melissa straus - enbridge gas

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From: Straus, Melissa To: "[email protected]" Cc: Hartwig, Emily ; Kelsey Mills ; Kathy McConnell ; Reischke, Karissa (MNRF) Subject: [External] RE: Ladysmith Designated Storage Area Well TL9H - Mitigation Plan for Butler"s Gartersnake Date: Friday, March 22, 2019 1:45:11 PM Attachments: let_mnrf_Ladysmith Well_20190307_fnl_updated.pdf Good afternoon, In follow up to my March 8 email below, please find an updated project description with regards to Project-specific tasks and timing. No changes in Project footprint from our originally submitted letter (attached) are proposed. Please advise if the proposed mitigation plan is satisfactory for implementation during construction. Enbridge Gas Inc. (“EGI”) is proposing to construct and complete a vertical stratigraphic test well located in the EGI Ladysmith Designated Storage Area (DSA) north of Courtright Line and west of Tecumseh Road in the Township of St. Clair, Lambton County (the “Project”). The well (TL9) is being installed as a stratigraphic test well for the purposes of coring approximately 165m of rock. Once coring operations are completed, instrumentation will be installed in the well and the well will be monitored from 2019 to 2021. In addition to the drilling, construction activities to support the Project include installation of a new drill pad for well TL9, and installation of an access road to facilitate equipment access during construction as well as during maintenance and monitoring operations. The work to construct the access road and prepare the drill pad is scheduled to occur in late May, early June of 2019. The drilling of the well is scheduled to occur in late August, early September of 2019, during which onsite drilling equipment will be stationary and is anticipated to run 24 hours a day, 7 days a week. Once the well is completed, the pad will remain in place until 2021, when the well will be re-entered, plugged back and recompleted as a gas storage well (TL9H). It is anticipated that this drilling will occur in March 2021. Thank you very much for your time, Melissa Straus M.Sc. Terrestrial Ecologist Direct: 519 780-8103 Mobile: 226 971-2704 Fax: 519 836-2493 [email protected] Stantec 1-70 Southgate Drive Guelph ON N1G 4P5 CA The content of this email is the confidential property of Stantec and should not be copied, modified, retransmitted, or used for any purpose except with Stantec's written authorization. If you are not the intended recipient, please delete all copies and notify us immediately. From: Straus, Melissa Sent: Friday, March 08, 2019 2:52 PM To: '[email protected]' <[email protected]> Cc: Hartwig, Emily <[email protected]>; Kelsey Mills <[email protected]>; '[email protected]' <[email protected]> Subject: Ladysmith Designated Storage Area Well TL9H - Mitigation Plan for Butler's Gartersnake Good afternoon, Filed: 2019-05-03, Exhibit C, Tab 1, Schedule 1, Attachment 3, Page 1 of 2

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From: Straus, Melissa To: "[email protected]" Cc: Hartwig, Emily; Kelsey Mills; Kathy McConnell; Reischke, Karissa (MNRF) Subject: [External] RE: Ladysmith Designated Storage Area Well TL9H - Mitigation Plan for Butler"s Gartersnake Date: Friday, March 22, 2019 1:45:11 PM Attachments: let_mnrf_Ladysmith Well_20190307_fnl_updated.pdf
Good afternoon,
In follow up to my March 8 email below, please find an updated project description with regards to Project-specific tasks and timing. No changes in Project footprint from our originally submitted letter (attached) are proposed.
Please advise if the proposed mitigation plan is satisfactory for implementation during construction.
Enbridge Gas Inc. (“EGI”) is proposing to construct and complete a vertical stratigraphic test well located in the EGI Ladysmith Designated Storage Area (DSA) north of Courtright Line and west of Tecumseh Road in the Township of St. Clair, Lambton County (the “Project”). The well (TL9) is being installed as a stratigraphic test well for the purposes of coring approximately 165m of rock. Once coring operations are completed, instrumentation will be installed in the well and the well will be monitored from 2019 to 2021. In addition to the drilling, construction activities to support the Project include installation of a new drill pad for well TL9, and installation of an access road to facilitate equipment access during construction as well as during maintenance and monitoring operations. The work to construct the access road and prepare the drill pad is scheduled to occur in late May, early June of 2019. The drilling of the well is scheduled to occur in late August, early September of 2019, during which onsite drilling equipment will be stationary and is anticipated to run 24 hours a day, 7 days a week. Once the well is completed, the pad will remain in place until 2021, when the well will be re-entered, plugged back and recompleted as a gas storage well (TL9H). It is anticipated that this drilling will occur in March 2021.
Thank you very much for your time,
Melissa Straus M.Sc. Terrestrial Ecologist
Direct: 519 780-8103 Mobile: 226 971-2704 Fax: 519 836-2493 [email protected]
Stantec 1-70 Southgate Drive Guelph ON N1G 4P5 CA
The content of this email is the confidential property of Stantec and should not be copied, modified, retransmitted, or used for any purpose except with Stantec's written authorization. If you are not the intended recipient, please delete all copies and notify us immediately.
From: Straus, Melissa Sent: Friday, March 08, 2019 2:52 PM To: '[email protected]' <[email protected]> Cc: Hartwig, Emily <[email protected]>; Kelsey Mills <[email protected]>; '[email protected]' <[email protected]> Subject: Ladysmith Designated Storage Area Well TL9H - Mitigation Plan for Butler's Gartersnake
Good afternoon,
Filed: 2019-05-03, Exhibit C, Tab 1, Schedule 1, Attachment 3, Page 1 of 2
March 8, 2019 File: 160951091
Attention: Ministry of Natural Resources and Forestry 615 John Street North Aylmer, ON N5H 2S8 Via email: [email protected]
To Whom it May Concern,
Reference: Ladysmith Designated Storage Area Well TL9H – Background Species at Risk Screening and Mitigation Plan for Butler’s Gartersnake
PROJECT DESCRIPTION
Enbridge Gas Inc. (“EGI”) is proposing to construct and complete a stratigraphic test well located in the EGI Ladysmith Designated Storage Area north of Courtright Line and west of Tecumseh Road in St. Clair Township, Lambton County (Figure A-1, attached).
Construction activities to support the drilling of the new well TL9H includes the installation of a well pad and/or upgrades to access roads. The work to construct the access road and prepare the drill pads is anticipated to be completed by May 2019.
PURPOSE
EGI retained Stantec Consulting Ltd. to conduct an Environmental Screening prior to construction of the Ladysmith well TL9H.
The purpose of this letter is to provide the Ministry of Natural Resources and Forestry (MNRF) with the results of our background screening for Species at Risk (SAR); determine if any additional measures (e.g., Letter of Advice, Information Gathering Form, or additional permitting) are required under the Endangered Species Act; and provide a proposed mitigation plan for Butler’s Gartersnake.
BACKGROUND RECORDS REVIEW
NATURAL HERITAGE INFORMATION CENTRE AND WILDLIFE ATLAS DATA
A search of the Natural Heritage Information Centre (NHIC) database and relevant wildlife atlases was conducted in 2018 to identify SAR with potential to occur within the Study Area.
Based on the background data review, historic records of five (5) SAR (i.e., species listed by COSSARO as At Risk in Ontario) were identified within 1km of the proposed well site: These species include:
• One reptile species: Butler’s Gartersnake
March 8, 2019 Ministry of Natural Resources and Forestry Page 2 of 5
Reference: Ladysmith Designated Storage Area Well TL9H – Background Species at Risk Screening and Mitigation Plan for Butler’s Gartersnake
• Three (3) bird species: Eastern Meadowlark, Bobolink, Barn Swallow
• One mammal species: Little Brown Myotis.
A description of each species, designated status, and habitat requirements are listed in Table 1.
Table 1: Summary of Threatened and Endangered Species known to occur in the general vicinity of the Study Area
Common Name Scientific Name SRANK Provincial
Status (COSSARO)
National Status
ORAA
Birds
Eastern Meadowlark
Sturnella magna S4B THR THR Hayfields OBBA
Barn Swallow Hirundo rustica S4B THR THR Buildings (nesting), open areas (foraging)
OBBA
Mammals
Little Brown Myotis Myotis lucifugus S4 END END Trees and buildings (roosting), open areas (foraging)
AMO
NOTES: THR: Threatened – a species that is at risk of becoming endangered END: Endangered – a species facing imminent extinction or extirpation ORAA: Ontario Reptile and Amphibian Atlas (Ontario Nature, online) OBBA: Ontario Breeding Bird Atlas (Cadman et al. 2007) AMO: Atlas of the Mammals of Ontario (Dobbyn 1994) S1: Critically Imperiled—Critically imperiled in the province (often 5 or fewer occurrences)
S2: Imperiled—Imperiled in the province, very few populations (often 20 or fewer)
S3: Vulnerable—Vulnerable in the province, relatively few populations (often 80 or fewer)
S4: Apparently Secure – Uncommon but not rare S#N: Non Breeding status rank
?: Denotes uncertainty in the assigned rank
March 8, 2019 Ministry of Natural Resources and Forestry Page 3 of 5
Reference: Ladysmith Designated Storage Area Well TL9H – Background Species at Risk Screening and Mitigation Plan for Butler’s Gartersnake
ENBRIDGE GAS PROJECTS
Previous consultation with the MNRF was undertaken for two similar projects; the most recent in 2018 referred to as the Dow Wells 27, 28H and 29H (approximately 10.5 km north) and the 2017 A-1 Observation Well (approximately 10.1 km northwest). A Letter of Advice for Butler’s Gartersnake was issued for each project, as described in the MNRF’s January 22, 2018 email for the Dow Wells and on April 3, 2017 in letter AYL-L-031-17 for the A-1 Observation Well.
PROJECT CONSIDERATIONS FOR SPECIES AT RISK
Based on the results of the background records review, habitat assessment, and Stantec’s experience in the surrounding landscape, Butler’s Gartersnake is the only SAR that we anticipate may be impacted by the proposed Project.
BUTLER’S GARTERSNAKE HABITAT ASSESSMENT AND POTENTIAL IMPACTS
Butler’s Gartersnake is primarily associated with tall-grass prairie habitats, but is also found in successional lands, meadows, herbaceous forest edges and along drainage swales and small bodies of water (COSSARO, 2011). In the Windsor-Sarnia area, these snakes are found most of the time in industrial and urban areas, which includes quarries, rail corridors, waste storage sites, and vacant industrial lands (COSEWIC, 2010). A key habitat component for Butler’s Gartersnake is the presence of dense grass and/or forb cover with a heavy layer of dead vegetation from previous years (COSEWIC, 2010).
Based on a desktop review, suitable habitat for Butler’s Gartersnake is marginal within the Study Area, restricted to grassy areas associated with the access road and roadside ditches, transmission line corridor, and the linear grassy strip west of existing infrastructure. There is potential for impacts to snakes that may move into the construction area during favorable weather conditions or while hiding in construction machinery for warmth. A site visit has not been completed, so details on potential hibernacula (e.g., ant mounds, crayfish burrows) cannot be provided.
PROPOSED CONSTRUCTION MITIGATION
Contingent upon the appropriate approvals and permits being secured, access road and pad installation is expected to be completed by May 2019. Although construction will occur during the active period for snakes (i.e., between April 1 and November 15), exclusion fencing is not proposed because the amount of potential habitat occurring within the work zone (i.e., road edge, adjacent to existing facilities) is extremely limited.
Drilling of the well is proposed in late August, early September 2019, during which onsite drilling equipment will be stationary and anticipated to run 24 hours a day, 7 days a week.
The following proposed mitigation measures will be implemented during all phases of construction:
• All onsite personnel shall be made aware of the potential of Butler’s Gartersnake individuals and habitat on the site. This will include project mobilization training and fact sheets made available to workers.
• Continual awareness through signage and posted minimum speeds on access roads to prevent vehicular interactions with snakes that may use roadways for hunting or basking.
March 8, 2019 Ministry of Natural Resources and Forestry Page 4 of 5
Reference: Ladysmith Designated Storage Area Well TL9H – Background Species at Risk Screening and Mitigation Plan for Butler’s Gartersnake
• Large equipment will be brought into the site using a spotter to prevent interactions with snakes on roadways.
• Daily inspection of equipment stored onsite each morning before equipment is started including a thorough inspection including around engine, tracks, etc. is required, as Butler’s Gartersnakes may be well concealed (if applicable).
• Vehicular traffic to remain on access roads and within construction envelope.
• If any snake is observed within the workspace, all mobile machinery and equipment shall maintain an operating distance of 30 m from the individual(s), monitored and allowed reasonable time to disperse from the area on its own ability.
• If a SAR species persists in the work area, Ministry of Natural Resources and Forestry (MNRF) must be contacted to determine appropriate action.
• If an injured or deceased SAR individual is found, the specimen shall be placed in a non-airtight container maintained at an appropriate temperature and MNRF SAR staff will be contacted immediately.
• An onsite inspector will be present to monitor compliance.
SUMMARY
In summary, Enbridge Gas Inc. is proposing to install the Ladysmith Designated Storage Area Well TL9H, consisting of an access road and drill pad installation slated for May 2019 and well drilling in late August, early September 2019. One species at risk, Butler’s Gartersnake, has the potential to occur in the study area based on the results of a background records review and experience with this species in this part of the province.
Construction mitigation measures are proposed in this letter for both the access road and drilling as a conservative approach. Habitat within the project footprint is marginal for Butler’s Gartersnake due to the historical use of a large portion of the study area for agricultural purposes (e.g., row crops) and the small grassy area to be removed.
In closing, we ask that you consider the above noted summary (e.g., historical agriculture uses, marginality of the habitat, small area to be impacted, provided mitigation measures) in your consideration of requirements under the Endangered Species Act.
March 8, 2019 Ministry of Natural Resources and Forestry Page 5 of 5
Reference: Ladysmith Designated Storage Area Well TL9H – Background Species at Risk Screening and Mitigation Plan for Butler’s Gartersnake
Please contact the undersigned if you have any questions or comments regarding the EGI Ladysmith Designated Storage Area Well TL9H project.
Regards,
Melissa Straus, M.Sc. Terrestrial Ecologist Phone: 519-780-8103 Fax: 519-836-2493 [email protected]
Attachment A: Figure 1 – Environmental and Socio-Economic Features
c. Rooly Georgopoulos, Stantec Consulting Ltd. Kelsey Mills, Enbridge Gas Inc.
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ATTACHMENT A: Figure A-1 – Environmental and Socio-Economic
Features
L a k e H u r o n
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Disclaimer: Stantec assumes no responsibility for data supplied in electronic format. The recipient accepts full responsibility for verifying the accuracy and completeness of the data. The recipient releases Stantec, its officers, employees, consultants and agents, from any and all claims arising in any way from the content or provision of the data.
160951091 REVA
1:10,000 (At Original document size of 11x17)
Prepared by SPE on 2019-02-05 Technical Review by CC on 2018-12-17
Environmental and Socio-Economic Features
1. Coordinate System: NAD 1983 UTM Zone 17N 2. Base features produced under license with the Ontario Ministry of Natural Resources and Forestry © Queen's Printer for Ontario, 2018, CanVec, 2018. 3. MECP Water well locations are approximate and have been positioned based on published UTM coordinates © Queen's Printer for Ontario, 2018.
ENBRIDGE GAS DISTRIBUTION INC. ENVIRONMENTAL SCREENING REPORT - LADYSMITH DESIGNATED STORAGE AREA WELL TL9H
Legend TL9H
PU Gas_Pipelines_1999_ogsr Study Area Constructed Drain
! ! Hydro Line Major Road Minor Road Watercourse Domestic Waste Petroleum Designated Gas Storage Area Petroleum Pools Random Tile Drainage
Systematic Tile Drainage Wetland - Evaluated (Provincial) Wooded Area
MECP Water Well (Well ID) "¹ Domestic "¹ Livestock
©¥ Test Hole &( Monitoring "² Monitoring and Test Hole
"k Well use not identified
"L Petroleum Well
County Of Lambton
Enbridge Gas Projects
Butler’s Gartersnake Habitat Assessment and potential impacts
Proposed Construction Mitigation
Summary
Please find attached the background species at risk screening and mitigation plan for Butler’s Gartersnake for the proposed Ladysmith Well TL9H, located in St. Clair Township. The plan is based on procedures established in consultation with the MNRF for Butler’s Gartersnake on nearby Enbridge projects.
Please provide any feedback you may have on the proposed plan and feel free to contact me if you have any questions.
Regards,
Direct: 519 780-8103 Mobile: 226 971-2704 Fax: 519 836-2493 [email protected]
Stantec 1-70 Southgate Drive Guelph ON N1G 4P5 CA
The content of this email is the confidential property of Stantec and should not be copied, modified, retransmitted, or used for any purpose except with Stantec's written authorization. If you are not the intended recipient, please delete all copies and notify us immediately.
Filed: 2019-05-03, Exhibit C, Tab 1, Schedule 1, Attachment 3, Page 2 of 2