 107

thermoregulatory responses of moose. Canadian Journal of Zoology, 64(2), 322-327. 108

Saether, B-E. and R. Anderson. (1990). Resource limitation in a generalist herbivore, 109

the moose, (Alces alces): Ecological constraints on behavioural decisions. Can. J. 110

Zoology. 68: 933-999. 111

Thompson, I.D and R.W. Stewart. (1997). Management of Moose Habitat. In A.W. 112

Franzmann, and C.C. Schwartz (Eds.), Ecology and management of the North American 113

moose. Pp. 377-401. Wildlife Management Institute, Washington, D.C. 114

Welsh, D.A., K.P. Morrison, K. Oswald and E.R. Thomas. (1980). Winter habitat 115

utilization by moose in relation to forest harvesting. Proc. N. Am. Moose Conf. 116

Workshop. 16: 398-428. 117

18/07/12 97


CEC/MH-III-050

Date June 7th 2012

Reference 6.2.6.5



1

Question: 2

“Moose populations in the western portion of the Project Study Area are in decline and 3

there are a number of conservation hunting closures that have been implemented to 4

rehabilitate moose numbers. Game hunting areas (GHAs) which have been closed to 5

allow for moose populations to recover from decline include GHAs 13, 13a, 14, 14A, 26, 6

18, 18A, 18B and 18C.” (6.2.6.5). 7

The statement does not properly indicate the extent to which some populations have 8

declined in the vicinity of the proposed transmission line. In particular, it appears that 9

the decline in GHAs 14 and 14A, through which the line would pass, has been such that 10

the population can be viewed to have been almost extirpated over the last 20 years, and 11

the population must be viewed to be in peril. To characterize the decrease in numbers 12

within these two GHAs as a “decline” is not accurate. Please provide specific detail in 13

the EIS on a GHA basis, and provide support that the population status is accurate. 14

Response: 15

A review of the updated Manitoba Conservation (2012) website indicates that the moose 16

populations in GHAs 13, 13A, 14, 14A, 26, 18, 18A, 18B and 18C are in decline, as 17

indicated in the Bipole III EIS, and therefore, the information is correct. Manitoba 18

Conservation states the following: 19

“GHAS 13, 13A, 14, 14A, 18, 18A, 18B, 18C AND GHA 26 - ALL MOOSE SEASONS 20

REMAIN CLOSED. Aerial surveys have determined that moose populations in GHAs 14 21

and 14A; GHAs 18, 18A, 18B, 18C (Duck Mountain); and GHA 26 have significantly 22

18/07/12 98


CEC/MH-III-050

declined, as well the cow/calf and bull/cow ratios are a concern in GHAs 13 and 13A 23

(Porcupine Mountain). As a conservation measure, the cancellation of all licensed moose 24

hunting seasons in these areas remain in effect. These management actions are 25

necessary to assist with the recovery of these populations. The success of the recovery 26

is dependent on co-operative efforts of all Manitobans (Manitoba Conservation, Wildlife 27

and Ecosystem Protection Branch, 2012)” 28

Manitoba Hydro is meeting with Manitoba Conservation to discuss moose concerns in 29

GHA's 14 and 14A. Mitigation topics such as routing, access management planning and 30

hunting closures will be considered further for the Bipole III Transmission Project. 31

Reference: 32

Manitoba Conservation, Wildlife and Ecosystem Protection Branch. 2012. 2012 Manitoba 33

Hunting Guide [online]. Available from 34

http://www.gov.mb.ca/conservation/wildlife/hunting/pdfs/hunting%20guide_2012_web.35

pdf [accessed 20 June 2012]. 36

18/07/12 99

http://www.gov.mb.ca/conservation/wildlife/hunting/pdfs/hunting%20guide_2012_web.pdf

http://www.gov.mb.ca/conservation/wildlife/hunting/pdfs/hunting%20guide_2012_web.pdf


CEC/MH-III-053e

Date June 7th 2012



Question CEC-MH-III-053e

1

Question: 2

The EIS lists potential impacts from construction of the converter stations: 3

e. EMF risks – cancer, communication trouble 4

Please clearly quantify and specify the potential impacts for each station in planning, 5

construction, and operation stages. 6

Response: 7

Electric and magnetic fields will be associated with the operation of the Bipole III 8

Transmission Project, not during the planning or construction stages. 9

Converter stations will be connected to each end of the Bipole III line to convert AC to 10

DC power at the northern converter and convert DC to AC power at the southern 11

converter. In addition there will be associated equipment and facilities to connect to AC 12

transmission lines and switching facilities. 13

The electric and magnetic fields associated with equipment in the converter station 14

would not be expected to significantly elevate field levels outside the boundaries of the 15

large proposed sites except where power lines, e.g., Bipole III, or connections to the AC 16

grid traverse the boundary. 17

Regarding EMFs and health, Chapter 8: Effects Assessment And Mitigation of the EIS at 18

p. 8-317 addressed questions about health and cancer: 19

“National and international scientific agencies responsible for public health have 20

convened multidisciplinary groups of scientists to evaluate the research and to 21

18/07/12 100


CEC/MH-III-053e

determine if health effects are associated with exposure to EMFs. Such groups include 22

the World Health Organization (WHO) in 2006, the National Radiological Protection 23

Board of Great Britain (NRPB) in 2004 and the International Agency for Research on 24

Cancer (IARC) in 2002. These organizations have concluded that there are no known 25

adverse health effects associated with ac EMFs or with low levels of static EMFs such as 26

those associated with dc transmission lines. 27

28

In Canada, the Federal Provincial Territorial Radiation Protection Committee (FPTRPC) 29

has established a Working Group to carry out periodic reviews, recommend appropriate 30

actions and provide position statements that reflect the common opinion of 31

intergovernmental authorities on EMFs. The FPTRPC concluded that “there is insufficient 32

scientific evidence showing exposure to EMFs from power lines can cause adverse health 33

effects such as cancer” (http://www.hc-sc.gc.ca/ewh-semt/radiation/fptradprotect/emf-34

cem-eng.php). In addition, the Manitoba Clean Environment Commission developed a 35

Health and EMF Expert’s Consensus Statement on the Human Health Effects of ELF EMF 36

in 2001 which concluded that “The weight of scientific evidence does not support the 37

conclusion that extremely low frequency EMFs such as those produced by power lines 38

are a cause of adverse effects on human health.” 39

Assuming standard design practices will be used to minimize radio frequency (RF) 40

interference from the converter station and electrode line, harmonics and RF are not 41

likely to be a problem, and if interference to communications is detected, it will be 42

mitigated. 43

18/07/12 101


CEC/MH-III-058

Date June 7th 2012

Reference EMF Technical Report



1

Question: 2

Please consider the effects of electromagnetic fields (EMFs) on drivers of vehicles on 3

major highways that pass beneath the Bipole III transmission line. The EMF Technical 4

Report appears to contain no information on the effects of EMFs on moving vehicles 5

passing beneath the proposed transmission line. Please provide the most up-to-date 6

findings on whether vehicles passing beneath Bipole III have any effect at all and 7

provide the threshold values of the electric fields 8

Response: 9

Neither the static electric or the static magnetic fields from the Bipole III line will 10

effectively couple with objects under or near the line whether the objects are moving or 11

stationary. Furthermore, the field levels from the line are too low to affect the health or 12

safety of persons. As described in the Electromagnetic Fields (EMF) Technical report, 13

“the electrical environment is expected to conform to exposure limits recommended by 14

provincial, national, and international agencies.” Further, the exposure of persons in a 15

vehicle to the static electric field from the natural environment or from the Bipole III line 16

will be reduced because of the shielding effect of the metal body of the vehicle. 17

Also see response to CEC-MH-III-059. 18

18/07/12 102


CEC/MH-III-059

Date June 7th 2012

Reference Section 8.3.5.3. Chapter 8 page 8-317



1

Question: 2

The implication is that the mathematical modeling and the instruments sensing the fields 3

assumed that the recipient was stationary (static). In reality, cars and trucks consist of 4

large masses of metal moving at speed through the electromagnetic fields produced by 5

the transmission line. This can produce induced currents (Section 8.3.5.3 in Chapter 8, 6

page 8-317). Such conditions are dynamic, not static. Knowledge of electric motors 7

and generators confirms that static and dynamic conditions are different. The EMF 8

Report has not shown that electromagnetic fields beneath transmission lines will have 9

no adverse effect on the abilities of drivers to control their vehicles. Please calculate the 10

potential induced currents mentioned above 11

Response: 12

Chapter 8 of the EIS references the guidelines developed by the International 13

Commission on Non-Ionizing Radiation Protection (ICNIRP) to address exposures of the 14

general public and workers to static magnetic fields (ICNIRP, 2009) and to time-varying 15

magnetic fields (ICNIRP, 2010). In the development of these guidelines, consideration 16

was given to the induction of an electric field in the body by a strong static magnetic 17

field such as that produced by the movement of patients into and out of a magnetic 18

resonance imaging (MRI) machine, e.g., ICNIRP (2009). While such induced electric 19

fields can be relatively large in the strong magnetic field of an MRI machine, they are 20

infinitesimally small in the weak static magnetic field of the earth or as may be modified 21

by the Bipole III line, even when moving at high speed. For example, the maximum 22

electric field (99th percentile) induced in the brain of a modeled male body moving at a 23

18/07/12 103


CEC/MH-III-059

rate of 1 m/s in a 1.7 Tesla magnetic field around an MRI machine is calculated as 24

0.4313 V/m (Chadwick, 2007)1. The induced electric field in a female model is similar or 25

smaller. To obtain an order of magnitude estimate of the induced electric field 26

requested, assume that this male model is traveling 100 km/h in a 1000 mG (0.0001 T) 27

static magnetic field (the maximum magnetic field from Bipole III under normal 28

operation is 280.2 mG + 580 mG field of the earth in Manitoba), the electric field 29

induced in the brain would be approximately 0. 0.4313 V/m per m/s x 27.78 m/s x 30

0.0001 T / 1.7 T = 0.00070 V/m. As the change in the spatial gradient of the magnetic 31

field around the MRI is likely greater than under the Bipole III line, and the metal body 32

of the car would provide some minimal shielding, this calculated value provides a 33

conservative estimate of the induced electric field in the brain. This value is about 14- 34

to 140-fold lower than the not-to-exceed Basic Restriction specified by ICNIRP (2010) 35

for the electric field induced in the CNS tissue of the head of the general public in the 36

relevant frequency range, 1-10 Hz. Thus, driving a vehicle in the earth’s magnetic field 37

in Manitoba or as may be slightly enhanced under the Bipole III line, will not induce 38

electric fields within the brain that would come close to exceeding the ICNIRP standard 39

and thereby adversely affect cognitive performance of the driver. 40

1 Chadwick. P. Assessment of electromagnetic fields around magnetic resonance imaging (MRI) equipment. Report RR570. Norwich, UK: Health and Safety Executive, 2007.

18/07/12 104


CEC/MH-III-061

Date June 7th 2012

Reference Pages 32 & 39 of the EMF Technical Report



1

Question: 2

There are three issues involved in the question of possible interference of EMFs with 3

GPS signals – health, efficiency, and safety. The Technical Report on Electromagnetic 4

Fields by Exponent Inc., consultants to Manitoba Hydro, examines evidence regarding 5

the impact of EMFs on GPS and on the health of operators. The report concludes that 6

health effects will be minimal – magnetic fields from the Bipole III line will be much 7

lower than needed for health concerns. Electric fields are closer to guideline thresholds 8

established by public health agencies. The conditions under which the background 9

research programs were carried out were not explained in the report, but they seem to 10

have involved measuring field strengths when the receiver was stationary, that is, under 11

static conditions. The Report speaks of „… large vehicles parked under transmission 12

lines‟ (page 32). Most of the research addresses magnetic fields, not electric fields. 13

The Report notes (page 39) that GPS signals operate at much higher frequency than the 14

Radio Noise (RN) that is expected to be generated by the Bipole III line and that it is 15

unlikely that the GPS signal will be interrupted. It also speaks about a possible 16

momentary loss of Nationwide Differential GPS signals which „should not‟ affect the 17

accuracy of overall performance. (NDGPS has recently been replaced in Canada by 18

satellite-based systems which are either not susceptible at all or minimally susceptible to 19

RN interference.) However, if interference is encountered, and the Report indicates this 20

may be possible, then control of ground equipment may be lost. The result can be 21

collision of ground machinery with towers, damage to towers and ground equipment 22

and possible injury to the operator. Loss of GPS information is obviously more critical 23

for aerial applicators. The issues relate to efficient operation, possible collisions with 24

18/07/12 105


CEC/MH-III-061

towers or conductors, and injury to the operator. Please provide an update to clearly 25

elaborate on the potential effects on GPS guided machinery 26

Response: 27

Regarding the comment in lines 6-9, no health effects of exposure to magnetic fields are 28

expected based upon the assessment contained in the cited Technical Report. 29

Regarding the comments in lines 9-13, the report does focus on static conditions, but 30

“dynamic” conditions involving movement in a static magnetic field are considered by 31

the ICNIRP guidelines that were used as assessment criteria. This issue is discussed 32

further in the response to CEC-MH-III-059. 33

As noted in Exponent‟s “Electromagnetic Fields Technical Report”, the NDGPS is no 34

longer used in Canada. Other GPS correction systems are less susceptible to 35

interference as noted because they operate at frequencies higher than the noise 36

spectrum of a DC transmission line. This Technical Report also states: 37

Two surveys by independent surveyors were performed using various types of 38

GPS technologies directly beneath the two existing Bipole I and II DC 39

transmission lines located in Manitoba‟s Interlake region (Pollock & Wright, 2010; 40

Plan Group, 2011). The tests showed no interference whatsoever with any type 41

of GPS or Global Navigation Satellite System (GNSS) technology tested, including 42

RTK and other correction systems. The GPS receivers tested continued to 43

operate without interruption at cm accuracies regardless of the presence of the 44

DC transmission lines (pdf p. 57). 45

The study mentioned above conducted by the Position, Location And Navigation (PLAN) 46

Group in the Schulich School of Engineering, University of Calgary has been published in 47

a peer-reviewed journal (Bancroft JB, Morrison A, Lachapelle G. Validation of GNSS under 48

500,000 V Direct Current (DC) transmission lines. Computers and Electronics in 49

Agriculture. 83:58–67, 2012). 50

The information provided in the EIS does not support the implication in lines 14-26 that 51

Bipole III will result in significant interference to GPS on farm machinery or airplanes. 52

18/07/12 106


CEC/MH-III-064

Date June 7th 2012

Reference Table 27 of the Agriculture Technical Report



1

Question: 2

Had the Agriculture Technical Report been available earlier than November 2011, there 3

would have been time to consider why the most common mitigation measure proposed 4

for the various concerns raised is compensation (Table 27 of the Report). This was a 5

common choice because no measure is fully effective in militating against the impacts on 6

agriculture. Better timing on the commissioning of the Report or, alternately, drawing 7

on the significant expertise that exists within Manitoba Hydro could have caused a 8

reconsideration of the routing choice through prime agricultural lands in southern 9

Manitoba. An underground line from about Amaranth using a shorter route running 10

north of Portage la Prairie and north of Winnipeg, although perhaps initially more 11

expensive, might have been a more prudent choice. Please comment on the use of 12

underground cable in the agricultural area mentioned above. 13

Response: 14

Manitoba Hydro keeps up to date with current technology and explores all feasible 15

options as part of its mandate to reliably supply power at the lowest feasible cost. 16

Underground cable options bring special challenges when compared to overhead 17

transmission lines and thus worldwide have typically only been employed when 18

overhead transmission solutions do not exist. 19

Very high per kilometer underground cable costs as compared to transmission, 20

reliability, technical, logistical and implementation difficulties have to date made the 21

underground cable option not viable for portions or for the entire Bipole III line. 22

However, the conceptual costs of three underground (U/G) transmission routes in the 23

18/07/12 107


CEC/MH-III-064

southern portion of Bipole III were evaluated by Manitoba Hydro. The preliminary 24

assessment indicates that the section of U/G transmission for Bipole III will be about 3 25

to 6 times the cost of the corresponding overhead line section. 26

Reliability is also a concern for the underground cable technology at 500kV. As indicated 27

in the EIS Chapter 2, the life expectancy of underground cables is about half of that of 28

overhead lines and the failure rates are high (failure every 3 to 17 years). 29

Implementation of long distance underground cable as required for Bipole III would 30

require a large number of splices (cable connections) due to the limited length of cable 31

that can be shipped as one piece. Suppliers have stated that distances in the order of 32

100 km for underground land cable would not likely be practical. 33

18/07/12 108


CEC/MH-III-071

Date June 7th 2012

Reference CEC Information Request # 3



1

Question: 2

Please provide information about MH and/or Manitoba restrictions, if any, concerning 3

Access Management Plans and/or traditional use restrictions employed in the vicinity of 4

existing repeater stations. If there are restrictions, please provide details concerning the 5

geographic extent and nature of the restrictions. 6

Response: 7

Manitoba Hydro repeater station sites typically are comprised of a cleared area of land, 8

shelter (i.e., building) to house the equipment, may or may not include a radio tower 9

and are fenced around the equipment shelter to ensure the security of the equipment as 10

well as minimize the ability for wildlife to enter into the sites. In some cases depending 11

on location, there could be a gate into the site, which would restrict vehicle approach 12

along the road to the area where the equipment is housed. There are no other access 13

restrictions associated with repeater stations. 14

18/07/12 109


CEC/MH-III-072

Date June 7th 2012




1

Question: 2

Please explain if MH and/or Manitoba anticipate employing similar management 3

measures for the two new repeater stations. 4

Response: 5

It is assumed that this question is in reference to access management measures. It is 6

anticipated that there will be no changes to access management associated with 7

repeater stations. Please see the response provided for CEC-MH-III-071. 8

18/07/12 110


CEC/MH-III-073

Date June 7th 2012




1

Question: 2

Please explain if MH intends to consult with Manitoba Metis and the MMF regarding 3

access management plans during the construction phase and with respect to any 4

restrictions during the operational phase. 5

Response: 6

Manitoba Hydro would like to meet with the MMF to review the Bipole III Environmental 7

Protection Plan, which would include the transmission line access management plan. 8

18/07/12 111


CEC/MH-III-082

Date June 7th 2012




1

Question: 2

Please provide information on any MH and/or Manitoba restrictions, if any, concerning 3

hunting implemented in the vicinity of other project construction phase camps. If there 4

were restrictions, please provide details concerning the geographic extent and nature of 5

the restrictions. 6

Response: 7

Please refer to response provided for CEC/MH-II-003d 8

Hunting and fishing are regulated by Manitoba Conservation and Water Stewardship and 9

as such the monitoring of the impacts from those activities fall under their jurisdiction. 10

Manitoba Hydro (MH) will restrict firearms in project locations in order to ensure project 11

personnel safety. MH’s Safe Work Procedures will apply to the Bipole Project and any 12

firearms that may be allowed into the project locations will need to be duly authorized 13

as per those procedures. Given the safety concerns with firearms in camps or on active 14

construction sites, firearms and the ability to engage in hunting activities while on site 15

will be restricted. Any hunting that project personnel wish to engage in will not be 16

allowed within the vicinity of those construction camps or sites and as with Wuskwatim a 17

buffer around those locations will be implemented. 18

18/07/12 112


CEC/MH-III-089

Date June 7th 2012




1

Question: 2

To what extent is MH willing to work with MMF and Manitoba Metis harvesters to identify 3

ROW vegetation maintenance measures in important gathering areas that do not involve 4

chemical management? 5

Response: 6

Manitoba Hydro would like to meet with the Manitoba Metis Federation and/or Metis 7

harvesters to review the draft Bipole III Environmental Protection Plan. This could 8

include discussions regarding vegetation management. 9

18/07/12 113


CEC/MH-III-092

Date June 7th 2012




1

Question: 2

Please provide an explanation as to why the transportation component of the Victory 3

Nickel Mine project, which overlaps the Project Study Area, was not included as a future 4

project in the cumulative effects assessment; 5

Response: 6

Please see response to MCWS/MH-TAC-011b. 7

The Bipole III EIS cumulative effect assessment focused on future projects within the 8

Project Study Area with environmental effects that could potentially overlap with effects 9

of the Project. In addition, the corridor for the Bipole III Project is extensive and it was 10

recognized that every local future project or activity along the HVdc route cannot be 11

considered, for practical reasons, as part of the cumulative effects assessment. 12

As noted on page 20 of the review comments provided by MMF, the Victory Nickel Mine 13

occurs outside the Project Study Area, approximately 55 km from the centre of the 14

Project’s HVdc centre line. The MMF review comments also note that this mine, once 15

operational, proposes to transport materials and ore along PTH 6 north to the rail line at 16

Ponton, and that a segment of the PTH 6 transportation route falls within the Project 17

Study Area and intersects the HVdc ROW. Aside from the cumulative effects of added 18

truck traffic on this specific segment of PTH 6, no potential overlap of Bipole III and 19

Victory Nickel Mine environmental effects is suggested for consideration in the MMF 20

review. 21

18/07/12 114


CEC/MH-III-092

In relation to increased traffic volumes, PTH 6 was assessed in the EIS and it was 22

determined that the increase in project-related construction traffic in the vicinity of the 23

Victory Nickel Mine and the rail line at Ponton was either below five percent of existing 24

traffic and / or within the existing design capacity of the roadway (as defined by 25

Manitoba Infrastructure and Transportation. For more detailed explanation please refer 26

to section 7.2.3 of the Transportation Technical Report). 27

As reviewed in the Bipole III EIS with regard to transportation activity effects, the 28

residual adverse effects of transportation related activities for the Project HVdc line and 29

Keewatinoow are expected to be limited, in practical terms, to the construction phase. 30

Further, potential transportation activity effects of the Project are expected to be short 31

term and reversible in nature (see, Chapter 8 page 8-297 and page 8-303 of the EIS). 32

Roads likely to notice an increase in traffic will be those used to transport materials for 33

all major construction components of the Project. This would include roads between the 34

Riel site, the northern transmission line segments and Keewatinoow (PTH 6, PTH 10, PR 35

391, PR 280 and PR 290). 36

Given the residual adverse effects of the Project’s construction-related transportation 37

activities are considered to be short term and reversible, material overlaps of the 38

Project’s effects with traffic related effects from other projects occurring outside the 39

Project Study Area are not anticipated, and any such overlaps that may occur from time 40

to time are not expected to result in significant adverse effects and/or additional 41

mitigation requirements for the Project. 42

18/07/12 115


CEC/MH-III-093

Date June 7th 2012




1

Question: 2

Please re-consider the findings of residual impact on moose populations and “Domestic 3

Resource Use” in light of the evidence of GHA closures and the high potential for 4

concentration of harvesters in the remaining GHAs that are transected by the HVdc. 5

Response: 6

Question MCWS/MH-TAC-011a is similar in nature and the response is provided below. 7

“The closure of GHAs 13, 13A, 14, 14A, 18, 18A, 18B and 18C and the partial closure of 8

GHAs 2A, 4 and 7A to moose hunting and effects of these closures on moose 9

populations and harvesting opportunities in adjacent and/or further removed GHAs was 10

not considered in the effects assessment conducted by Manitoba Hydro. And in 11

considering them now the conclusions reached in the EIS respecting residual effects and 12

cumulative effects would not change as a result of these closures. 13

Numerous access routes/travel corridors already exist in much of western Manitoba. As 14

a result the Bipole III transmission line, though creating potentially one more access 15

route through the closed and remaining open GHAs (potentially is used here as 16

transmission lines are often not easily traversable in some locations and in other 17

locations parallel existing linear corridors), is not expected to significantly increase the 18

ability of hunters to access new areas and/or new opportunities for wolf predation on 19

moose in this area of Manitoba. “ 20

As to the concern regarding the effect of concentrating hunters in the remaining open 21

GHAs, presumably this would occur irrespective of the Bipole III project and was 22

18/07/12 116


CEC/MH-III-093

considered by Manitoba when implementing the closures and since the closures are 23

already in effect it is being managed by the responsible management authority, that 24

being Manitoba Conservation and Water Stewardship.” 25

18/07/12 117


CEC/MH-III-094

Date June 7th 2012




1

Question: 2

What were the criteria used to determine the groups that are proposed to be eligible 3

under the Community Development Initiative? 4

Response: 5

Please see response provided for CEC/MH-III-096 6

18/07/12 118


CEC/MH-III-095

Date June 7th 2012




1

Question: 2

Why are the MMF and the Metis communities it represents, excluded from MH’s 3

proposed Community Development Initiative? 4

Response: 5

Metis people living in eligible rural municipalities, Northern Affairs communities, villages, 6

towns or First Nations will benefit from the CDI funded community development projects 7

undertaken by those communities. As such, it is expected that individuals represented 8

by the Manitoba Metis Federation will benefit from the CDI. 9

The intent of the CDI is to fund worthwhile projects that will benefit a wide spectrum of 10

persons who live within a modest distance of Bipole III facilities and the mechanism 11

proposed to do that is to provide the funding to the rural municipality, Northern Affairs 12

Community, village, town or First Nation in which they live. 13

18/07/12 119


CEC/MH-III-096

Date June 7th 2012




1

Question: 2

Please explain the basis or rationale for why First Nations who are similarly situated as 3

Metis communities are not included in the proposed Community Development 4

Initiative? 5

Response: 6

This question appears to suggest that First Nations are not eligible for the Community 7

Development Initiative (CDI). First Nations located within 25 km of the Bipole III 8

facilities, or whose associated Resource Management Area is traversed by Bipole III 9

facilities, are eligible for the CDI. 10

The intent of the CDI is to fund worthwhile projects that will benefit a wide spectrum of 11

persons who live within a modest distance of Bipole III facilities and the mechanism 12

proposed to do that is to provide the funding to the rural municipality, Northern Affairs 13

Community, village, town or First Nation in which they live. 14

18/07/12 120


CEC/MH-III-099

Date June 7th 2012




1

Question: 2

Please provide a map showing known archaeological sites with actual or potential 3

evidence for Metis artifacts and cultural heritage. 4

Response: 5

Actual or potential evidence for Metis artifacts and cultural heritage was not found in the 6

archaeological investigations since the majority of environmentally sensitive sites that 7

were of a heritage nature were not able to be visited as access to private lands was not 8

granted. For the HRIA known archaeological and heritage sites, potential archaeological 9

and heritage sites (based on predictive modeling) and ATK provided the foundation for 10

the limited field investigations. The presence/absence of an archaeological site is the 11

first stage in determining the effects of a project on heritage sites. All heritage sites are 12

protected under Manitoba’s Heritage Resources Act (1986) (The Act) regardless of 13

cultural affiliation. 14

A Heritage Resources Protection Plan (HRPP) will be developed; this is a proactive 15

process that sets out standards and guidelines for the construction phase and is based 16

on The Act (1986) and Policy for the Reporting, Exhumation and Reburial of Found 17

Human Remains (1987). 18

18/07/12 121


CEC/MH-III-101

Date June 7th 2012




1

Question: 2

Please describe the process whereby the MMF will be consulted on unknown Metis 3

heritage resources that may be discovered during the course of the project, including 4

Metis burial sites 5

Response: 6

The Bipole III Heritage Resources Protection Plan (HRPP) will establish a protocol for 7

contacting and working with the MMF regarding any unknown Metis heritage resources 8

that may be discovered during the course of the project, including Metis burial sites. 9

Manitoba’s Heritage Resources Act (1986) and the Policy Concerning the Reporting, 10

Exhumation and Reburial of Found Human Remains (1987) determine the process of 11

investigation for burials. Should human remains be identified during construction of the 12

Bipole III transmission line the following essential best practice occurs: 13

1. Unless unavoidable and necessary human remains are not to be removed from 14

their original resting place; 15

2. When human remains are discovered a) all work ceases and the Historic 16

Resources Branch of Manitoba Culture, Heritage and Tourism is notified 17

immediately; b) no further disturbance of the remains occurs until the arrival of 18

personnel designated by the Historic Resources Branch; 19

3. Community consultation takes place before exhumation or removal of human 20

remains or associated grave goods; 21

4. Personnel designated by the Historic Resources Branch shall carry out the 22

exhumation, and as much as possible, out of the public eye; 23

18/07/12 122


CEC/MH-III-101

5. Identification procedures will be undertaken only by personnel designated by the 24

Historic Resources Branch; 25

6. Reburial of human remains when a First Nation is involved is arranged by the 26

Aboriginal Liaison Officer of the historic Resources Branch in conjunction with the 27

community. Reburial in all other cases will be handled only by personnel 28

designated by the Historic Resources Branch. (n.d. Manitoba Pamphlet, copy 29

attached). 30

18/07/12 123

18/07/12 124

18/07/12 125


CEC/MH-III-102

Date June 7th 2012

Reference Chapter 4: Environmental Assessment Approach - Reference: p. 4-6



1

Question: 2

“Appropriate limits on the data collection ...” Who determines/how? 3

Response: 4

The phrase referred to in the question occurs in the Section 4.2.3.1 Project Study Area 5

under Section 4.2.3. Study Area Delineation and Characterizations. The sentence refers 6

to limits to data collection for the whole Project study area which covers a large portion 7

of western and northern Manitoba. Individual specialists in conjunction with Manitoba 8

Hydro determined the scope of work and the amount of data, which must be collected 9

for the assessment of each Valued Environmental Components (VEC) and for each 10

component. 11

The limits on data collection are in reference to a specific early phase in the 12

environmental impact assessment process as described in Chapter 4 of the EIS. The site 13

selection and environmental assessment (SSEA) process involves a phased approach 14

that uses increasing levels of study area refinement, and intensity of data collection and 15

analysis. 16

18/07/12 126


CEC/MH-III-105

Date June 7th 2012

Reference Caribou IR. Section 6.2.6.2 Ungulates, pg. 6-75 White-tailed deer.



1

Question: 2

Further to white-tailed deer issues described in the Caribou IR. Section 6.2.6.2 3

Ungulates, pg. 6-75 White-tailed deer. “The northward expansion of the white-tailed 4

deer range has been well documented; ...” Please provide this documentation as it 5

pertains to the current distribution of white-tailed deer in Manitoba. 6

Response: 7

White-tailed deer extended their range into Manitoba in the late nineteenth century 8

northward from Minnesota. White-tailed deer continued to expand northward, 9

extending their range from Minnesota into Manitoba, following the pattern of human 10

settlement, and taking advantage of land-use practices such as pioneer agriculture and 11

logging (Goulden, 1981). The earliest accounts of white-tailed deer in Manitoba 12

occurred in 1881; however, it was not until 1900 that white-tailed deer were regularly 13

seen in southern Manitoba. The first set of antlers were found in Carberry, Manitoba in 14

1907 and white-tailed deer were first recorded near Souris in 1911 (Goulden, 1981). 15

Since then, the limit of primary white-tailed deer range extended to areas north of the 16

Winnipeg River, through Manitoba’s Interlake Region to the north shore of Lake 17

Winnipegosis (Goulden 1981) (Figure 1). The northern expansion of white-tailed deer is 18

thought to be limited by a combination of the duration of severe cold winter 19

temperature, and snow depth which immobilize deer for extended periods of time 20

(Hesselton and Hesselton 1982). 21

White-tailed deer have existed in low densities throughout west-central Manitoba for 22

several decades with the primary northern limit of deer range as described by Golden 23

18/07/12 127


CEC/MH-III-105

(1981) being similar, with localized concentrations occasionally observed, typically in 24

association with extensive forest harvesting areas or the agricultural area surrounding 25

The Pas (Kent Whaley, Northwest Region Wildlife Manager, personal communication July 26

11, 2012). Deer density is much lower overall than the southern portion of the 27

Manitoba range and naturally fluctuates in response to severe winter conditions and 28

predation from wolves. No long term trend in respect to increasing/decreasing density 29

appears to be occurring in the region and Figure 1 is consistent with current deer 30

distribution (Kent Whaley, personal communication July 11, 2012). Figure 1 is also 31

consistent with current deer distribution in south-eastern Manitoba (Kelly Leavesley, 32

Eastern Region Wildlife Manager, personal communication July 13, 2012). 33

References: 34

Goulden, Herb, The White-Tailed Deer in Manitoba.Manitoba Natural Resources: 1981. 35

Hesselton, William, T., RuthAnn Monson Hesselton, “White-Tailed Deer.” In Wild 36

Mammals of North America: Biology, Management and Economics. Ed. Joseph A. 37

Chapman, George A. Feldhamer. Baltimore and London: The JohnsHopkinsUniversity 38

Press, 1982. 878-901. 39

18/07/12 128


CEC/MH-III-107

Date June 7th 2012

Reference Small Mammals - p. 6-75/76



1

Question: 2

There is a short list of small mammals presented and inconsistent treatment of their 3

presence and distribution in the Ecozone descriptions. They are included in the list in 4

some descriptions and not others. It would be helpful to have some indication on how 5

small mammal cycles influence the predator population in the long and short term. 6

These facts need to be taken into consideration in the effects assessment of certain 7

predator populations. Please provide. 8

Response: 9

Small mammals are discussed in more detail in Section 4.2 of the Bipole III Mammals 10

Technical Report. Small mammals serve as a main food source for furbearer species 11

and the importance of small mammals for Valued Environmental Components (VEC) 12

species including marten and wolverine and VEC linkage species grey wolf are discussed 13

in Sections 5.1 of the Bipole III Mammals Technical Report (Valued Environmental 14

Components, Environmental Effects and Mitigation). A full listing of mammal species 15

including small mammals is included in Appendix C: The role of hare cycles on lynx and 16

the potential effects of cyclic populations have been dealt with in the Response for 17

CEC/MH-II-010e. A discussion on predators and small mammals relative to the Bipole III 18

ROW is provided below. 19

Additional information: 20

Small mammal populations have been shown to inhabit and in some cases benefit from 21

the habitat created through ROW development. Given this, it is unlikely that predator 22

18/07/12 129


CEC/MH-III-107

populations which rely on small mammals will decline in the Project Study Area due to 23

lack of available prey. Over the long term, predator-prey populations are likely to 24

naturally cycle (Korpimaki and Krebs, 1996; Ryall and Fahrig, 2006), with predators 25

switching between available small mammal prey species as prey population cycling 26

occurs. Overall, these factors are not likely to be limiting for small mammal and 27

associated predator populations in the Project Study Area. 28

Beier and Loe (1992) describe small mammal species as “corridor dwellers”, indicating 29

corridors containing early successional habitat have most or all of the requirements for 30

small mammal life history. The early successional habitat created through the ROW has 31

been documented to be used as habitat by numerous small mammal species (Schreiber 32

and Graves, 1977; Lauzon et al. 2002; Clarke et al, 2006). Overall, narrow corridors 33

(ranging from 30 to 60 meters wide) have been found to not restrict small mammal 34

movements in eastern North American (Schreiber and Graves 1977; Gates 1991). 35

Clarke et al (2006) have found that small mammal populations recolonize 36

disturbed/cleared corridors approximately 1.5–3.5 years after disturbance (varying 37

based on species and disturbance type). It has also been supported in the literature that 38

species such as weasel (Mustela spp.) (Fisher and Wilkinson, 2005) and American 39

marten (Martes americana) (Gyug, 1994) will shift ranges for periods during 40

disturbance, moving back into their previous range post-disturbance. 41

The theory of predator-prey cycles (based off of Lotka-Volterra models) shows that prey 42

population regulation is driven through predation pressure (Korpimaki and Krebs, 1996). 43

The most classic example of a predator-prey cycle includes the snowshoe hare (Lepus 44

americanus) and lynx (Lynx lynx). MacLuich (1937) demonstrated that there is a 45

relationship between available hare forage and cyclic response of hare and lynx 46

populations. This example has been applied more broadly to demonstrate patterns seen 47

in other predator-prey relationships. Within the Bipole III Study area, predators that are 48

noted to predate upon small mammal populations include American marten, red fox 49

(Vulpes vulpes), arctic fox, (Alopex lagopus), coyote (Canis latrans), weasel, ermine 50

(Mustela erminea), mink (Mustela vison), fisher (Martes pennanti), striped skunk 51

(Mephitis mephitis) and opportunistically, lynx and wolverine (Gulo gulo) (Banfield, 52

18/07/12 130


CEC/MH-III-107

1974).These small mammal predators are broadly described as generalist predators, 53

indicating that they will utilize a range of prey sources and are not reliant on solely one 54

prey species. 55

Given that small mammal population are not likely to decline with the development of 56

the ROW (Schreiber and Graves 1977; Gates 1991), it is unlikely that these predator 57

populations will decline due to lack or available prey species in the area. Similarly, 58

generalist predators (as listed above) have been shown to exhibit prey switching 59

behaviour when prey populations cycle (Korpimaki and Krebs, 1996; Thompson and 60

Colgane, 1987), resulting in a predator’s non-permanent shift from one prey species to 61

the next. This results in allowing for smaller mammal populations to increase, once 62

again allowing for higher levels of predation to occur. These cycles and prey species 63

shifts are noted to occur over a long-term basis, with small mammal populations 64

fluctuating in 3 to 5 year cycles in mice and voles and 5 to 10 years in hare (Boonstra et 65

al, 1998). 66

References: 67

Banfield, A.F.W. 1987. The Mammals of Canada.University of Toronto Press. Toronto, 68

ON. pp.289-339 69

Beier, P. and S. Loe. 1992. A checklist for evaluating impacts to wildlife movement 70

corridors. Wildlife Society Bulletin 20:434-440. 71

Boonstra, R., Hik, D., Singleton, G. R. & Tinnikov, A. (1998). The impact of predator-72

induced stress on the snowshoe hare cycle. Ecol. Monogr. 68, 371–394. 73

Clarke, D. J., Pearce, K. A., & White, J. G. (2006). Powerline corridors: degraded 74

ecosystems or wildlife havens? Wildlife Research, 33(8), 615–626 75

Fisher, J.T., Wilkinson, L., 2005. The response of mammals to forest fire and timber 76

harvest in the North American boreal forest. Mammal. Rev. 35,51–81. 77

Gates, J. E. 1991.Powerline corridors, edge effects, and wildlife in forested landscapes of 78

the central Appalachians. Pp. 15-32, in Wildlife and habitats in managed 79

18/07/12 131


CEC/MH-III-107

landscapes (J. E. Rodick and E. G. Bolen, eds.). Island Press, Washington, D.C., 80

219 pp. 81

Gyug, L.W. (1994). Wildlife use of logging debris piles in clearcuts. Final Report.B.C. 82

Ministry of Environment. Penticton, B.C. 45 p. 83

Korpimaki, E., and C. J. Krebs. 1996. Predation and population cycles of small mammals. 84

A reassesment of the predation hypothesis. BioScience 46:754-764. 85

Lauzon RD, Grindal SD, Hornbeck GE (2002) Ground squirrel re-colonization of a pipeline 86

right-of-way in southern Alberta. In: Goodrich-Mahoney JW, Mutrie D, Guild C 87

(eds) Proceedings of the seventh international symposium on environmental 88

concerns in rights-of-way management, Calgary, pp 439–445 89

MacLulich DA (1937) Fluctuations in the numbers of the varying hare (Lepus 90

americanus). University of Toronto Studies Biological Series 43. University of 91

Toronto Press,Toronto 92

MacLulich DA (1937) Fluctuations in the numbers of the varying hare (Lepus 93

americanus). University of Toronto Studies Biological Series 43. University of 94

Toronto Press, Toronto 95

Ryall, K.,and Fahrig, L., 2006. Response of predators to loss and fragmentation of prey 96

habitat: a review of theory. Ecology 87 (5), 1086–1093. 97

Schreiber, R. K., and J. H. Graves. 1977.Powerline corridors as possible barriers to the 98

movement of small mammals. Am.Midl. Nat. 97: 504-508. 99

Thompson, I. D. & Coglan, P. W. (1987). Prey choice by marten during a decline in prey 100

abundance. Oecologia. 83: 443-451. 101

18/07/12 132


CEC/MH-III-108

Date June 7th 2012

Reference Small Mammals. p. 6-75/76



1

Question: 2

Please provide the criteria that would determine whether herbicides will be used. How 3

and when would they be applied? What kinds of herbicides will be used? 4

Response: 5

Manitoba Hydro’s Integrated Vegetation Management program utilizes selective 6

herbicides in conjunction with other control methods to target tree species. The use of 7

herbicide is conducted under the strict guidelines of the label and only Industrial 8

approved selective herbicides are permitted. All herbicides used are applied in 9

accordance with applicable provincial and federal laws and regulations, registered with 10

the Pest Management Regulatory Agency (federally), and Manitoba Conservation – 11

Environmental Approvals. 12

Selective herbicide use encourages a low growing plant community of grasses, forbs and 13

shrubs, that helps inhibit tree invasion onto the right-of-way, reducing the need for 14

future vegetation maintenance. 15

The tree control herbicides used at present are Garlon XRT, and Tordon 101. 16

The Operational Environmental Protection Plan will identify any areas where herbicides 17

may not be used, such as sites identified for medicinal plant harvest or where rare or 18

endangered plant species exist. 19

18/07/12 133


CEC/MH-III-112

Date June 7th 2012

Reference Climate Change impacts p. 8-26



1

Question: 2

Climate Change impacts are dismissed here as of medium or longer term importance 3

and have not been considered in the effects assessment. Please reconsider as even 4

small climate change impacts can be experienced in the short-term. E.g. warming 5

winters, increased frequency of extreme events. Warming winters, even in the short-6

term can have a significant effect on the construction schedule and methods as well as 7

long-term maintenance, particularly related to winter access. Please comment on how 8

climate change will influence moderate and longer term on-the-ground operation and 9

maintenance during the life of the project. 10

Response: 11

Page 8-26 includes analysis of climate change impacts and more detail is included on 12

page 8-365. This response summarizes information from page 8-365 and provides 13

additional information. 14

Short term climate change impacts are difficult to distinguish from natural climate 15

variability. A construction approach, which is adaptive to weather conditions, can help 16

offset weather related impacts. Medium and long term climate change impacts such as 17

permafrost degradation are considered manageable. While extreme events can impact 18

the Bipole III project components, potential adverse impacts of future extreme events 19

on Manitoba Hydro’s transmission system as a whole are reduced by the Bipole III 20

Project. 21

18/07/12 134


CEC/MH-III-112

Climate change impacts were assessed following the Intergovernmental Panel on 22

Climate Change (IPCC) guidelines, which recommend the use of 30 year averaged time 23

periods (termed the 2020s, 2050s and 2080s). While the 2020s time period could be 24

seen as the short term, it represents the average climate between the year 2010 and 25

2039. Climate change projections are made with respect to average conditions and not 26

extreme events, since greater uncertainty surrounds the analysis of extremes. Given the 27

difficulty in distinguishing climate change from natural climate variability in the short 28

term, and the nature of future climate projections, it is difficult to directly consider short 29

term climate change impacts for construction planning. However, the prospect of 30

significant new effects arising from climate change impacts before the planned in service 31

date are considered unlikely. 32

18/07/12 135


CEC/MH-III-117

Date June 7th 2012

Reference Invasive and Non-native Plants p. 8-66



1

Question: 2

Methods outlined to stop the spread of invasive plants are commendable. It is stated 3

that access management will be used to limit introduction during clearing and 4

construction. Have other methods been considered for the operational stage? Have 5

alternative ROW vegetation management strategies been considered that would limit the 6

survival of invasive and non-native species? 7

Response: 8

In order to prevent the spread of vegetation collected on machinery during line 9

maintenance (operational) activities standard operating procedures include washing 10

machinery thoroughly at the end of the work. Additionally, as Manitoba Hydro becomes 11

aware of issues regarding non-native species or invasive species in areas where rights-12

of-way or other facilities are maintained, appropriate measures would be undertaken, as 13

per Manitoba Hydro’s vegetation management practices. 14

18/07/12 136


CEC/MH-IV-128

Date June 15th 2012

Reference Birds Technical Report

Source CEC Information Requests # 4

Question CEC/MH-IV-128

1

Question: 2

The Technical Report on Birds offers comment on the leks of the Sharp-Tailed Grouse, 3

but only proposes monitoring of these leks. Would Manitoba Hydro please explain 4

whether it intends to identify leks in advance of construction and to avoid them or 5

whether it simply intends to identify and monitor them without any adjustment to tower 6

placement or routing of the Bipole III line? 7

Response: 8

As per Appendix H of the Draft Environmental Protection Plan for the Bipole III 9

Transmission Project, “Investigations for sharp-tailed grouse leks (courtship display 10

grounds) will occur in areas where suitable breeding habitat and Project components 11

(e.g., towers) overlap. Locations of active leks will be identified and appropriate set-back 12

distances will be applied. Number of grouse observed using leks will also be recorded 13

and will function as baseline for comparison to grouse numbers observed during and 14

after Project construction.” 15

Based on the pre-construction surveys, mitigation measures identified in the draft 16

Environmental Protection Plan and a review of the tower locations, small adjustments in 17

tower placement may be possible in some circumstances where the footprint of a 18

transmission line tower overlaps an identified lek. 19

Other mitigation measures for sharp-tailed grouse leks that are documented in the Birds 20

Technical Report include the following: 21

Setback distances will be applied around sharp‐tailed grouse leks if the timing of 22

construction activity overlaps with sensitive time periods. 23

18/07/12 137


CEC/MH-IV-128

Perch deterrents (see Bird Technical Report Section 5.2.2.3 and 5.2.3) such as 24

porcupine wire or triangles on transmission towers will be installed near 25

sharp‐tailed grouse leks to reduce predation on sharp‐tailed grouse by raptors. 26

Shrubby vegetation on the right-of-way will be maintained where possible to 27

impede transportation via snowmobile and ATV, and some foot traffic to reduce 28

access to the area by hunters and decrease the local harvest of and sensory 29

disturbance sharp‐tailed grouse. 30

18/07/12 138


CEC/MH-IV-131

Date June 15th 2012

Reference CEC Information Requests # 4



1

Question: 2

In describing technical parameters important in maintaining separation distance 3

Between Bipole III line and the Bipoles I and II lines, Appendix 7A states: 4

5

Separation from Bipoles I and II is critically important in addressing system reliability 6

concerns. The objective of this evaluation was to select route segments that meet the 7

minimum separation distance requirement of 40 km from Bipoles I and II. 8

Response: 9

For discussion regarding system reliability please refer to the response provided for 10

CEC/MH-II-023. 11

18/07/12 139


CEC/MH-IV-133

Date June 15th 2012

Reference Appendix 7B of the EIS



1

Question: 2

In describing preliminary preferred route adjustments, Appendix 7B of the EIS reveals 3

that no change was made in route in response to numerous suggestions from several 4

landowners and a Rural Municipality asking for the re-routing of the Bipole III line from 5

private land into marginal land in the Lenswood Community Pasture. Appendix 7B 6

documents a similar suggestion asking for the re-routing of the line from private land 7

into the Langruth Community Pasture. Although the EIS states that these suggestions 8

were considered, it explains that no re-routing occurred because it “may cause federal 9

approval triggers which jeopardize project timing.” Would Manitoba Hydro please advise 10

on the extent that decisions on the routing of the Bipole III line were affected globally 11

by concerns about federal approval triggers and the effect that a federal review might 12

have on project timing? 13

Response: 14

It was anticipated that federal participation in an environmental review would add 15

complexity and time to the review and approvals process. Therefore, a strategic decision 16

was made to avoid federal lands (Indian Reserves, National Parks) or land under federal 17

authority or interest, (Community Pastures, TLEs) as part of the routing criteria. In that 18

decision it was recognized that the removal of the relatively small amount of federal land 19

from the route selection process would have little effect on routing opportunities. As a 20

result of the federal land removal from the route selection process, the Canadian 21

Environmental Assessment Act (CEAA) was not triggered based on federal land 22

decisions. Other areas of federal jurisdiction were addressed in regards to fish and 23

navigation through the respective federal authorities. 24

18/07/12 140


CEC/MH-IV-138

Date June 15th 2012

Reference Birds Technical Report



1

Question: 2

There are other similar areas to the one noted above, in addition to those “bottlenecks” 3

identified in the Technical Report on Birds. Manitoba Hydro needs to explain how it 4

intends to reflect the relative impact anticipated for the various areas that are 5

environmentally sensitive for birds to indicate the importance of the concern for each 6

area. 7

Response: 8

The effects assessment identified and considered all potential impacts, including those 9

relative to environmentally sensitive areas for birds. For a detailed description on 10

environmentally sensitive sites and areas with high values for birds refer to Section 4.5 11

(pages 118 to 130) in the Bipole III Bird Technical Report. As discussed in Section 8.2.7 12

of the Bipole III EIS, and Section 5.1 of the Bipole III Bird Technical Report, effects on 13

bird populations, that include environmentally sensitive sites and areas with high values 14

for birds are mortality, habitat alteration and sensory disturbance, and disruption of 15

movements (Section 8.2.7.2 of the Bipole III EIS, and Sections 5.1.1.1 to 5.1.1.3 of the 16

Bipole III Bird Technical Report). The effects of habitat fragmentation and other 17

potential effects as identified by First Nations are outlined in Sections 5.1.1.4 and 18

5.1.1.5 of the Bipole III Bird Technical Report respectively. 19

Please see the Draft Environmental Protection Plan for further detail with respect to 20

general and specific mitigation measures (EIS Chapter 11 - Attachment 11-1). 21

18/07/12 141


CEC/MH-IV-143

Date June 15th 2012

Reference (Question CEC-MH-IV-142). Referring to Tom Lamb and

Summerberry WMAs



1

Question: 2

Please provide a proposal on how MH will minimize the impact on land use in above two 3

Wildlife Management Areas .Moreover, it appears that MH attempts to downplay the 4

impact of the intrusion of the Bipole III line into two rare-occurrence and enduring soil 5

features within these areas by calculating the percentage of the total area protected 6

under each area that is accounted for by the path of the right-of-way through these 7

protected areas. Please provide mitigation measures. 8

Response: 9

Please see response provided in CEC/MH-IV-142. 10

18/07/12 142


CEC/MH-V-155

Date June 22nd 2012

Reference Chapter 2


Question CEC/MH-V-155

1

Question: 2

Please discuss the implication, if any, of the proposed timing of Bipole III related to the 3

potential delay or cancellation of proposed northern generation. 4

Response: 5

The Bipole III Transmission Project is a reliability initiative to ensure the security and 6

reliability of electricity to Manitobans in the event of catastrophic failures of the Bipole I 7

& II transmission lines and Dorsey Station by supplying much needed redundancy. The 8

delay or cancellation of the development of new northern generation will not alter the 9

need for or impact the in-service date of the Bipole III Transmission Project. 10

18/07/12 143


CEC/MH-V-166

Date June 22nd 2012

Reference Chapter 6 Section 2.7 page 6-97



1

Question: 2

The statement that “Historically, a large portion of the Prairie Ecozone consisted of tall-3

grass prairie” (page 6-97) is incorrect; change this to “mixed-grass prairie” to be more 4

accurate. Historically, tall-grass was largely restricted to Red River valley, while the 5

areas further west were mixed-grass and the extreme southwest of Manitoba short-6

grass (e.g. burrowing owl habitat). 7

Response: 8

Smith et al. (1998) states, "Originally, a large part of this ecozone in Manitoba consisted 9

of tall-grass prairie (pp. 209)." Smith et al. (1998) was the primary reference used in 10

describing the ecozones, ecoregions and ecodistricts of Manitoba, and its use here 11

appears to be paraphrased accurately. The authors agree with the observation of tall-12

grass, mixed-grass and short-grass prairie distribution in Manitoba, and appreciate the 13

clarification to the description of the Prairie Ecozone. This correction does not change 14

the outcome of the effects assessment. 15

References: 16

Smith, R.E., H. Veldhuis, G.F. Mills, R.G. Eilers, W.R. Fraser, and G.W. Lelyk. 1998. 17

Terrestrial ecozones, ecoregions, and ecodistricts, an ecological stratification of 18

Manitoba’s natural landscapes. Technical Bulletin 98-9E. Land Resource Unit, Brandon 19

Research Centre, Research Branch, Agriculture and Agri-Food Canada, Winnipeg, MB. 20

18/07/12 144


CEC/MH-V-168

Date June 22nd 2012

Reference Chapter 6 Sec 2.9 Pages 6-124 to 6-131



1

Question: 2

References are made to the role of insects and forest health, and to biodiversity of 3

insect taxa in boreal wetlands (though curiously not to bryophytes, lichens, fungi and 4

vascular plants, and their productivity and organic biomass accumulation). Carabid 5

beetles and monarch butterflies are also briefly mentioned. Yet the entire focus is on 6

three VECs, moths of the genus Hesperia that occur in native prairie habitat. This is 7

unfortunate, since the focus is on a very narrow group and a single habitat. A more 8

broad-based approach that addresses the insects (and other invertebrates, e.g. aquatic) 9

is needed. 10

Please comment. 11

Response: 12

The Bipole III Transmission Project has been evaluated using a Valued Environmental 13

Component (VEC) approach. The selection criteria for terrestrial invertebrate VECs 14

included: current or historical distribution ranges within or in close proximity to the 15

Bipole III right-of-way; presence of suitable habitat within the Bipole III Local Study 16

Area; specific listing by COSEWIC, SARA, or MBESA; species with isolated populations; 17

species sensitivity to habitat alteration/fragmentation; and the rarity of species habitat. 18

This approach resulted in the selection of three prairie dependent terrestrial 19

invertebrates as VECs. In this way the greatest potential effects (i.e., habitat alteration, 20

fragmentation and associated effects) and the species most likely impacted through the 21

Project were included in the effects assessment. 22

18/07/12 145


CEC/MH-V-168

As it relates to the aquatic environment, the construction and operation of overhead 23

transmission lines pose a minimal risk for negative effects. To this end the Department 24

of Fisheries and Oceans Canada (DFO) has developed an Operational Statement (OS) for 25

overhead line construction. The OS identifies specific mitigation measures, and when 26

these are applied the Project will avoid negative effects to fish and fish habitat and be in 27

compliance with the Fisheries Act. In protecting fish habitat, aquatic invertebrates will be 28

protected as well. 29

18/07/12 146


CEC/MH-V-173

Date June 22nd 2012

Reference Aboriginal Traditional Knowledge Technical Report 2



1

Question: 2

This report appears to miss and/or misinterpret (in a manner favouring the proponent) a 3

great deal of the substantive content of the concerns identified in the self-directed 4

reports. 5

a) Why was this report written? 6

b) Who was the author(s)? 7

c) Was the accuracy of the summarization this report validated with: i.) the authors 8

of the self-directed studies and/or ii.) the community members who participated in the 9

self-directed studies? 10

d) If the accuracy of this report was validated, please describe how. 11

e) If the accuracy of this report wasn’t validated, why not? 12

Response: 13

The Aboriginal Traditional Knowledge Technical Report 2 was drafted by Manitoba Hydro 14

staff with the intent of providing a brief summary of the information shared through the 15

seven self-directed Aboriginal Traditional Knowledge (ATK) studies. Each ATK study was 16

summarized by Manitoba Hydro and in October 2011, the MMF and each First Nation 17

were provided the summary relating to their report for review. They were asked to 18

review the summary to ensure that they were comfortable with the way in which their 19

information was presented. 20

18/07/12 147


CEC/MH-V-173

Where changes were requested, Manitoba Hydro worked with the MMF or First Nation 21

representatives to develop new wording. Manitoba Hydro is not aware if the MMF or 22

First Nations shared parts or all of Manitoba Hydro’s summary with the members who 23

participated in their respective study. As the summaries are not meant to provide the 24

level of detail contained in the reports themselves, the complete reports were included 25

as attachments to the Aboriginal Traditional Knowledge Technical Report 2. 26

18/07/12 148


CEC/MH-V-174a

Date June 22nd 2012

Reference Socio-Economic Baseline Technical Report Appendix B, Part 1


Question CEC/MH-V-174a

1

Question: 2

The methods for developing the key person interview (KPI) summaries are not described 3

in sufficient detail to assess their quality and utility. 4

a) How were these interview summaries produced? For example, were the 5

interviews audio-recorded and then transcribed, or were these summaries based on 6

written notes made by the interviewer? 7

Response: 8

All key person interviews were digitally recorded, with the consent of the interviewee, as 9

per Appendix B-4 (Consent to Interview Form). Upon completion of the interview, the 10

summaries were prepared by reviewing the audio-recording of the interview and 11

transcribing the information into summary format, following the order of the questions 12

asked during the interview. Any notes taken during the interview were also incorporated 13

into the summaries, as necessary. The interview summaries also included information 14

that was identified on the maps used during the interview (if applicable). All interviewers 15

and other attendees from the consultant team reviewed their corresponding summaries 16

to ensure accuracy. When local landmarks and areas of interest were identified, further 17

confirmation took place regarding spelling or location information. Examples included 18

correct highway numbering, river and waterbody names, and community services 19

names. 20

18/07/12 149


CEC/MH-V-175a

Date June 22nd 2012

Reference Socio-Economic Baseline Technical Report Appendix B, Part 1


Question CEC/MH-V-175a

1

Question: 2

Most importantly, the technical report states “overall the extent of participation in the EA 3

consultation process was substantial (approximately 4,500 participants) and should be 4

considered effective for a project of this scale.” This statement is without any context or 5

explanation. How much is enough? What % of each community was actually consulted? 6

Based on the numbers presented, the proportion of the people living in the study area 7

that actually participated in the consultation process was exceedingly low. These kinds 8

of low participation rates are typical for projects similar to Bipole III where likely many 9

community members feel that the project would go ahead regardless of what they say 10

so they would be unlikely to participate. It is recommended that a follow-up study be 11

done to assess if communities in affected areas actually feel that they were adequately 12

consulted and informed. 13

Response: 14

Manitoba Hydro does not intend to pursue a follow up study regarding its consultation 15

program. Manitoba Hydro undertook a 4 round process over 3 years to elicit feedback 16

from stakeholders, communities, landowners and the general public regarding the 17

Project. Manitoba Hydro undertook a variety of methods to engage the public 18

(leadership, council and stakeholder meetings, regional and community open houses, 19

and landowner information centers) and is continuing its dialogue with the public using 20

methods which are readily accessible such as the Bipole III Project information line 21

which has been in service since July 2010 and the Bipole III email address. These 22

venues provided interested parties with an opportunity to become informed of the 23

18/07/12 150


CEC/MH-V-175a

Project, to have their concerns addressed and to and to have any questions answered 24

that they may have regarding the Project. 25

Manitoba Hydro attempted to elicit feedback from as many individuals as possible. 26

Manitoba Hydro utilized a variety of methods to notify interested parties, the public and 27

stakeholders of events and venues in which they could participate and provide feedback. 28

Manitoba Hydro used radio advertisements, newspaper notices, direct mailings, postal 29

code drops, and posters to reach as many people as possible. 30

In the way of follow-up, Manitoba Hydro is committed to ongoing dialogue with 31

communities along the Final Preferred Route. Manitoba Hydro has been engaging First 32

Nation and NACC communities and the MMF to ensure that specific site locations, which 33

were noted in the ATK process and any additional sites are incorporated into the 34

Environmental Protection Plan (EnvPP) for the Project. These meetings and discussions 35

are ongoing. 36

18/07/12 151


CEC/MH-V-175c

Date June 22nd 2012

Reference Chapter 5 and Consultation Technical Report Nov 2011, Table 4


Question CEC/MH-V-175c

1

Question: 2

Table 4 assigns stakeholders to tiers, according to a set of criteria that are given. Who 3

applied those criteria, and how? How were direct versus indirect effects assessed during 4

that process? 5

Please clearly and fully explain the process. 6

Response: 7

The criteria were applied by the Environmental Assessment Consultation Program 8

(EACP) team to a variety of stakeholders. The EACP team was comprised of Manitoba 9

Hydro staff and external specialists. 10

The tier structure was developed as a non-analytical management tool to assist the 11

EACP team in ensuring notification and engagement methods would be adequate. No 12

stakeholder was confined to a specific tier. Furthermore, notification methods and 13

engagement processes changed as the EACP evolved and from the feedback received 14

during the EACP. As stated in section 8.0 of the EACP technical report “any interested 15

party would be provided an equal opportunity to meet with project representatives and 16

an equal opportunity to access project information.” 17

Tier 1 considered directly affected stakeholders as those who had direct interest in the 18

land which were to be potentially traversed by the Preliminary Preferred Route. This tier 19

included First Nation and NACC Communities, Landowners, Municipalities, the MMF and 20

those who informed the EACP team of their perceived potential impact. 21

18/07/12 152


CEC/MH-V-175c

Tier 2 represented umbrella organizations, government departments, environmental 22

groups who may have an interest in the project following the determination of the 23

Preliminary Preferred Route. 24

Tiers 3 and 4 were used in the initial Rounds of the EACP as the consultation team 25

gauged involvement and interest in the Project. As the study area was broad, all entities 26

were considered as to having a direct or indirect impact. As an example, during Round 3 27

Rural Municipal councils that were potentially crossed by an alternative route corridor 28

were considered Tier 3 (potential impact) whereas those who were in the study area 29

and were not traversed by one of the three routing corridors were considered not 30

impacted (Tier 4). Those municipalities in Tier 4 received notifications of project status 31

and those in Tier 3 were offered council meetings. 32

This tier method determined what notification and engagement methods would be 33

appropriate to elicit feedback from those potentially affected stakeholders. It was not 34

used as an assessment method, but only for process management. 35

18/07/12 153


CEC/MH-V-177

Date June 22nd 2012

Reference Lands of Special Interest and TLE Lands Technical Report



1

Question: 2

The report lists 27 factors that were used to evaluate the alternative routes. How were 3

these chosen? It seems like they were mainly chosen based on existing data that were 4

readily and freely available rather than any specific criteria. Explanation and justification 5

of these choices is needed and is one of many places where reference to the literature 6

and what has been done in other similar areas has not been done. The ranking seems 7

highly subjective, often in favor of the proponent. Please explain. 8

Response: 9

The criteria for each of the 27 factors used in the Site Selection and Environmental 10

Assessment process are provided in Appendix 7a of the EIS. The selection process, 11

including ranking considerations for all 27 factors, is also provided in the same 12

Appendix. 13

18/07/12 154


CEC/MH-V-179

Date June 22nd 2012




1

Question: 2

The methods on how ATK was incorporated into the ranking are not clear, but it appears 3

that inclusion of ATK either had no effect or increased a ranking. Why could it not also 4

decrease a ranking? 5

Response: 6

An explanation of how ATK was incorporated into Site Selection and Environmental 7

Assessment process is provided in EIS Chapter 7, Appendix 7a. ATK information 8

consisted of values or areas of importance to the Aboriginal communities/members. 9

Where such values/areas of importance were intersected by alternative corridors, 10

rankings would naturally be elevated since the rankings represent level of constraint. 11

Where such values/areas were not identified, rankings remained unaffected (e.g. not 12

increasing the level of constraint for a particular route segment). 13

18/07/12 155


CEC/MH-V-182

Date June 22nd 2012




1

Question: 2

The use of ‘enduring features’ in the analysis is unusual and not seen in the literature. 3

More commonly, ecozones and ecoregions are used to identify representative areas, 4

which are reflective of biological aspects of the landscape rather than geological. Please 5

explain the use of the term ‘enduring features’ in the analysis and provide any 6

background literature. 7

Response: 8

The source of the term and its definition was provided by the Province of Manitoba's 9

Protected Areas Initiative with whom Manitoba Hydro consulted on route selection and 10

mitigation. The following excerpt is from the Protected Areas Initiative website 11

(http://www.gov.mb.ca/conservation/pai/establishing/index.html). 12

"To determine areas that are of special interest to the Protected Areas Initiative (PAI), 13

an analysis of the enduring features of Manitoba has been conducted. Enduring 14

features are combinations of soils and surficial geology that are used to represent the 15

biodiversity within Manitoba’s 18 natural regions (areas that are differentiated from one 16

another by their geographic, climatic and vegetative features). All biological organisms 17

share a connection to the landscapes in which they are found. The soil and landforms 18

that create these landscapes however, endure and are more stable over time than the 19

organisms themselves. As a result, it is easier to identify these more permanent 20

enduring features than it is to attempt to assess the biological diversity of a natural 21

region over time. Representing enduring features in a system of protected lands 22

therefore, serves as a useful way of protecting the biological diversity of a natural 23

18/07/12 156

http://www.gov.mb.ca/conservation/pai/establishing/index.html


CEC/MH-V-182

region. Enduring features analysis allows for the identification of Areas of Special 24

Interest (ASIs) and aids in prioritizing which areas are most critical for protection." 25

18/07/12 157


CEC/MH-V-183

Date June 22nd 2012




1

Question: 2

183. That the proposed route will pass through 9 of the 21 Wildlife Management areas, 3

including one of the largest WMAs in Manitoba indicates serious capacity for impact. A 4

rating of „medium‟ while subjective seems low and indefensible. Please explain how 5

“medium” was determined. 6

Response: 7

Nine WMAs were encountered at the initial stages of the route selection process using a 8

4.8 km wide planning corridor. The Final Preferred Route (FPR) on a 66 m right-of-way 9

intersects only two existing WMAs (Churchill and Tom Lamb) both of which are classified 10

by Protected Areas Initiative as “Not Protected”. The FPR also intersects two (2) 11

proposed WMAs, namely Summerberry and Red Deer WMAs. 12

The Lands of Special Interest and TLE Lands Technical Report deals specifically with 13

land use issues as they relate to the proposed Bipole III Transmission Project, protected 14

lands and lands proposed for protection, and First Nations reserve and TLE lands (see 15

Section 1.2 of the Technical Report). The rankings within this report are limited to this 16

perspective and were conducted at the alternative routes evaluation stage on a segment 17

basis. The ranking method is explained in Sec. 3.2.2, VEC Evaluation - Protected Areas. 18

Protected lands were ranked from high, medium to low according to the level of 19

protection afforded them. A high ranking was assigned for those lands designated under 20

Legislation for permanent protection and included National Parks, Provincial Parks and 21

Ecological Reserves. A medium ranking was assigned to Areas of Special Interest, 22

Wildlife Management Areas and Forest Reserves. A medium to low ranking was assigned 23

to Crown Lands and Community pastures because a transmission line is considered to be 24

18/07/12 158


CEC/MH-V-183

compatible with activities such as cultivating hay and livestock pasturing, which are 25

common land use practices in these areas. Forest Reserves were also ranked medium as 26

resource use activities including forest harvesting are allowed. 27

Considerations for connectivity, fragmentation, biological effects, traditional Aboriginal 28

values and resource use are provided in the following Bipole III Transmission project 29

supporting technical reports which in many cases elevated rankings for route segments 30

that intersected protected areas and Areas of Special Interest (ASI): 31

Caribou Technical Report; 32

Birds Technical Report; 33

Mammals Technical Report; 34

Resource Use Technical Report; 35

Terrain and Soils Technical Report; 36

Terrestrial Ecosystems and Vegetation Technical Report; 37

Terrestrial Invertebrates, Amphibians and Reptiles Technical Report; and 38

Aboriginal Traditional Knowledge Technical Reports #1 and #2. 39

18/07/12 159


CEC/MH-V-184

Date June 22nd 2012


Source CEC Information Request#5


1

Question: 2

The report states that hydro developments are not allowed under legislation on 3

protected areas or Wildlife Management Areas, yet the proposed route includes many 4

WMA’s and several other areas. How is that possible? 5

Response: 6

National and provincial parks, ecological reserves and some wildlife management areas 7

(WMA) are generally closed to industrial developments such as hydro-electric projects. 8

In Manitoba, WMAs are classified by Manitoba Conservation and Water Stewardship, 9

Protected Areas Initiative (PAI) as either "Protected" or "Not Protected". Within the 10

latter some development is allowed. 11

The proposed Bipole III Transmission Project Final Preferred Route (FPR) does not 12

directly affect any parks, ecological reserves or "Protected" WMAs. It does intersect with 13

two (2) WMAs (Churchill and Tom Lamb) that are classified "Not Protected". The FPR 14

also intersects with three Areas of Special Interest (ASI), namely ASI 114 (Stephens 15

Lake), ASI 190 (Summerberry Proposed WMA) and ASI 86 (Red Deer Proposed WMA). 16

In regards to all of the above Manitoba Hydro has worked closely with PAI to identify 17

the best routing opportunities and mitigate concerns. 18

See also CEC/MH-V-183. 19

18/07/12 160


CEC/MH-V-185

Date June 22nd 2012

Reference Lands of Special Interest and TLE Lands Technical Report page 56



1

Question: 2

On page 56, the report states: “It is not anticipated that Bipole III will affect the 3

ecological reserve, as the transmission line only occupies a 66 m ROW within the 4.8 km 4

planning corridor and there should be suitable flexibility within the tower spans to avoid 5

the salt water spring as well as the proposed addition to the ecological reserve.” This 6

judgment is made without any real basis and seems to suggest that as long as a tower 7

isn’t physically in the pond then there will be no impact, when there are in fact likely to 8

be other impacts associated, especially during construction, but also during ongoing 9

monitoring and maintenance that will affect biological diversity and human use. Please 10

provide the rationale for this statement. 11

Response: 12

The proposed Bipole III Transmission Project Final Preferred Route (FPR) is situated well 13

clear of the Lake Winnipegosis Salt Flats Ecological Reserve, the proposed reserve 14

addition and the associated salt spring. 15

UNIT NEAREST POINT FROM FPR CENTRE LINE 16

L. Winnipegosis Salt Flats ER 2560 meters 17

L. Winnipegosis Salt Flats ER Addition 1995 meters 18

Salt spring 1280 meters 19

Manitoba Hydro has worked closely with Protected Areas Initiative (PAI) during the 20

routing phase of the Project, including final routing, that has ensured the protection of 21

these features. In addition, Manitoba Hydro has identified existing access routes in this 22

area that intersect with the proposed right-of-way (ROW) and are well clear of these 23

18/07/12 161


CEC/MH-V-185

features. All clearing, construction and maintenance related activities will be restricted to 24

the identified access routes. Also, all ground-based activities, during all phases of the 25

development will be restricted to frozen ground conditions thereby minimizing 26

environmental disturbance. 27

18/07/12 162

Documents

RE: Bipole III Transmission Project Response Package #3manitobawildlands.org/pdfs/bp3cec/HY-BP3-MBHY-ResponsetoCECIRs...(204) 360-4394 [email protected] July 18th, ... Carry out