{ Enbridge Line 21 Replacement Segment MVLWB Hearing October 27, - PDF document

2017‐10‐18 Dehcho First Nations { Enbridge Line 21 Replacement Segment MVLWB Hearing – October 27, 2017 Dehcho First Nation’s Perspective • Enbridge Line 21 Replacement Segment is in the heart of the traditional territory of the Dehcho First Nations • Most directly impacted community by the Enbridge Line 21 Replacement Segment is Liidlii Kue but other communities have a shared interest in this project. • Boat travel, fishing and hunting and other traditional harvest activities are important for subsistence and way of life in the Dehcho • DFN’s ultimate goal for participating in this process is to ensure that the water quality and overall health of the Mackenzie River is maintained. 1

2017‐10‐18 Enbridge’s Line 21 Pipeline • In the 1980s, the Line 21 pipeline was constructed from Norman Wells to Zama, AB, with approximately 80% of the pipeline running through the Dehcho. • Line 21 Pipeline was the first fully buried pipeline thorough discontinous permafrost in North America. • Extensive ground thermal monitoring has shown several meters of vertical thaw, ponding and ground subsidence of more than 2 m (Smith et al 2008). • DFN to date does not know how many pipeline failures have occurred on the Line 21 pipeline. • DFN communities have outstanding concerns regarding the integrity of the Line 21 Pipeline. Dehcho K’e ́ hodi Stewardship & Guardian Program • Community based monitoring program has been expanded from Dehcho AAROM • Currently there are 1-2 Guardians per community • Any monitoring programs for the proposed Enbridge Line 21 Replacement Program entail Enbridge funding towards an independently run Dehcho K’e ́ hodi Stewardship and Guardian Program 2

2017‐10‐18 DFN’s Concerns regarding the LUP & WL • Impacts of Temporary workers on Fort Simpson • Engagement Plan • Drilling Fluids • Spill Contingency Planning and Reporting • Archaeological Resources • Closure and Reclamation Planning Impact of Temporary Workers 3

2017‐10‐18 Engagement Plan Enbridge’s Line 21 Replacement Program Engagement Plan focuses on the proponent’s regulatory requirements. DFN supports a more holistic approach to engagement planning DFN’s Recommendation: • More detailed engagement plan developed with DFN communities. • Includes engagement activities outside regulatory requirements. Drilling Fluids In the draft LUP permit it states: • The Permittee shall not use any Drilling Fluids, or additives that were not identified in the complete application, unless the MSDSs are provided to the Board and Inspector and usage of the chemical(s) is authorized in writing by the Board. • At least seven days prior to the use of any chemicals that were not identified in the complete application, the MSDS sheets must be provided to the Board and an Inspector. DFN’s Recommendation: Consultation with DFN and DFN member communities prior to using any drilling fluids or additives that were not identified in the complete application. Enbridge will identify any proposed drilling fluids or additives. 4

2017‐10‐18 Spill Contingency Planning & Reporting DFN’s Recommendation: • Include spill reporting to DFN and DFN communities: • Report on all spills to date in the Dehcho; • Report each spill to DFN and DFN member communities within 24 hours; and Submit, to DFN and DFN communities, a detailed report an each spill within 30 days. • Any further reporting or follow-up on the cause of the spill beyond the 30 days will be forwarded to DFN and DFN communities. This includes reports to the National Energy Board. Archaeological Resources DFN Recommendation: • A suspected archaeological or historical site, or burial ground is discovered: it will be reported to DFN (867) 695-2355 and any directly impacted DFN community. 5

2017‐10‐18 Closure and Reclamation of the site DFN recommends that Enbridge submit a Closure and Reclamation Plan that includes (but is not limited to) Site objectives and closure criteria • Methods to restore natural drainage • Physical approach • Maps delineating the disturbed areas • Photographs of the site • Method of reclamation • Community participation in long term site monitoring and maintenance • 6