BP Exploration Pokak 3D Seismic Program - Draft Environmental by fex18304

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									                  DRAFT ENVIRONMENTAL SCREENING REPORT
              Pursuant to the Canadian Environmental Assessment Act (CEA Act)

                                  SCREENING SUMMARY
                           BP Exploration Pokak 3D Seismic Program

BP Exploration Company Limited (BP) has applied to the National Energy Board (NEB) for
approval to gather two and/or three dimensional (2D and 3D, respectively) seismic data within
the Inuvialuit Settlement Region (ISR) in the Beaufort Sea.

The proposed priority area for the seismic data collection would be in the vicinity of BP’s
Exploration Licence (EL) 449 and EL 451, covering a total area of approximately 2800 km2.
Should weather or ice conditions not permit the collection of data over the priority area, seismic
data may be collected over adjacent areas, including BP’s EL 453.

The licence areas are located approximately 180 km north of Tuktoyaktuk. The proposed project
would be conducted during the 2009 open water season (July though to October), and if required
within the same period in 2010. The project includes the use of seismic arrays, support vessels,
icebreaker support, helicopter and fixed-wing support activities, and associated re-supplying
activities. Both the 2D and 3D seismic programs would utilize the same equipment.

This Draft Environmental Screening Report (ESR) was prepared to meet the requirements of the
CEA Act. A project screening was also completed by the Environmental Impact Screening
Committee (EISC) pursuant to the Inuvialuit Final Agreement.

The NEB is the Federal Environmental Assessment Coordinator for the Project. Fisheries and
Oceans Canada, Environment Canada, Natural Resources Canada and Transport Canada have
declared themselves as Federal Authorities, in possession of specialist advice. Pursuant to section
18(3) of the CEA Act, the NEB has determined that public participation is appropriate in the
circumstances of this project, and is requesting public review and comment on the Draft
Environmental Screening Report.

The analysis for this ESR is based on BP’s Project Description, responses to information
requests and letters of comment. This ESR identifies a number of potential adverse
environmental effects that could result in relation to the proposed Project. The main concerns
raised by the public and those of the EISC are the potential for adverse environmental effects
relating to marine mammals, marine mammal harvesting, and traditional activities.

The NEB has considered the information provided by BP, government departments, the EISC,
and the public in its review of the Project and is of the view that with the implementation of BP’s
environmental protection procedures and mitigation measures, the proposed Project would not be
likely to cause significant adverse environmental effects.

                                                 i
PROJECT IDENTIFICATION

Applicant Name:               BP Exploration Company Limited

Application Date:             25 February 2009          CEA Act Registration    4 March 2009
                                                        Date:

CEA Act Law List Trigger:     Canada Oil and Gas        CEA Registry Number:    09-01-46112
                              Operations Act 5(1)(b)

National Energy Board         OF-EP-GeopOp-B250-        Project Location        Beaufort Sea
(NEB or Board) File Number:   5554136 0201                                      (Inuvialuit
                                                                                Settlement
                                                                                Region)

Federal Environmental         National Energy Board     CEA Act Determination
Assessment Coordinator                                  Date:




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                                               TABLE OF CONTENTS


1.0    INTRODUCTION............................................................................................................. 1
       1.1       Project Overview .................................................................................................... 1
       1.2       Information Sources Used in this Environmental Screening Report ...................... 1

2.0    ENVIRONMENTAL ASSESSMENT PROCESS ......................................................... 1

3.0    RATIONALE FOR THE PROJECT.............................................................................. 2

4.0    DESCRIPTION OF THE PROJECT ............................................................................. 2
       4.1       Location .................................................................................................................. 2
       4.2       Project Timing ........................................................................................................ 3
       4.3       Project Components ................................................................................................ 3

5.0    DESCRIPTION OF THE ENVIRONMENT................................................................. 5
       5.1       Traditional Land Uses............................................................................................. 5
       5.2       Biophysical Conditions........................................................................................... 6

6.0    CONSULTATION ............................................................................................................ 8
       6.1       Project-Related Issues Raised in Comments Received by the NEB....................... 8
       6.2       Project-Related Issues Raised through Consultation Conducted by BP................. 9
       6.3       Project-Related Issues Identified by the Environmental Impact Screening
                 Committee............................................................................................................... 9
       6.4       Involvement of other Federal Authorities pursuant to the CEA Act .................... 10

7.0    METHODOLOGY OF THE NEB’S ENVIRONMENTAL ASSESSMENT............ 10

8.0    ENVIRONMENTAL EFFECTS ANALYSIS.............................................................. 11
       8.1       Project - Environment Interactions ....................................................................... 11
       8.2       Potential Adverse Environmental Effects............................................................. 14
                 8.2.1 Analysis of Potential Adverse Environmental Effects to be Mitigated
                         through Standard Measures....................................................................... 14
       8.3       Cumulative Effects Assessment............................................................................ 17
       8.4       Follow-Up Program .............................................................................................. 18

9.0    THE NEB’S CONCLUSION ......................................................................................... 18

10.0   NEB CONTACT ............................................................................................................. 19




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1.0 INTRODUCTION

   1.1      Project Overview
BP Exploration Company Limited (BP) is proposing to gather two and/or three dimensional (2D
and 3D, respectively) seismic data within open waters of the Beaufort Sea, in the Inuvialuit
Settlement Region (ISR). The project is proposed to be conducted during the 2009 open water
season (July though to October), and if required within the same period in 2010. The project
would include the use of seismic arrays, support vessels, icebreaker support, helicopter and
fixed-wing aircraft support, and associated re-supplying activities. Both the 2D and 3D seismic
programs would utilize the same equipment.

Section 4.0 of this Environmental Screening Report (ESR) provides further detail regarding the
proposed activities associated with the Project.

   1.2      Information Sources Used in this Environmental Screening Report
This ESR is based on the information from the following sources:

   •     BP Exploration Company Limited’s Project Description
   •     Supplementary filings to the Project Description including Support Vessel Update and
         updated Acoustic Modeling of Underwater Noise (JASCO Research, Appendix B of the
         Project Description)
   •     Information received from the public (comments from the public are discussed further in
         Section 6.1)
   •     Information received from Federal and Territorial Departments, including a letters of
         comment from the Government of Northwest Territories Department of Environment and
         Natural Resources, Fisheries and Oceans Canada, and Environment Canada
   •     BP’s response to information received from the public
   •     BP’s responses to Information Requests
Information filed with the NEB, pertaining to the environmental assessment can be found on the
NEB website (www.neb-one.gc.ca), by following the Public Registries/Anticipated Applications
link.


2.0 ENVIRONMENTAL ASSESSMENT PROCESS
The application for the project was filed pursuant to section 5(1)(b) of the Canada Oil and Gas
Operations Act (COGOA) which triggers the CEA Act Law List Regulations, thereby requiring
the preparation of this ESR.

Pursuant to the CEA Act Regulations Respecting the Coordination by Federal Authorities of
Environmental Assessment Procedures and Requirements, the NEB coordinated responsible



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authority (RA)/federal authority (FA) involvement in the CEA Act process by sending out a
letter of Federal Coordination Notice to:

   •     Transport Canada
   •     Environment Canada
   •     Department of Fisheries and Oceans Canada (DFO)
   •     National Defence Canada
   •     Natural Resources Canada
   •     Parks Canada
   •     Health Canada
   •     Canadian Transportation Agency
   •     Indian and Northern Affairs Canada

The NEB is the Federal Environment Assessment Coordinator (FEAC) for this project.

Transport Canada, Natural Resources Canada, Environment Canada, and the DFO indicated that
they were in possession of specialist or expert information necessary to conduct the
environmental assessment for the Project.

Pursuant to section 18(3) of the CEA Act, the NEB has determined that public participation is
appropriate in the circumstances of this project. The NEB has posted a scope of the assessment,
and is providing the public with an opportunity to examine and comment on this draft ESR.


3.0 RATIONALE FOR THE PROJECT
The purpose of the project would be to gather seismic data over and in the vicinity BP’s
Exploration Licenses (ELs) 449, 451 and 453. The evaluation of the seismic information would
be used to improve geological knowledge of the ELs and identify potential hydrocarbon
reservoirs that may be used to identify potential targets for future exploratory drilling programs.


4.0 DESCRIPTION OF THE PROJECT
The NEB considers the scope of the project to be the proposed seismic operations related to
hydrocarbon exploration in the Beaufort Sea within the Inuvialuit Settlement Region (ISR),
Northwest Territories.

   4.1      Location
The project would be located approximately 180 km north of Tuktoyaktuk, Northwest
Territories, in open waters of the Beaufort Sea, within the ISR. BP identifies that the priority
areas for the acquisition of seismic data would be in the vicinity of EL 449 and EL 451, covering


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a total area of approximately 2800 km2 (please refer to the Project Location map on Page ii of
this ESR), in water depths of 60 m to 1300 m.

Should weather or ice conditions not permit the collection of data over the priority areas, seismic
data would be collected in the adjacent areas totaling 11,040 km2 for 3D seismic area of
operation or 21,256 km2 for the 2D seismic area of operation. The 2D program would be
implemented on and in the vicinity of BP’s EL 449, 451 and 453, and would extend beyond the
proposed 3D area of operation. Water depths associated with the 3D area of operations are 50 m
to 1700 m, and 25 m to 1700 m for the 2D area of operations. Collectively, the delineated areas
of seismic activity are identified as the “area of operation.”

Support vessel activities would take place on the route between Tuktoyaktuk and the area of
operation. Herein, the “Project area” is considered the seismic area of operation and the supply
route between Tuktoyaktuk and the area of operation.

    4.2      Project Timing
The survey is proposed to be conducted during the 2009 open water season (July though to
October), and if required within the same period in 2010.

    4.3      Project Components
The project would include the use of seismic arrays, hydrophones, support vessels, icebreaker
support, helicopter and fixed-wing activities, and associated re-supplying activities. Both the 2D
and 3D seismic activities would utilize the same equipment.

There would be no physical works associated with construction, operation, decommissioning, or
abandonment related to the project. The following activities comprise the “Project”:

                                        Description of Physical Activities
Seismic Data Acquisition:
   Two source arrays, containing up to 24 active airguns each (48 total) would be towed behind a seismic vessel to
   generate sound energy. Each airgun array would consist of three sub-arrays (8 airguns on each sub-array).
   Each array would discharge alternately every 12 to 15 seconds, and would operate 24 hrs per day, pending
   visibility constraints.
   The airgun volumes would range from 70 in3 to 330 in3, with each array having a total volume of 4450 in3.
   The airguns would produce sound energy that can be measured in decibels (dB). The peak sound pressure level
   from the Pokak seismic array would be approximately 255 to 261 dB at a distance of 1 m from the array, and
   would consist of low frequency broadband impulses (<1000 Hz). Sound levels from the arrays would drop
   rapidly with distance away from the source, and sound energy traveling horizontally away from the arrays would
   be less than those traveling vertically.
   Up to ten streamers would be towed behind the seismic vessel, each containing positioning transceivers and
   hydrophones that would receive and record sound data.
   Streamers are filled with solid polyurethane foam and towed at a depth of 6 to 9 m below the ocean surface.
   Streamers would be separated horizontally by up to 200 m and would extend approximately 7 km behind the
   vessel for 3D data collection and up to 9 km behind the ship for 2D data collection.
   Up to six ocean bottom hydrophones would be deployed on the seafloor to record seismic data. Ocean bottom



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                                          Description of Physical Activities
   hydrophones would be deployed with a cast iron or concrete anchor that would remain in place following
   hydrophone retrieval.


Seismic Vessel Travel and Operations:
   The proposed seismic vessel, CGGVeritas Viking Vision, is an ICE-C class vessel.
   The proposed seismic vessel measures 105 m long and 24 m wide, has a draft of 9.15 m, and would
   accommodate a crew of 70 persons. The seismic vessel would operate at a cruising speed of 14 knots when
   mobilizing to and demobilizing from the area of operations, and would operate at a maximum speed of 4.5 knots
   when acquiring seismic information.
   Approximately 6 to 10 m3 of solid waste would be generated per month onboard the Viking Vision. Waste
   suitable for incineration would be incinerated on board, and the ashes from incinerated waste and hazardous
   waste not incinerated would be stored for disposal at an approved waste facility outside of the Beaufort Sea
   region. Kitchen waste would be macerated and discharged from the vessel at a minimum distance of 12 nautical
   miles from any reef or coastline.
   The seismic vessel would mobilize to the Beaufort Sea via Vancouver and Alaska, and demobilize from the
   Beaufort Sea by way of Point Barrow, Alaska.
Support Vessel and Aircraft Operations:
   An icebreaker may be used to accompany the support and seismic vessel from Alaska in the Canadian Beaufort
   Sea.
   A picket vessel would be used to scout for the seismic vessel and identify ice hazards. The picket vessel would
   generally not accompany the seismic vessel and has a capacity of 16 persons.
   A supply vessel would be used for the re-supply of equipment and fuel, for the seismic vessel and picket vessel,
   and would transition between Tuktoyaktuk and the area of operation.
   Solid waste (excluding food scraps) generated by the supply and picket vessels would be disposed of at onshore
   facilities in Tuktoyaktuk.
   Fixed wing aircraft may be used to support program activities by monitoring ice conditions prior to and during
   operations. A helicopter would be available for use to respond to emergencies and for crew changes.


Fuel Storage and Refueling Activities:
   The Viking Vision has a fuel capacity of approximately 2,900 m3 and consumes 40 m3 of fuel per day.
   Fuel would be supplied to the seismic vessel by the supply vessel. The refueling activities would take place at
   sea, approximately every two weeks.
   Marine diesel fuel would be supplied to the supply vessel from a stationary single-hulled barge located in the
   Tuktoyaktuk harbour.
   The supply vessel would be refueled from a shore based tank in Tuktoyaktuk harbour.




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                                          Description of Physical Activities
Environmental Monitoring:
   Marine Mammal Observers (MMOs) would be stationed on the seismic vessel and supply vessel. The role of
   MMOs on the seismic vessel is to identify the presence of marine mammals (including polar bears) that may
   occur within the safety radii of the seismic vessel. The MMOs would shut down (or delay the start-up of)
   seismic activities in the event of marine mammal observations within the safety radii of the seismic vessel, and
   would shut-down the seismic array if the safety radii cannot be observed by the MMOs in recurring bowhead
   feeding/aggregation areas as defined by DFO.
   If the picket vessel is transitioned in to the role of supply vessel, MMOs would be stationed on the picket vessel.
   MMOs onboard the supply vessel would monitor and record information on marine mammals observed and
   monitor the interactions of the supply vessel with traditional harvesting activities.
   Passive Acoustic Monitoring (PAM) of marine mammals would be initiated as a field trail by BP to monitor the
   presence and detection of Arctic marine mammals. The PAM system would involve a string of hydrophones
   towed behind the supply vessel which would interface with software systems that would listen for and detect
   marine mammal vocalizations. Approximately three weeks of testing would take place with the PAM system.


Non-Seismic Data Collection Activities:
   Oceanographic data (water temperature, conductivity, sound velocity, and current velocity) would be collected
   using expendable sound velocimeters that would be deployed weekly.
   Bathymetric data would be collected on EL areas using multi-beam echosounders, which would collect
   information on seafloor topography.
   Gravity data would be collected on board the Viking Vision using a gravity meter.




5.0 DESCRIPTION OF THE ENVIRONMENT

    5.1      Traditional Land Uses
Traditional harvesting activities and other land uses have been defined through Community
Conservation Plans (CCPs) developed in each of the six Inuvialuit communities (Inuvik,
Uluhaktok, Sachs Harbour, Tuktoyaktuk, Aklavik, and Paulatuk). The seismic operations overlap
the CCP site 313C (winter seal and polar bear harvesting area), and the supply vessel travel
corridor would overlap with sites 307C, 310C, 311C, 312C, 712C, and 714CDE (summer fishing
area, fall fishing area, fall seal harvesting area, fall goose harvesting area, Beluga Management
Zone 2, and Kugmallit Bay, respectively).

All of the preceding areas are designated as Category C in the CCPs. Category C lands are
defined in the CCPs as: “lands and waters where cultural or renewable resources are of
particular significance and sensitivity during specific times of the year. These lands and waters
shall be managed as to eliminate, to the greatest extent possible, potential damage and
disruption.”

The offshore areas are identified as important summer habitat for whales, seals, waterfowl and
fish that are harvested by the Invualuit. Nearshore subsistence harvesting takes place for fish,
ducks, and geese, and harvesting of beluga takes place in the nearshore shallow waters of
Kugmallit Bay, generally in July. The re-supply route could also overlap with caribou harvesting
areas that are accessed from the ice in the vicinity of Tuktoyaktuk harbour.

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   5.2      Biophysical Conditions
         Marine Environment

The Project is characterized by Arctic climatic conditions, which is dominated by the Beaufort
Gyre, a system of atmospheric and regional ocean waters that circulates in a clockwise direction.
Ocean waves in the Beaufort Sea are mild compared to other Canadian offshore areas, average
wave heights for August and September are 0.95 m and 1.36 m respectively, with smaller wave
heights generally occurring earlier in the season and larger waves occurring later in the season as
the extent of open water area increases.

Water depths range from 70 m to 1050 m in the southern and northern extent of the Project area
of operations, respectively. Sea ice is present in the Project area, and an open water period ranges
from mid-June to mid-October, although there is considerable inter-annual variability.

Sub-marine topography includes the Mackenzie Shelf, which is a portion of the Continental
Shelf, located approximately 100 – 150 km offshore, of which water depths are up to 100 m. The
Project area of operations includes the Mackenzie Trough, which cuts into the Continental Slope
at approximately 500 m deep and extents to within 50 km of the Mackenzie River. The Project
area of operations includes portions of the Mackenzie Shelf but is primarily located over the
Continental Slope.

         Marine Mammals

Marine mammals that may be present include: bowhead whales (a baleen whale), beluga (a
toothed whale), narwhals, ringed and bearded seals, and polar bears. Presence of whales is
limited primarily to the open water season, while polar bears and seals are present year-round.

Bowhead whales within the Project area are part of the Bering-Chukchi-Beaufort (BCB)
population, which is the largest of the five separate bowhead stocks identified in the Arctic,
numbered at approximately 13,300. Bowhead whales migrate in and out of the Canadian portions
of the Beaufort Sea annually, as most bowhead whales winter in the Bering Sea, and use areas of
the Beaufort Sea primarily for feeding activity during the open water season. Bowhead whales
may aggregate during feeding activity in the Beaufort Sea as a reflection of increased prey
(copepods) density. Analysis of aerial survey data has indicated that ‘clumps’ of increased
bowhead density occurred in two out of seven years of non-consecutive surveys in the Project
area of operations. The DFO has identified the presence of many feeding/aggregation areas in the
past 25 years in the Beaufort Sea. A potential feeding/aggregation area (approximately 40 km x
120 km), as delineated by the DFO, occurs within the 2D area of operation.

Bowhead whales generally produce calls including tonal moans, pulsive sounds, and songs that
are tonal frequency modulated sounds in the range of 50-400 Hz, likely as a means to maintain
communication and stay in synchrony when feeding, traveling or socializing. Dominant
frequencies produced are 100-400 Hz for tonal moans, and <4000 Hz for songs. Calls during
migrations can include average sound levels of 151 +/- 9.5 dB at 1 m, and up to 180-189 db at
1 m. Audiograms are not available for bowhead whales specifically, however, baleen whales


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collectively have a hearing range of 7 Hz to 22 kHz, although the most sensitive range of
bowhead hearing range can be likely be inferred indirectly from vocalizations sound
characteristics.

Belugas within the Project area are part of the Eastern Beaufort Sea (EBS) population,
numbering more than 39,000 in 2004. The Project would overlap with the Beluga Management
Plan Zones 2 and 3 (known whale migration and aggregation areas) identified in the Beluga
Management Plan for the Beaufort Sea by the Fisheries Joint Management Council, the Hunter
and Trapper Committees, and the DFO. The supply route traverses eastern areas of Kugmallit
Bay; Beluga Management Plan Zone 1a is located on the eastern portions of Kugmallit Bay and
is the primary area for harvesting beluga, which takes place primarily in July.

Beluga are a highly vocal species that use calls to detect predators, socialize, and for navigation.
Sounds produced by belugas include tonal whistles, pulsed sounds for echolocation, cries, grunts
and barks. Belugas may remain in acoustic contact over ranges of 300-500 m. Belugas are
capable of echolocation, which involves pulsed sounds of high source level clicks of up to 225
dB. Echolocation frequencies are typically within the 40-60 kHz range, but pulses may range up
to 100-120 kHz. Belugas have extremely acute hearing within the mid-frequency range, with
most sensitive hearing between 32-108 kHz.

The occurrence of polar bears in the Project area is limited to the ice-covered seasons, and as
such the presence of polar bears is not expected to overlap temporally with the Project, although
polar bears may be sighted near multi-year ice that may occur near to the Project area of
operations. Ringed and bearded seals are a crucial prey source in the diet of polar bears, and
seals are hunted by polar bears during the ice-covered seasons. Ringed seals are believed to be
more abundant than bearded seals; the former numbers more than 650,000 in the western Arctic.

       Fish and Invertebrates

Seventy-one fish species have been documented in the Beaufort Sea, the majority of which are
marine rather than freshwater species. Common species in nearshore waters include fourhorn
sculpin, Arctic and starry flounder, saffron cod, pacific herring, and Arctic cod. The Arctic cod is
considered a critical link in Arctic food chains. In water depths up to 100 m, Arctic cod and
Pacific herring are the most abundant. Fish species presence at deeper water depths is less
certain, with Artic cod, polar cod, eelpouts, alligator fish, sculpins, lump fish, Greenland halibut,
and thorny skate potentially being present.

Invertebrates in the Project area would include zooplankton (copepod, insects) and benthos
(molluscs, crustaceans) that may include crabs, sea urchins, starfish, brittle star, whelks, cockles,
and scallops.

       Marine Birds

The coastal and offshore areas of the Beaufort Sea are important habitats for many bird species,
included species of ducks, geese, swans, loons, gulls, jaegers, murres, guillemots, and shorebirds.
Offshore leads and polynyas, and coastal bays are especially important for moulting and staging
areas, and nearshore areas are important foraging areas for nesting and brood-rearing birds.



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Offshore areas may be used for fall, post-moult migrations by several seabirds such as king and
common eiders.



Species At Risk

The following species have been identified as being “At Risk” and listed in the Species at Risk
Act or by the Committee on the Status of Endangered Wildlife in Canada (COSEWIC).

                                           COSEWIC
Species               Scientific Name                        SARA Status         SARA Schedule
                                           Designation

Ivory gull            Pagophila eburnea    Endangered        Special Concern     Schedule 1

Ross’s gull           Rhodostethia rosea   Threatened        Threatened          Schedule 1

                      Anarhichas
Northern wolffish                          Threatened        Threatened          Schedule 1
                      denticulatus

Bowhead whale         Balaena mysticelus   Special Concern   Special Concern     Schedule 1

Polar bear            Ursus maritimus      Special Concern   Special Concern     Schedule 3




6.0 CONSULTATION

    6.1       Project-Related Issues Raised in Comments Received by the NEB
The NEB received a letter from Ecojustice on behalf of the World Wildlife Fund Canada (WWF
Canada) regarding BP’s proposed project and other similar projects in the Beaufort Sea. WWF
Canada also requested that the NEB provide for public participation in the review of the
application under section 18(3) of the CEA Act. The comments submitted by WWF Canada
include concerns related to:

    •     marine mammal hearing damage;
    •     change to marine mammal health;
    •     changes to marine mammal habitat use;
    •     masked communication by marine mammals;
    •     alteration of marine mammal migration routes and displacement from feeding areas;
    •     disturbance of marine mammals due to aircraft flight; and
    •     the adequacy of current mitigation to prevent impacts to marine mammals.




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No other public comments have been received by the NEB to date. This draft ESR will be
released for public comment and available through the Canadian Environmental Assessment
Agency Registry and the NEB Public Registry.

   6.2       Project-Related Issues Raised through Consultation Conducted by BP
BP held consultation activities in each of the six communities (Inuvik, Uluhaktok, Sachs
Harbour, Tuktoyaktuk, Aklavik, and Paulatuk) from 11 November 2008 to 26 November 2008.
The issues and concerns discussed included comments related to:

   •     effect of the seismic operations on marine mammals, fish, and invertebrates;
   •     effects of the support vessel activities on traditional harvesting activities;
   •     emergency response procedures and the potential of accidents and spills;
   •     business and employment opportunities related to the project; and,
   •     concerns relating to management of waste, wastewater, and ballast water.


From 22 September, 2008 to 20 January 2009, BP consulted with representatives from
Environment Canada, the DFO, Natural Resources Canada, Indian and Northern Affairs Canada,
the Government of the Northwest Territories Department of Environment and Natural Resources,
the Inuvialuit Regional Corporation, the Fisheries Joint Management Committee, the Inuvialuit
Game Council, and the NEB.

   6.3 Project-Related Issues Identified by the Environmental Impact Screening
   Committee
BP submitted to the NEB the results of the Project screening completed by the Environmental
Impact Screening Committee (EISC). The EISC identified that the main environmental issue of
concern was whether the seismic operations could have a significant negative impact on
bowhead and beluga whales. The EISC reviewed the Project Description and concluded that the
proposed development, if authorized subject to the following condition recommended by the
EISC, will have no significant negative impacts on the environment of on Inuvialuit wildlife
harvesting in the Inuvialuit Settlement Region, pursuant to the Inuvialuit Final Agreement
(Section 11(17)b). The EISC decision letter dated 1 April 2009 made the following
recommended condition:

“MMOs are employed on the picket vessel in order to assist in the identification or confirmation
of bowhead feeding areas and to document the presence of marine mammals along the transit
route between the PAAs and Tuktoyaktuk.”

The EISC identified that having the MMOs onboard the picket vessel would be a prudent
additional mitigation measure, given the importance of identifying and confirming the locations
of bowhead feeding areas for implementation of mitigation measures, especially for travel within
the 2D area of operations.




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The EISC identifies that it utilized the advice received from the DFO, the Government of the
Northwest Territories Department of Environment and Natural Resources, and the Fisheries Joint
Management Committee in reaching its decision. The EISC noted that the developer may need to
complete the proposed seismic program in 2010, and has committed to employing the same
mitigation measures in 2010 if the additional field season is required.

   6.4     Involvement of other Federal Authorities pursuant to the CEA Act
Environment Canada, the Government of the Northwest Territories Department of Environment
and Natural Resources, and DFO submitted letters of comment to the National Energy Board
regarding the Project. The letters of comment can be found on the NEB’s Public Registry for the
Project.


7.0 METHODOLOGY OF THE NEB’S ENVIRONMENTAL ASSESSMENT

Scope of the factors that were considered:
In conducting the environmental screening, the Board considered the factors set out in
paragraphs 16(1) (a) through (d) of the CEA Act.

Methodology of the analysis:
In assessing the environmental effects of the Project, the NEB used an issue-based approach
taking into consideration the information sources identified in section 1.2 of this ESR. In its
analysis within Section 8.1, the NEB identified interactions expected to occur between the
proposed project activities and the surrounding environmental elements. Also included were the
consideration of potential accidents and malfunctions that may occur due to the Project and any
change to the Project that may be caused by the environment. If there were no expected
element/Project interactions then no further examination was deemed necessary. Similarly, no
further examination was deemed necessary for interactions that would result in positive or
neutral potential effects. In circumstances where the potential effect was unknown, it was
categorized as a potential adverse environmental effect.

Section 8.2.1 provides an analysis for all potential adverse environmental effects that are
normally resolved through the use of standard design or routine mitigation measures. In these
cases, mitigation measures are outlined or explanations are provided as to why mitigation
measures are not required. Section 8.3 addresses cumulative effects, and Section 8.4 addresses
follow-up programs.




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                 8.0 ENVIRONMENTAL EFFECTS ANALYSIS

                   8.1         Project - Environment Interactions

                                                   Project                                                     Type of
                                                    Inter-            Description of Interaction              Potential
                     Environmental Element                                                                                Potential Adverse Environmental Effect
                                                   action?              (How, When, Where)                      Effect
                                                   Y/N/U                                                      P/Ntl/Adv
                 Air Quality                         Y       Release of emissions from the onboard              Adv       Decrease in local ambient air quality.
                                                             incinerator and from vessel engines
                 Marine Mammals (bowhead whale,      Y       Aircraft noise, boat noise, and seismic airgun     Adv       Hearing damage (either permanent or
                 beluga, seals, and polar bears)             array operations may interact with marine                    temporary) may result if marine mammals were
                                                             mammals through sensory and physical                         located in very close proximity to the full
                                                             disturbance                                                  airgun array discharge (<20 m). This situation
                                                                                                                          is unlikely as marine mammals generally avoid
                                                                                                                          areas in which seismic sound energy is
                                                                                                                          uncomfortable.
                                                                                                                          Masked communication may occur if the
                                                                                                                          presence of sound energy coincides with
                                                                                                                          vocalizations by marine mammals so that
                                                                                                                          mammal vocalizations are undetectable. BP
  Bio-physical




                                                                                                                          identifies that if present, masked
                                                                                                                          communications would likely impact <1% of
                                                                                                                          the bowhead whale populations.
                                                                                                                          Behavioral changes could result if acoustic
                                                                                                                          disturbance resulted in changes in time spent
                                                                                                                          feeding or nursing by marine mammals.
                                                                                                                          Change in habitat use including alteration of
                                                                                                                          migration routes and/or displacement from
                                                                                                                          feeding areas may occur as migrating bowhead
                                                                                                                          whales have shown seismic activity avoidance
                                                                                                                          in shallow water by up to 20 km, and feeding
                                                                                                                          bowheads may avoid seismic activity by up to
                                                                                                                          7.2 km.
                                                                                                                          Assuming a 160 dB sound source results in
                                                                                                                          temporary habitat avoidance by bowheads
                                                                                                                          during feeding, avoidance of the array may

                                                                                        11
BP Exploration Pokak 3D Seismic Program                                                                NEB Environmental Screening Report


                                  Project                                                   Type of
                                   Inter-           Description of Interaction             Potential
     Environmental Element                                                                             Potential Adverse Environmental Effect
                                  action?             (How, When, Where)                     Effect
                                  Y/N/U                                                    P/Ntl/Adv
                                                                                                       extend to approximately 8 km in waters 500 m
                                                                                                       in depth, and 9 km in 200 m water depths
                                                                                                       Belugas are thought to strongly avoid seismic
                                                                                                       activity by 7 to 20 km.
                                                                                                       Alteration of a group distribution could occur if
                                                                                                       acoustic or vessel disturbances impacted
                                                                                                       whales near to feeding/aggregation areas.
                                                                                                       Change in animal health could result from
                                                                                                       Project activities due to increased mortality risk
                                                                                                       (whale strikes), hearing loss or damage, and
                                                                                                       increased stress responses.
 Marine Birds                       Y       Effects of aircraft noise, boat noise, and       Adv       Sensory disturbance to marine birds may result
                                            seismic airgun array operations may impact                 from Project activities, and may result in
                                            marine birds through sensory disturbance and               avoidance of Project vessels and aircraft, and
                                            physical disturbance                                       potential increase in mortality.
                                                                                                       Alteration of a group distribution could occur
                                                                                                       from a vessel disruption.
 Marine Fish and Fish Habitat       Y       Effects of aircraft noise, boat noise, and       Adv       Sensory disturbance to fish may occur due to
                                            seismic airgun array operations may impact                 Project activities, and may result in avoidance
                                            fish through sensory disturbance                           of project vessels and fish habitat.
 Invertebrates                      Y       Effects of aircraft noise, boat noise, and       Adv       Sensory disturbance to invertebrates may occur
                                            seismic airgun array operations may impact                 due to Project activities, and may result in
                                            invertebrates through sensory disturbance                  behavioural, physiological, or pathological
                                                                                                       effects.
 Water Quality and Quantity         Y       Discharge of macerated food waste and            Adv       Deposition of macerated food, sewage, or gray
                                            sewage >12 nautical miles from shore                       water may result in adverse effects to water
                                            Discharge of treated grey water from the                   quality.
                                            vessel
 Species At Risk                    Y       Effects of aircraft noise, boat noise, and       Adv       Potential adverse effects to bowhead whales
                                            seismic airgun array operations may impact                 and polar bears are noted above under Marine
                                            Species designated as At Risk through                      Mammals.
                                            sensory and physical disturbance                           Potential adverse effects to ivory gull and


                                                                      12
BP Exploration Pokak 3D Seismic Program                                                                                                                   Draft Environmental Screening Report


                                                                  Project                                                         Type of
                                                                   Inter-                Description of Interaction              Potential
                          Environmental Element                                                                                                    Potential Adverse Environmental Effect
                                                                  action?                  (How, When, Where)                      Effect
                                                                  Y/N/U                                                          P/Ntl/Adv
                                                                                                                                                   Ross’s gull are noted above under Marine
                                                                                                                                                   Birds.
                                                                                                                                                   Potential adverse effects to northern wolffish
                                                                                                                                                   noted above under Marine Fish.
                    Heritage Resources                               N         No interaction with cultural or heritage             n/a      n/a
                                                                               resources is apparent due to the offshore
                                                                               nature of the activities
  Socio-Economic




                    Traditional Land and Resource Use                Y         Nearshore supply vessel activities have the         Adv             Potential disturbance to traditional land use and
                                                                               potential to overlap with harvesting of                             harvesting activities through ice damage and in
                                                                               beluga, seals, fish, and waterfowl.                                 the Tuktoyaktuk harbour.
                                                                               Offshore Project activities would not overlap                       Potential disturbance traditional land use and
                                                                               or interact with traditional and subsistence                        harvesting activities during supply vessel
                                                                               harvesting activities.                                              activities in nearshore waters.
                    Human Health/ Aesthetics                         N         No interactions                                      n/a      n/a
                    Accidents/Malfunctions                           Y         Accidents and spills would have the potential       Adv             Adverse changes to ecosystem process and
                                                                               to release hydrocarbons into the marine                             marine life presence due to spills or accidents,
                                                                               environment through loss of fuel                                    depending upon the spill or accident
                                                                               containment of the fuel supply tanker or fuel                       characteristics.
                                                                               storage barge, or through fuel loss during
                                                                               fuel transfer operations.
  Other




                    Effects of the Environment on the                U         The potential exists for the environment to          N        n/a
                    Project                                                    interact with the Project through the
                                                                               occurrence of severe weather or ice presence
                                                                               that may limit the accessibility of the seismic
                                                                               vessel or force the Project vessels to seek
                                                                               shelter in a sheltered bay (Thetis Bay at
                                                                               Herschel Island).
                   Legend: Y (Yes); N (No); U (Uncertain); P (Positive); Ntl (Neutral); Adv (Adverse)




                                                                                                           13
BP Exploration Pokak 3D Seismic Program                                    Draft Environmental Screening Report




    8.2       Potential Adverse Environmental Effects

8.2.1    Analysis of Potential Adverse Environmental Effects to be Mitigated through
Standard Measures

    Potential Adverse
                                              Proposed Standard Design or Mitigation Measures
   Environmental Effect
Decrease in local ambient air       BP would comply with the Regulations for the Prevention of Pollution from
quality                             Ships and for Dangerous Chemicals (2007) for the operation of the onboard
                                    incinerator
Sensory and physical            Mitigation through Project Design
disturbance to marine               The seismic vessel would avoid recurring bowhead feeding/aggregation areas
mammals from vessel,                as identified by DFO when travelling to and from the Pokak seismic area of
aircraft, and airgun array          operations.
noise resulting in potential:
                                    Identification of bowhead feeding/aggregation areas would also take place by
    Hearing damage                  the DFO during aerial surveys in 2009 and those identified areas would be
    Masked communication            used to revise the delineation of bowhead feeding/aggregation areas used by
    Behavioural changes             BP for restricted operations.
    Change in habitat use           Vessels would not travel through Beluga Management Zone 1a.
    including alteration of
    migration routes and/or     Mitigation through Project Procedures
    displacement from
    feeding areas                   A flying altitude restrictions of >400 m would be in place for supporting
                                    aircraft operations, except for takeoff and landing, to minimize the effects of
    Alteration in group             aircraft disturbance to marine mammals.
    distribution
                                    Vessel speeds would be limited to a maximum of <14 knots when traveling to
    Change in animal health         and from the area of operations, and limited to 4.5 knots when collecting
                                    seismic data. The speed restriction would be expected to minimize of the
                                    likelihood of whale strikes.
                                    Vessels would adhere to the use of existing shipping routes in Beluga
                                    Management Zones.
                                    The Project would adhere to the Statement of Canadian Practice with respect to
                                    Mitigation of Seismic Sound in the Marine Environment’ (2007, hereafter “the
                                    Statement of Practice”), with the exception of sections 11 and 12 of the
                                    Statement of Practice, which speaks to the use of Passive Acoustic Monitoring
                                    (PAM). Passive Acoustic Monitoring would be employed as a field trial by BP
                                    to determine its effectiveness at bowhead whale locations within the Arctic,
                                    although it would not be used as a mitigation measure.
                                    Marine Mammals Observers (MMOs) would be on board the seismic vessel
                                    and supply vessel and would continuously monitor for the presence of marine
                                    mammals during daylight hours. If an MMO observed a marine mammal or
                                    polar bear within the designated safety radius of the seismic array, the airgun
                                    sound source would be shut down immediately. The safety radii used for the
                                    Project would vary with water depth and would be as follows:

                                          Water depth            Safety Radii
                                       <100 m                1860 m
                                       100 m to 400 m        1990 m
                                       >400m: 1050 m         1050 m




                                                        14
BP Exploration Pokak 3D Seismic Program                               Draft Environmental Screening Report



   Potential Adverse
                                          Proposed Standard Design or Mitigation Measures
  Environmental Effect
                               If airgun operations were shut down due to the presence of a marine mammal,
                               operations would only resume if they are not sighted again for a period of 30
                               minutes, or following visual confirmation that any marine mammal observed
                               had left the safety radius. While detection of marine mammals by MMOs is
                               likely not 100% effective, it is endorsed by the Statement of Practice, and
                               training programs would be conducted all MMOs to increase the effectiveness
                               of the mitigation technique.
                               Startup procedures for airgun operations would include ‘ramping up’ of the
                               airgun array such that the smallest airgun would be activated first and
                               additional airguns would be added gradually over a period of 20 minutes until
                               the full operation levels are reached. Ramp-up procedures would commence
                               only after a 30 minutes survey of the full safety radius has determined that
                               there are no whales in the safety zone. Ramp-up procedures are based on the
                               demonstrated avoidance by marine mammals of seismic sound sources.
                               During low visibility seismic operations, an MMO would be ‘on-call’ and
                               prepared to go on duty.
                               Ramping up procedures would be used on all occasions when the airgun source
                               is reactivated following shutdown.
                               When not collecting seismic data, if the safety radius is visible the source array
                               would be shut down completely.
                               During transitions between survey lines, the smallest airgun in the array (with
                               a volume of 70 in3) would continue to operate in periods of low visibility and
                               is intended to deter marine mammals from entering the area when MMOs
                               cannot observe the safety radius. When the smallest airgun is in use and
                               visibility is sufficient, the MMOs would implement shutdown procedures if a
                               marine mammal was observed within 150 m of the 70 in3 airgun. The 70 in3
                               airgun (termed a single source array) would not be used in bowhead
                               feeding/aggregation areas.
                               If low visibility conditions occur while the full seismic array is shut down,
                               ramp up would begin only after the entire safety zone has been observed for 30
                               minutes and no whales have entered the safety zone. If the 70 in3 airgun is
                               operating during an array shut down, ramp up could take place in low visibility
                               conditions except areas identified as feeding/aggregation areas.
                               A potential bowhead feeding/aggregation area (approximately 40 km x 120
                               km) has been identified within the 2D area of operation by DFO; no recurring
                               feeding/aggregation areas exist within the 3D area of operation. The seismic
                               vessel would implement ‘restricted operations’ when collecting data in this
                               area, such that all airguns would be shut down if the entire safety radius cannot
                               be observed by MMOs on board the vessel.
                               While no individual mitigation measure would be able to completely eliminate
                               adverse effects to marine mammals, nor would any individual measures be
                               without fault, it is understood that collectively, the mitigation measures above
                               would:
                               o    avoid critical marine mammal habitat areas;
                               o    include procedures to cease operation to prevent adverse effects;
                               o    include conservative shut-down criteria in sensitive areas for marine
                                    mammals (feeding/aggregation areas); and,
                               o    use mechanisms to deter marine mammals from entering the Project area
                                    where they may be exposed to adverse effects.



                                                   15
BP Exploration Pokak 3D Seismic Program                                 Draft Environmental Screening Report



    Potential Adverse
                                           Proposed Standard Design or Mitigation Measures
   Environmental Effect
                                Collectively, the mitigation measures would minimize the possibility of marine
                                mammals occurring in close enough proximity to the airgun discharges such
                                that they would suffer permanent or temporary hearing damage, and minimize
                                the possibility of masked communication, behavioural changes, change in
                                habitat use and alteration of migration routes and/or displacement from feeding
                                areas, alteration in group distribution, and change in animal health.
Disturbance to marine birds      A flying altitude restrictions of >400 m would be in place for supporting
and fish                         aircraft operations, except for takeoff and landing, to minimize the effects of
                                 aircraft disturbance to marine birds.
                                 Vessel speeds would be limited to a maximum of <14 knots when traveling to
                                 and from the area of operations, and limited to 4.5 knots when collecting
                                 seismic data. The speed restriction would be expected to minimize of the
                                 likelihood of bird or fish strikes.
                                 Startup procedures for airgun operations would include ‘ramping up’ of the
                                 airgun array such that the smallest airgun would be activated first and
                                 additional airguns would be added gradually over a period of 20 minutes until
                                 the full operation levels are reached. Ramping up procedures would be used on
                                 all occasions the airgun source is reactivated following shutdown.
Disturbance to marine            Ramp up of the seismic array (using the smallest airgun would be activated
invertebrates                    first and additional airguns would be added gradually over a period of 20
                                 minutes) may allow for some invertebrates- such as squid - to move away from
                                 the sound source.
Disturbance to Species At        Mitigation procedures for bowhead whales and polar bear are noted above
Risk                             within marine mammal mitigation section above.
                                  Mitigation procedures for ivory gull, Ross’s gull, and northern wolffish are
                                 noted above within marine birds and fish mitigation sections above.
Deposition of macerated         The Viking Vision is equipped with a ST 6A Super Trident sewage treatment
food, sewage and gray water     plant that would treat sewage to a residual fecal coliform count of 250/100 ml
may result in adverse effects   and would discharge treated sewage at sea. Treated sewage discharge would
to water quality.               have a residual chlorine level of 4 to 6 parts per million.
                                Grey water from shower water, sinks, and kitchen water would be treated and
                                discharged at sea. Bilge water would not be discharged at sea, and ballast water
                                would only be discharged to maintain safe operation of the vessel.
                                BP would comply with the Regulations for the Prevention of Pollution from
                                Ships and for Dangerous Chemicals (Transport Canada 2007)
Disturbance to traditional       To minimize the risk of disruption of late fall ice formation in the BP would
land use and harvesting          aim to finish Project activities prior to ice formation in Tuktoyaktuk Harbour.
activities                       Vessel movement to and from Tuktoyaktuk Harbour would occur only for
                                 refuelling and resupply activities.
                                 BP would maintain communication with the Tuktoyaktuk HTC, Inuvialuit
                                 Land Administration, and Hamlet to keep parties aware of the support vessel
                                 movement and timing of ice formation. If necessary public notices and
                                 announcements would be made to make mitigate human safety risks.
                                 BP has identified that if it were to enter Tuktoyaktuk Harbour after freeze-up,
                                 it would develop a plan to remediate ice damage in the Harbour, review the
                                 plan with the Tuktoyaktuk HTC, hire local Inuvialuit to conduct remedial
                                 work, hire local Inuvialuit to warn of public safety dangers, and whenever
                                 possible use the same track to enter and exit the Harbour to minimize the width




                                                     16
BP Exploration Pokak 3D Seismic Program                                 Draft Environmental Screening Report



    Potential Adverse
                                           Proposed Standard Design or Mitigation Measures
   Environmental Effect
                                 of disturbance.
                                 No vessels would travel through the Beluga Management Zone 1a.
                                 MMOs would monitor and report any potential interactions with traditional
                                 harvesting activities.
Adverse changes to               BP would maintain and implement emergency response and spill contingency
ecosystem process and            training and plans, and maintain containment materials and procedures on
marine life presence due to      vessels to maximize early response in the event of a spill.
spills or accidents              The supply vessel would be equipped with dry-break coupling for fuel transfer
                                 at sea.
                                 The fuel supply tanker would be Arctic class and would be accompanied by an
                                 ice breaker for higher risk portions of the journey.
                                 Outer tanks of the fuel storage barge would be emptied first to reduce risk of
                                 hull breach leading to oil spill. Fuel containment booms would be deployed
                                 around the barge.
                                 Fuel transfer activities would comply with the Arctic Waters Oil Transfer
                                 Guidelines (Transport Canada 1997).
                                 The streamers would be equipped with recovery devices in the event of
                                 breakage.


The NEB is of the view that for this Project, if BP follows the above-mentioned design and
mitigative measures, the potential adverse environmental effects identified in the Project –
Environmental Interactions table in Section 8.1 are not likely to be significant.

    8.3      Cumulative Effects Assessment
To determine the potential for cumulative effects in this assessment, the NEB has considered the
residual effects directly associated with the Project in combination with the residual effects
arising from other projects and activities that have been or that are likely to be carried out in the
vicinity of the Project. The NEB also considered the measures that would be used to mitigate
residual cumulative effects.

The potential for cumulative effects was also assessed by BP in their Project Description; further
analysis and methodology used by BP is discussed in Section 13 of the Project Description.

Additional projects that may contribute to cumulative effects include past offshore seismic
projects, the potential 2010 GX Technology Ocean Bottom Cable seismic project, the
Government of Canada and ArcticNet offshore research programs, and shipping activities
including cruise ships, community re-supply and the use of tugs and barges in the Beaufort Sea.

Considering these projects and the proposed BP Exploration Pokak 3D Seismic Program, the
following residual effects have been identified for the Project:

    •     increase in the amount of time the Project area is exposed to anthropogenic sound input;
          and,




                                                     17
BP Exploration Pokak 3D Seismic Program                         Draft Environmental Screening Report



   •     increase in the likelihood of adverse cumulative effects on the beluga and bowhead
         populations due to habitat avoidance.

Mitigation of residual cumulative effects would include the following measures, which are
intended to reduce the intensity of seismic sound propagated in the water from multiple sources:

   •     use of the mitigation measures outlined in Section 8.2.1 of this ESR;

   •     the BP and GX Technology seismic vessels would maintain a minimum separation of
         50 km between the vessels when both seismic arrays are active;

   •     where practical, the BP and GX Technology seismic vessels would not operate their
         seismic arrays simultaneously within a DFO-designated feeding/aggregation area that
         occurs within the 2D area of operations plus a 20 km buffer;

   •     use of the formal Simultaneous Operations Plan developed by CGGVeritas to identify
         vessels external to the Project that are operating in the Project area, which would be
         updated continuously and includes a communication strategy with the Chief Science
         Officer on board the CGGS Amundsen;

   •     the BP seismic vessel would establish daily contact with other vessels ensure operational
         plans are known; and

   •     the Canadian Coast Guard receives and provides daily updates on the location of vessels
         operating in the Project area.

The NEB has considered the potential for cumulative environmental effects and determined that
any potential cumulative environmental effects that are likely to result from this Project in
combination with other projects or activities that have been or will be carried out would be
temporary, reversible, and not likely to interact directly due to a planned avoidance of other
vessels and activities by the BP vessels. Therefore, it is not likely that there would be any
significant cumulative environmental effects resulting from this Project.

   8.4      Follow-Up Program
The Project and its associated activities are routine in nature. The potential adverse
environmental effects of the Project are well understood based on past projects of a similar
nature. For these reasons, the NEB is of the view that a follow-up program would not be
appropriate for this Project.


9.0 THE NEB’S CONCLUSION
The NEB is of the view that with the implementation of BP’s environmental protection
procedures and mitigation measures, as well as any conditions imposed by the NEB in any
authorization that may be granted, the Project is not likely to result in significant adverse
environmental effects.




                                                 18
BP Exploration Pokak 3D Seismic Program        Draft Environmental Screening Report



10.0       NEB CONTACT
Claudine Dutil-Berry
Secretary of the Board
National Energy Board
444 Seventh Avenue S.W.
Calgary, Alberta T2P 0X8
Phone: 1-800-899-1265
Facsimile: 1-877-288-8803
secretary@neb-one.gc.ca




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