Birtle Transmission Project Environmental Act Proposal -Wildlife and Fisheries Branch Review

The Wildlife and Fisheries Branch's previous recommendations to avoid the Spy Hill-ElliceCommunity Pasture are documented in Appendix A - Page A-39 of the proposal. The Branch still doesnot agree with the project's routing across Spy Hill-Ellice Community Pasture and all previousdiscussions on route mitigation within the pasture and comments on future monitoring and mitigationshould be considered secondary to our original position.

As previously expressed to Manitoba Hydro, we believe that regardless of minor routingamendments, the route in its entirety will still result in the loss and degradation of valuable prairie andforest habitats that support species listed under the Endangered Species and Ecosystems Act, and otherspecies of cultural and economic value. The Branch requested that Manitoba Hydro consider thefollowing as part of this project assessment and monitoring programs:

Assess the direct loss of mixed-grass prairie habitatMonitor long term changes in the use and productivity of various grassland bird species withinan appropriate zone of influence along the routeAssess/evaluate changes in the presence of birds of prey and passerine brood parasites withinthis same zone of influenceMonitor changes in the distribution of ungulate species and human access to areas currentlyutilized by these speciesProvide construction and operational mitigation options for all of the above, which include, butmay not limited to:

o Rehabilitation using native seed mixes in disturbed areaso Access restrictions and deterrents as developed by Manitoba Hydro, Manitoba

Sustainable Development, and Association of Manitoba Community Pastures staffo Installation of bird strike diverters in high risk collision areaso Installation of perch and nesting deterrents on transmission line infrastructure

The Branch also communicated that it expects that Manitoba Hydro will be required to provideoffsets in the form of habitat creation, management, and/or compensation as an Environment ActLicence condition.

Our comments below address these expectations and other concerns and inquiries on theassessment materials.

Recommended Licence Conditions:

1) If this project and its current route are permitted, then Manitoba Hydro should be required toprovide a Terrestrial Mitigation Implementation Plan that addresses habitat loss within the project area.This plan with provide offsets in the form of habitat creation, management, and/or compensation forthe valuable lands that will be impacted by the project, specifically within the Project Footprint andLocal Assessment Areas. The Wildlife and Fisheries Branch would expect that the proposed activities willinclude the following:

Active habitat management, or compensation for management within the RAA that offsets theloss of functional grassland within the PFAand LAA. This will be at an acceptable ratio for landsimpacted, as to not only maintain the quantity of high-quality grasslands in the area, but toincrease it as well. Brush mowing, burning, and other methods used to control shrub and aspenencroachment, and invasive weed control should be considered.Fencing to prevent new motorized access along the RoW on the east side of the CommunityPasture. This should include signage that communicates:

o Community Pasture Right of Access and sign-in information for resource users wishingto access the pasture.

o Educational information that addresses why unabated access is a concern in this pasturein regards to agriculture biosecurity, disturbance to wildlife, and grassland habitatprotection.

Maintaining safe, visual buffers where the RoW crosses forested habitats within the pasture.Rehabilitation using native seed mixes in disturbed areasInstallation of bird strike diverters in high-risk collision areas.Installation of perch and nesting deterrents on transmission line infrastructure

This plan should be developed through consultation with both Manitoba SustainableDevelopment and Association of Manitoba Community Pastures staff.

2) We appreciate that Manitoba Hydro has stated that the new access point on the eastern edge ofthe community pasture will be decommissioned (Chapter 7, 7.4.4.3), however we suggest that this beadded as a specific licence condition. Other large transmission project Environment Act Licences have/orwill have clauses that require the proponent to supply and install measures to limit access to theirproperty, where an access issue has been identified. In the case of this project, we are concerned thatincreased access, particularly vehicle traffic, could increase disturbance to wildlife populations anddamage habitat within Spy Hill-Ellice Community Pasture. It is recommended that Manitoba Hydro berequired to work with Manitoba Sustainable Development and the Association of Manitoba CommunityPastures (AMCP) to determine suitable ways to limit an increase in access to the pasture as result of theRoW's creation. This can include Manitoba Hydro's proposed decommissioning of construction accessroutes, and other recommendations mentioned in our Terrestrial Mitigation Implementation Plancomments above.

Section specific comments and inquiries:

Chapter 22.3.1.2 & 2.3.1.3

It appears that Manitoba Hydro has accounted for private landowner concerns about loss ofcultivated agricultural land and is proposing to install tubular steel H-frame structures through privateproperty, which reduces the RoW width to 54 m. It also makes specific mention that RoW widths will bereduced to 40 m on private land. Given the environmental concerns that have been expressed by theBranch and others, we'd expect that design adjustments would also be made to accommodate for ourconcerns over direct habitat loss from tower footprints, and potential effects of an increase RoW width

on various wildlife species. Please explain why lattice structures and larger RoW widths are proposed onCrown land, rather than the tubular structures and narrower RoW used on private land.

Chapter 5 & Biophysical Technical Report

Were are concerned that point counts and sharp-tailed lek counts were conducted only duringspring/summer 2017, after it was already determined that the preferred route would traverse Spy Hill-Ellice Community Pasture (albeit the exact routing within was not determined). Baseline surveysidentified numerous leks within 1000 m of the RoW, and listed grassland songbirds at several locationswithin close proximity to the row.

Why was only the Community Pasture portion of the route systematically surveyed for sharp-tailed grouse leks? Were leks identified outside of the Community Pasture during waterfowl aerialsurveys conducted on the same day, or through other methods? Given the statements about grousebeing vulnerable to predators from creation of perching sites/disturbance, it would be useful to knowhow much effort was made to determine how many lek sites were locate along the RoW outside of thepasture.

Mammals

Were any black bear, badger or other furbearer dens observed during the 2017 ground trackingsurveys?

Was any consideration give to assessing ungulate calving activity along the route during baselinefield surveys?

Chapter 7

Table 7 -1Marshalling yards and borrow sources could interact with the ecological environment,

depending on location. This should be included in the table, and proposed locations identified in theConstruction Environmental Protection Plan.

Clearing activities could affect grasslands due to rutting, compaction, non-native and invasivespecies spread, and other disturbances caused during not only machinery mobilization but clearingactivities within forest-grassland transition zones as well. This should be included in the table.

7.4.3.1While we understand that a process was followed based on a combination of previous studies

and recommendations, most of our comments provided for section 7.4.3 illuminate our concern withselecting only one grassland bird species as and indicator species for the effects assessment. Regardlessof the basis of the effect assessment, we feel that monitoring and mitigation should not revolve arounda sole species since densities, habitat requirements, and potential effects will vary between species.

Relevant project interactions should have included the potential for increase/establishment ofinvasive species due to construction activities.

The avoidance ofthe transmission line, not just movement near or across it, due to an increasein edge and raptor presence should have been included as a possible interaction.

7.4.3.3liAs outlined in Table 5-2 there are 61.5 ha of grassland/rangeland habitat in the PFA, the area subjectto direct disturbance as a result of the Project. Less than 1% (0.2%) of 7-47 the 32,648.7 ha ofgrassland/rangeland habitat in the RAA and 1.4% of the 4,387.0 ha grassland/rangeland habitat in theLAA will be affected. There will be permanent loss of grassland/rangeland habitat at the towerfoundations, but the remainder of the area is expected to remain as grassland habitat. The finalpreferred route will cross one patch of intact grassland habitat in the Spy Hill-Ellice CommunityPasture. In all, the PFA will traverse 25.2 ha of grassland/rangeland in the pasture, affecting 0.5% ofthe pasture in the RAA and 1.8% of the pasture in the LAA (Table 7-10)."

"Because less than 1% of the grassland habitat in the RAA and just over 1% of the grassland habitat inthe LAA will be affected by the Project, effects on grassland habitat and indicator species are expectedto be small, and not measurably change availability of plants or wildlife."

Basic area calculations should not be used to determine extent of effects on grassland habitat.As explained within the EAP, not all grassland is equal in the sense of species composition,presence/absence of non-native or invasive species, and habitat requirements for individual species.General assessment of "grassland/rangeland habitat" throughout the RAA can be misleading due to thevast differences in quality between the Community Pasture and some pasture and hay lands outside ofit, and the differences in habitat selection between species, e.g.) sharp-tailed grouse leks were found tobe concentrated along the edges of intact grasslands, rather than the open expanses of grassland withinSpy Hill-Ellice Community Pasture. Thirteen of 28 leks were located within 1000 m of the preferredroute, which is not visible in simple area calculations.

Furthermore, statements like liThe final preferred route will cross one patch of intact grasslandhabitat in the Spy Hill-Ellice Community Pasture." are misleading, since this patch is the largest withinthe pasture and is intersected by the RoW at several points. The ecological value of this one large patchcould be considered much higher than smaller patches, or even other large patches of low-qualitygrassland.

"While grassland birds including chestnut-collared longspur tend to avoid the edges created wheregrasslands transition to other habitat such as forest or agriculture (Sliwinski and Koper 2012), the finalpreferred route traverses a small tract of forest separating two intact grassland 7-48 patches, andminimal to no additional edge effects are anticipated."

Did this statement incorporate any functional disturbance buffers for chestnut-collaredlongspur? The creation and extension of edge habitat may occur with project development, so indirecthabitat loss should also be considered.

"Routing also favoured the edge of grassland areas, and avoided open areas. In addition, clearing andconstruction activities in Spy Hill-Ellice Community Pasture will be scheduled during frozen groundconditions while vegetation is dormant and migratory birds are not present."

Sharp-tailed grouse are not represented under typical migratory bird breeding periods.Restricted periods should be expanded to account for disturbance to sharp-tailed grouse lek sites(March 15 - May 15).

"Continued rangeland management practices through livestock grazing in previously forested areascould create modified grassland habitats in the future. This conversion from forest to modifiedgrassland habitat has been observed during field surveys in other recently cleared areas within theSpy Hill-Ellice Community Pasture (Biophysical Technical Report Appendix D)."

Manitoba Hydro should not passively rely on standard pasture operations to offset habitat thatmay be lost due to this project. As per our recommended licence condition above, Manitoba Hydroshould be required to actively offset habitat loss associated with the project. A formal plan should becreated and grazing (amongst other methods) will have to be approved as an acceptable tool to achievethe objectives.

Proposed Mitigation

"Plant SAR and critical habitat will be protected in accordance with provincial and federal legislationand provincial and federal guidelines. A 10 m buffer will be applied to mapped SOCCoccurrenceswithin the PFA. Setbacks and buffers along the ROW will be clearly identified by signage or flaggingprior to construction, and signage or flagging will be maintained during construction to alert crews tothe presence of the setback or buffer."

A 10 m buffer around protected plant species may not be sufficient to either protect individuals,or fully eliminate the risk of impact from machinery operation and/or location error. It is suggested thatManitoba Sustainable Development is notified when rare plant species are identified with 50 m ofconstruction activity, and suitable buffers be determined through consultation with the ConservationData Centre. This comment also applies to section 3.6.2 of the Draft Environmental Monitoring Plan.

"Clearing and construction activities in the Spy Hill-Ellice Community Pasture will be carried out duringfrozen ground conditions to limit affects to vegetation and avoid sensitive timing windows forwildlife."

Please provide dates for timing windows. The Conservation Data Centre's recommendedsensitive timing window for disturbance around sharp-tailed grouse leks runs between March 15 - May15, which must incorporated into the federal migratory bird windows.

"Perch deterrents will be installed on transmission line infrastructure in Spy Hill-Ellice CommunityPasture within grassland ESSsites where feasible as identified through the environmental monitoringprogram, and in consultation with Manitoba Sustainable Development."

We appreciate the inclusion of this mitigation tactic. Exploring various methods for deterringperching raptors, and potentially brood parasites, in an attempt to lessen the project impacts tograssland songbirds and sharp-tailed grouse will be an integral part of this project. That being said, we

are concerned that deterrents will be installed as an adaptive management technique, rather thanproactively during construction (Draft Environmental Monitoring Plan, 3.5.1).

Manitoba Hydro should also consider the impacts that some perching deterrent methods andplacement may have on raptors, through increased electrocutions. Monitoring will be required todetermine both the effectiveness of deterrents and assess potential impacts to perching birds.

Environmentally Sensitive Sites

Has Manitoba Hydro considered the use of matting for construction activities within grasslandsites even when conducted under frozen conditions? We are concerned that even under frozenconditions rutting and surface scraping may still occur within sensitive grassland habitats, and arewondering if this is a feasible mitigation option that will lessen the potential for habitat damage.

"Naturallow-growing shrub and grass vegetated buffer areas of 30 m, or greater, will be delineatedaround wetlands and riparian areas and be maintained to the extent possible."

Has Manitoba Hydro considered increasing setback distances around wetland and riparian areaswhere northern leopard frog and snapping turtle have been observed, or may be observed duringadditional pre-construction surveys?

Clearing within forested areas

We suggest that selective clearing that maintains low growing shrubs and reduces increases inline of sight along the RoW be used within all forested portions or the route, especially within theCommunity Pasture.

Draft Environmental Monitoring Plan

We understand that this plan is in draft form, and that Manitoba Hydro may already beconsidering amendments and additions based of reanalysis, new information, and/or new concerns,however the comments provided below are based on the content provided in proposal that wassubmitted. Additional comments and concerns will likely arise during reviews of future drafts.

General Questions:

Has Manitoba Hydro considered conducting pre-clearing den surveys along the route? Groundtracking surveys identified both badger and black bear sign along transects within the CommunityPasture, and we are left wondering what impact RoW clearing and transmission line construction mayhave on denning black bear and furbearers.

Has Manitoba Hydro considered conducting pre-construction ungulate calving assessmentsduring the month of June to identify potential calving areas along the RoWand determine if clearing,construction and maintenance conducted during the calving period could negatively impact ungulates?

Given the high proportion of observed sharp-tailed grouse leks that were found within 1000 mof preferred RoW, why is no specific sharp-tailed grouse monitoring proposed? Furthermore, we'dexpect that Manitoba Hydro will proactively deploy and monitor the effectiveness of perch deterrentsnear leks, which should include monitoring to determine if the project has had an negative impacts onsharp-tailed grouse.

Does Manitoba Hydro plan to deploy pre and post-construction trail cameras along the RoW tomonitor for changes in predator and resource user movements, as has been done with othertransmission projects where increase access may increase ungulate mortality? The monitoring planstates "Change in hunter accessibility to suitable ungulate habitat will be assessed by comparingwinter ungulate occurrence (pre-versus post-disturbance) relative to project-related access.", howeverit is not clear how a single snapshot of winter ungulate occurrence will help determine a "change inhunter accessibility".

Has Manitoba Hydro considered that standard point count monitoring may not be able to assesschanges in productivity of grassland songbirds as a result of project disturbance and infrastructure?Rather than using invasive methods to monitor nesting occurrences, Manitoba Hydro should attempt tooffset direct and indirect losses of grassland habitat through habitat improvement and creation, andmonitor offsets for utilization by listed grassland songbirds. We appreciate that Manitoba Hydro hasincluded habitat improvements in their Thresholds for Action/Decision Triggers, however we'dencourage a proactive, rather than reactive approach be taken, given that metrics like changes inproductivity may not be easily measured.

Figure 4-1

Changes in space use by ungulates may not be observed immediately after construction,therefore it is suggested that another assessment be conducted during the post-construction period.

Invasive species monitoring should continue past 2021.

Post construction bird monitoring may also need to be extended past 2022 based on many ofthe comments provided above.

Given the objectives, abundance should be included as a monitoring parameter in the table.

3.5.3 & 3.6.3The action following the decision trigger for invasive plant species is minimal. Manitoba Hydro

should commit to providing the resources necessary to address/contain/eliminate any invasive speciesinfestation.

Draft Construction Environmental Protection Plan

We understand that this plan is in draft form, and that Manitoba Hydro may already beconsidering amendments and additions based of reanalysis, new information, and/or new concerns,

however the comments provided below are based on the content provided in proposal that wassubmitted.

General comments

Please identify all proposed access routes, marshalling yards, aggregate stockpiles, and all otherconstruction related sites in the final version of the plan.

Restricted activity periods around sharp-tailed grouse leks should be expanded to begin onMarch 15.

"Rare ecological communities" are referenced in this section, however no definition andbuffers/setbacks are provided for this component. Please define this and incorporate suitablebuffers/setbacks.

Dagdick, Elise (SD)

From: Kopytko, Myles (SO)Sent: May-27-18 10:04 PMTo: Dagdick, Elise (SO) <Elise.Dagdick@gov.mb.ca>Subject: MANITOBA HYDRO- BIRTLETRANSMISSION PROJECT(FILE 5950.00)

Hello Elise:

Crown Land Implications:As indicated in earlier correspondence from Lands Branch, the proposed route will traverse five parcels of crown landscoded for the Spyhill Community Pasture. One other parcel (NW2-018-29W - small portion of LSD lIon the east side ofthe river) has been identified for wildlife, fisheries, agricultural resources, and noting that it has erosive potential(steep walls of the Assiniboine Valley and soils) as well as flood potential (Assiniboine River and its flood plain. Further,the land identified in the Spyhill Community Pasture represents one of the few last unbroken tracts of native mixedgrass prairie, and has been identified by Wildlife Branch as having significant number of unique and rare plant species,and also rare and endangered bird species. Wildlife Branch has prepared separate submission to the Environment ActProposal and as such, will not be part of this response, only to what has been identified above.

Forestry has identified no real concerns with the proposal, only Forest damage appraisal will apply for any timberremoval and all timber to be cut not bulldozed and set aside for utilization. Forestry may direct to existing commitmentsor requests.

Fisheries Identified sensitives of working on the Assiniboine River, and suggest that setbacks be employed to ensurethat adequate buffer is provided to the Assiniboine River. All aspects of the Department of Fisheries and OceansflWorking with Water Guidelines" be strictly followed.

With Respect to Flooding, region urge that establishment of poles and any establishment of roads required for line andpole maintenance be established so that no rutting or further potential for erosion be considered. Establishment ofroads kept to a minimum around the floodplain and developed with adequate geotechnical survey. Span of poles to bedeveloped so that minimum development near river or done on higher elevation with little chance of being within theflood plain higher risk areas.

Spyhill community pasture is noted to be on lighter soils and native prairie. Effort should be given to minimize soilidsturbances and impacts to the fragile soils and plant landscape. Matting should be considered to be used whereapplicable.

Plant and bird surveys conducted by wildlife branch should be reviewed and considered for any activities associatedwith the preferred route if it is final.

Should you have any questions, please don't hesitate to contact me.

Sincerely,

Myles KopytkoRegional Land Manager - Western RegionSustainable Development

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Oagdick, Elise (SO)

Subject:

From: Kopytko, Myles (SO)Sent: March-26-18 11:23 AMTo: Dagdick, Elise (SO) <Elise.Dagdick@gov.mb.ca>Subject: FW: Request for Review/Comment - Environment Act Proposal- Birtle Transmission Project File 5950.00 - DueDate March 20, 2018

Western IRMT has reviewed the preferred route for the Birtle Transmission Line Project has noted that the "preferredroute" will see a transmission line built across the following Crown land parcels (see below):

• NW2-018-29W (small portion of LSD11 on the east side ofthe river) coded for wildlife flooding, erosion,fisheries resources with an native grazing component.

Under Crown Land Policy, the development of a transmission line is considered controlled development permissible.The transmission Line R-O-W will also traverses across the following Crown Lands Designated as Community Pasture(Spy-Ellice).

• NW3-018-29W• NE4-018-29W• NW4-018-29W (along north Rd allowance)• N :h 5-018-29W (along north Rd allowance)• N :h 6-018-29W (along north Rd allowance)

All these lands are considered crown land and subject to the authorization of a work permit under the Crown Land'sAct. The also fall under the Community Pasture Program and require authorizations in the way of Right of Entry supportfrom the Pasture Managers themselves.

Assessment is very comprehensive. The following comments were noted:

Forestry: Forest Damage Appraisals will apply to any timber removal

Wildlife: It was noted that the EA is conducting a fairly intense assessment and monitoring model for the transmissionline. As the project will transect the pasture, which is one of the most diverse and native habitats that has a number ofrare and endangered species. Specifically, it is noted that the project will go right through one observed area of habitatfor the rare, Endangered or threatened bird's species Sprague's pipit. It was noted 1/ effects were assessed as beingonly small to moderate, locolized, medium term and not significant." The effects on their nesting or how species willinteract with the activity and if mitigation will be in play to address if the transmission line impacts the species as aresult fracturing their habitat. It is hoped that further research will be involved to understand how this will bemonitored in the future.

Other notes:

Review of the maps shows that the symbology for the community pastures is the same as the symbology for thepreferred routes on the maps (A-14l, making some confusion as to exact route of final preferred route.

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Reviewing the consultation comments with Indiginious and First Nation groups, it was noted that Metis Rights Coalition(MRC) were not one of the groups contacted. The Manitoba Metis Federation was listed which is primarily the maingroup for the Metis in Manitoba, but it should be noted that the MRC is primarily located in the Russell area, very closeproximity to the project.

There is significant interest in the oil and gas industry as well as mining, as well as one company identifying interest toestablish a well within 1 mile of line. It is encouraged that the oil sector could work with Manitoba Hydro to coordinateservice roads and so forth to reduce the footprint on the native habitat.

Sincerely,

Myles KopytkoRegional Land Manager - Western RegionSustainable Development

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Sport, Culture and Heritage

DATE: 2018-04-05

TO:Elise DAGDICKEnvironmental Approvals BranchManitoba Sustainable DevelopmentSuite 160-123 Main StreetWinnipeg, ManitobaR3C 1A5(204) 619-0709

Memorandum

FROM: Holly COTEMunicipal Heritage ConsultantHistoric Resources BranchMain Floor - 213 Notre Dame AvenueWinnipeg, ManitobaR3B 1N3

PHONE NO: (204) 945-7259FAX: (204) 948-2384

E-MAIL: Holiy.Cote@gov.mb.ca

SUBJECT: Request for Review/Comment - Environment Act Proposal - BirtleTransmission Project File 5950.00 - Due March 22, 2018

HRB File: AAS-16-11262, AAS-17 -12808

Concerns.

Further to your request for review and comments regarding the Environmental ActProposal for the Birtle Transmission Project, the Historic Resources Branch (HRB) hasexamined the location in conjunction with Branch records for areas of potential concern.The potential to impact heritage resources has been flagged throughout the proposedarea, therefore, the Historic Resources Branch has concerns with the project. Attached isa list of HRB comments/concerns with the Birtle Transmission Project Environmental ActProposal.

Under Section 12(2) of The Heritage Resources Act, if the Minister of Sport, Culture andHeritage has reason to believe that heritage resources or human remains are known, orthought likely to be present, on lands that are to be developed, then the owner/developeris required to conduct at his/her own expense, a Heritage Resource Impact Assessment(HRIA) and mitigation, if necessary, prior to the project's start.

The developer must contract a qualified archaeological consultant to conduct/complete aHeritage Resources Impact Assessment (HRIA) of the projects final route, in order toidentify and assess any heritage resources that may be negatively impacted bydevelopment. If desired, the Branch will work with the developer/land owners and itsconsultant to draw up terms of reference for this project.

If you have any questions or comments, please feel free to contact the Branch as above.

Manitoba Historic Resources BranchArchaeological Assessment Services Unit

Historic Resources Branch Comments/Concerns with the BirtleTransmission Line Environmental Act Proposal (File 5950.00)

Composed by the Archaeological Assessment Services Unit

Historic Resources Branch (HRB)

March 2018

Executive Summary, Glossary, and Table of Contents

EAP Statement:"Manitoba Hydro will also implement a Cultural and Heritage Resources Protection Plan, whichoutlines a clear process if an archaeological find is encountered." (Page 5)

HRB Comments:• The Heritage Resource Impact Assessment (HRIA) for the project remains incomplete. A

Cultural and Heritage Resources Protection Plan is acceptable method of protectingheritage resources that may be uncovered during project construction efforts.

• This protection plan should be implemented once the project HRIA has receivedclearance.

EAP Statement:"Known heritage sites were also considered during the routing process, with measuresdeveloped to manage previously un-discovered cultural or heritage resources. Residual effectsto recreation and tourism and heritage sites were therefore assessed as being not significant."(Page 7)

HRB Comments:• Areas of heritage concern were sent to Manitoba Hydro (MH) during the alternate route

selection stage. HRB recommended the "North Route" as the preferred route to avoidareas with know heritage resources. A "Southern Route" was eventually chosen for thepreferred route.

• The measures developed to "manage previously un-discovered cultural or heritageresources" involved a preliminary HRIA in 2017.

• 14 quarter sections remain outstanding and require investigation to complete the HRIAprior to project construction.

• Any changes in location from the preferred route to the final route will also need to bescreened for the potential to impact heritage resources and investigated if necessary.

Page 1 of 5

Chapter 2 - Project Description

EAP Statement:"Other surveys include those of environmental and heritage resources, initially in thebroader region and later in the process along the ROW, to confirm specific locations ofimportant resources." (Page 2)

HRB Comment:• The proposed work for the 2017 HRIA is incomplete.

Chapter 4 - Indigenous Engagement Process

EAP Statement:"During the values and interest workshop, the community (Canupawakpa Dakota First Nation)identified the Assiniboine River crossing as a special area. This was alsoconfirmed during the verification meeting with the community. The Assiniboine Rivercrossing will be identified as an Environmentally Sensitive Site for heritage." (Page 18)

HRB Comments:• Investigation of Assiniboine River crossing (including deep testing at major waterways)

was requested by HRB but only a portion of investigation was undertaken in the 2017HRIA.

• Additional field investigations are required.

EAP Statement:liThe Cultural and Heritage Resources Protection Plan (Appendix H) outlines measures andprotocols in the event the discovery of heritage sites during construction, as well as ongoingmonitoring of known heritage sites. Results from the heritage resources monitoring programwill be reported to the regulatory authorities and interested Indigenous communities andorganizations annually and as required." (Page 29-30)

HRB Comments:• The repeated references to the Cultural and Heritage Resources Protection Plan gives

the reader the impression that an HRIA has been completed and monitoring efforts areall that is to be required as the construction phase begins.

• The HRIA must be completed and clearance must be granted prior to constructionactivities commencing.

Page 2 of 5

Chapter 5 - Existing Environment (lof2)

EAP Statement:"Appendix E contains a detailed analysis of the culture and heritage resources of the region,based on research and field studies conducted on August 21-24 and October 10-13 during2017." (Page 87)

HRB Comment:• This is the EAP's first reference to the HRIA undertaken (2017). The field component

remains incomplete and to date a clearance letter has not been issued by the HistoricResources Branch.

EAP Statement:"Due to the extensive land development and agricultural practices over the last 100 years,almost all known sites have undergone varying degrees of natural or man-made disturbances.Many sites have been removed from their original depositional context, while others do notcontain dateable evidence to link to a specific cultural period and can only be assigned to thegeneral Precontact period." (Page 88)

HRB Comment:• This paragraph implies that heritage resources at sites that have been disturbed, either

naturally or through agricultural practices, are of no concern. Although surface finds areremoved from depositional context, important information can still be gathered fromsites such as these, especially when excavated below the plough zone (30cm) wherethere is potential to find intact archaeological/heritage materials.

Chapter 7 - Environmental Assessment

EAP Statement:"Study authors of the MMF MLOUS identified a historically important access routeadjacent the Assiniboine River (see Figure 9 for the MLOUS). Participants in the Canupawakpaworkshop spoke a great deal about 'Indian mounds' or rocks that are set in a pattern. Theystressed that it was highly likely for these types of sites to be found along the Assiniboine Riverand that extra caution should be taken along the river. It was explained that a 'mound' wouldhave been a village or an area where a family gathered, and there would be a high potential offinding artefacts in these areas. Participants also noted that hills in fields close to theAssiniboine River can be places where ceremonies took place and that the majority of burialswould be along the Assiniboine River given the importance it played as a major travel route."(Page 146-147)

HRB Comments:• The HRIA has not tested or inspected the lower eastern side of the Assiniboine River

crossing area.

Page3 of 5

• A rock formation was found in the Snake Creek area, this information should be sharedwith communities to help understand significance

EAP Statement:"Heritage evaluations have been conducted at crossing sites along the AssiniboineRiver./I (Page 152)

HRB Comment:• The HRIA has not tested or inspected the lower eastern side of the Assiniboine River

crossing area.

EAP Statement:"The Assiniboine River will be traversed by the Project; however, several mitigation measureshave occurred or are planned to reduce effects. An archaeological assessment to determinepresence of heritage or cultural resources within the proposed transmission corridor wascarried out prior to completing this assessment. The report provided recommendations thatwill be carried out prior to and during construction of the Project. In addition, areas along theAssiniboine River will be protected through a riparian buffer area where ground disturbancewill be reduced in a management zone (an area that varies between 30 and 85 m in sizedepending on slopes), which includes a 7 m machine free zone (which only allows reaching intozone with equipment but not entering the zone except at trail crossing). These equipmentrestrictions reduce ground disturbance, which reduces the likelihood of disturbance to thecultural sites described along the river./I (Page 152)

HRB Comments:• The 2017 HRIA assessment of the Assiniboine River involved investigation and testing

along the upper and lower sections of the western valley.

• The eastern valley portion was investigated along the upper terrace but has not beentested or inspected along the lower eastern portion of the valley within the ROW.

EAP Statement:Further mitigation measures to reduce or limit effects on cultural sites (Bullet points listed onPage 153)

HRB Comment:• These mitigation measures should be implemented after the archaeological

investigations within the project area are complete.

Page 4 of 5

EAP Statement:"The results of the review identified 32 quarter-sections along the FPRfor heritageinvestigation and in July 2017, these were provided to the HRB for review andcomment. Upon review, the HRB requested an additional 13 quarter-sections to beincluded in the 2017 field program. This brought the total number of quarter sections to45 parcels of land" (Page 163)

HRB Comment:• 22 quarter sections were identified by the consultant in their heritage permit

application, HRB requested an additional 13 quarter section be investigated. A total of35 quarter section were identified for investigation during the 2017 field assessment.

• To date 14 quarter sections remain outstanding and require testing/investigation priorto construction activities commencing.

• Testing is also required at water crossings areas that were not previously tested in 2017.

The five major water crossings that are located within the project's ROW are as follows:

1. Assiniboine River; (partial archaeological testing in 2017 -lower terrace on eastern sidehas not been tested)

2. Birdtail Creek; (testing complete in 2017)3. Snake Creek; (partially tested - southern side has not been tested)4. Armstrong Creek; and (not tested in 2017)5. Snake Creek Tributary. (testing complete in 2017)

Chapter 10 - Environmental protection, Follow-up and Monitoring

EAP Statement:"Manitoba Hydro proposes establishing a heritage and culture review (HCR) team thatwould include the Project Archaeologist and a community representative. The HCRteam would conduct a pre-construction survey of the final preferred route at locationswith high potential for the discovery of cultural and heritage resources." (Page 15)

HRB Comment:• HRB agrees.

• The HCR team can finalize the fieldwork/investigations that were not undertaken duringthe 2017 HRIA, as well as investigate the Saskatchewan border crossing location(finalized after the 2017 field investigations) and transmission tower footing locationsthat are located in areas with potential for the presence of heritage resources.

Page 5 of 5

InfrastructureHighway Planning and Design BranchEnvironmental Services Section1420 - 215 Garry St., Winnipeg, MB R3C 3P3T (204) 771-4941 F (204) 945-0593

March 19, 2018

Tracey Braun, M. Sc.Director, Environmental Approvals BranchManitoba Sustainable Development123 Main St., Suite 160Winnipeg, MB R3C 1A5

RE: Manitoba Hydro - Birtle Transmission ProjectClient File No. 5950.00

Dear Ms. Braun:

MI has reviewed the proposal under the Environment Act noted above and we offer thefollowing comments:

Roadside Development and Access Management:

The Proponent should be advised that a permit will be required for any developmentcrossing the provincial highways network, constructing within the right-of-way, accessinga highway, or building within MI's Controlled Area. Work will be done in accordance withManitoba Hydro-Manitoba Infrastructure working guidelines.

To obtain permit applications or to submit crossing requests, please contact either of thefollowing:

MI Brandon Office207-726-7000MI.SW,Region.Utilities@gov.mb.ca

Karen Toews-Therrien204-945-0324Karen.ToewsTherrien@gov.mb.ca

Water Management. Planning and Standards:

The proposed Birtle Transmission corridor runs from Birtle, Manitoba to theSaskatchewan- Manitoba border, crossing the Assiniboine River Valley in sections 3-18-29 WPM and 3-18-29 WPM. The Assiniboine River is subject to severe flooding, withmajor events occurring in 1976,2011, and 2014. During these events, the AssiniboineRiver Valley experienced widespread flooding at the location of the proposed crossing.

Manitoba Infrastructure assesses flood to the 200 year flood level. However, 200 yearflood levels are not available at this location, nor are historic flood level elevationsavailable at this location.

Water Management, Planning and Standards has no objections to the approval of EAP5950. However, Manitoba Hydro should develop the Assiniboine River crossing with fullknowledge of the known flood hazard.

Thank you very much for providing us the opportunity to review the proposal.

Sincerely,

/ti} .Kimber Osiowy, M. sir. Eng.Manager of Environmental Services

Dagdick, Elise (SD)

Subject:

From: sobkowich, Dale (SO)Sent: February-23-18 1:49 PMTo: Frias, Winifred (SO) <Cc: Kopytko, Myles (SO) < >; Anderson, Sheldon (SO) < >Subject: RE: Request for Review/Comment - Environment Act Proposal - Birtle Transmission Project File 5950.00 - DueDate March 20, 2018

Land Management and Planning Section has reviewed the preferred route for the Birtle Transmission Line Project hasnoted that the "preferred route" will see a transmission line built across the following Crown land parcels (see below)that may require appropriate Crown Land Operational Land Use Code update in the future (i.e., UT - Utility Code).

• NW2-018-29W (small portion of LSD11 on the east side of the river) coded: C/J/F2/T/7a

The transmission Line R-O-W will also traverses across the following Crown Lands Designated as Community Pasture(Spy-Ellice).

• NW3-018-29W• NE4-018-29W• NW4-018-29W (along north Rd allowance)• N ~ 5-018-29W (along north Rd allowance)• N ~ 6-018-29W (along north Rd allowance)

No other concerns have been identified.

Dale Sobkowich, Resource PlannerLands BranchDepartment (~fSllst(/in(/ble Development

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Dagdick, Elise (SD)

Subject:

From: Nayar, Rena (SD)Sent: March-15-18 3:38 PMTo: Dagdick, Elise (SD) <Elise.Dagdick@gov.mb.ca>Cc: Lavallee, Nicole (SD) <Nicole.Lavallee@gov.mb.ca>Subject: Request for Review/Comment - Environment Act Proposal- Birtle Transmission Project File 5950.00 - DueMarch 22, 2018

Manitoba Sustainable Development, Environmental Compliance and Enforcement Branch has reviewed the EAPfor theBirtle Transmission Project (File 5950.00) and has no concerns.

Thank you.

Rena NayarEnvironment Officer - WesternManitoba Sustainable Development- Environmental Compliance and Enforcement

Oagdick, Elise (SO)

Subject:

From: Epp, Jane (SO)Sent: March-08-18 10:57 AMTo: Oagdick, Elise (SO) <Elise.Oagdick@gov.mb.ca>Subject: RE: Request for Review/Comment - Environment Act Proposal - Birtle Transmission Project File 5950.00 - OueMarch 22, 2018

Hello,

Forestry and Peatlands has reviewed this proposal.

Our only request is the timber removed during construction and maintenance is done so under properauthority. Contact Regional Forester for information.

Jane EppForestry and Peatlands BranchWater Stewardship and Biodiversity Division, Sustainable Development

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Oagdick, Elise (SO)

Subject:

From: Vitt, Cory (SO)Sent: February-27-18 1:28 PMTo: Dagdick, Elise (SO) <Elise.Dagdick@gov.mb.ca>Subject: RE: Request for Review/Comment - Environment Act Proposal - Birtle Transmission Project File 5950.00 - DueMarch 22, 2018

No concerns.Office of Drinking Water (ODW)

Cory Vitt, M.Eng. P.Eng.Approvals EngineerOffice of Drinking WaterManitoba Sustainable Development

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Oagdick, Elise (SO)

From: Andersen, Peter (MR)Sent: February-26-18 12:54 PMTo: Dagdick, Elise (SD) <Elise.Dagdick@gov.mb.ca>Subject: RE: Request for Review/Comment - Environment Act Proposal - Birtle Transmission Project File 5950.00

Elise:This office has reviewed the above referenced Environment Act Proposal No. 5950 related to the development of a newhydro transmission corridor to the Manitoba/Saskatchewan border. We note the following in respect of the proposeddevelopment:

1. The proposed route involves placement of above ground hydro towers and high voltage lines across private land(use of which has been secured through easement agreements with private landowners) and Crown Lands (SpyHill Community Pasture.

2. Lands forming the route of the proposed hydro transmission corridor are located in Prairie View Municipalityand Ellice-Arche Municipality both of which are members of the Mid-West Planning District. Lands in these twomunicipalities are currently subject to the policies of the Carlton Trail Planning District Development Plan By-lawNo. 2-2008.

3. According to the Carlton Trail Planning District Development Plan, all lands forming the proposed hydro corridorare designated AGRICULTURE/ RURAL AREA. Development of a hydro corridor is a land use supported in thisland use designation. Specifically, PART 2, Section 2.3.3.1 ofthe Carlton Trail District Development Plan statesthe following:

" "Essential activities of government and public and private utilities should be permitted in any land usedesignation subject to requirements in a municipal zoning by-law. Such uses should be located anddeveloped in a manner which will minimize any incompatibility with neighbouring land uses. Specialconsideration should be given to reviewing siting requirements associated with such uses ascommunication towers and maintenance yards to ensure they will minimize adverse impacts onadjacent lands".

On the basis of this information, the brandon Community and regional Planning Office has no concerns with theproposed scope of work for this project. We do however recommend the proponent contact the Mid-West PlanningDistrict Development Officer ( to determinewhether any local permits or approvals are required in respect of the proposed development.

Cheers,

Peter Andersen, M.Sc. MCIP: RPP.Community PlannerCommunity and Regional Planning Branch

MUNICIPAL RELATIONS

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Dagdick, Elise (SD)

Subject:

From: Frykoda, Amy (H5AL)Sent: February-21-18 12:01 PMTo: Oagdick, Elise (50) <Elise.Oagdick@gov.mb.ca>Subject: FW: Request for Review/Comment - Environment Act Proposal - Birtle Transmission Project File 5950.00 - OueMarch 22, 2018

NO further comments,

Dr. Amy Frykod.a, MD, CCFP, ?vISe

Medical Officer of Health

Manitoba HC,llth

p.o. Box 960

Minnedosc1, iVlanitoba ROJ H~O

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Oagdick, Elise (SO)

Subject:

From: Phipps, Graham (SO)Sent: February-21-18 10:52 AMTo: Oagdick, Elise (SO) <Elise.Oagdick@gov.mb.ca>Subject: RE: Request for Review/Comment - Environment Act Proposal - Birtle Transmission Project File 5950.00 - OueMarch 22, 2018

Hi Elise,

In Section 5.3.4 the report several times incorrectly references a conference proceeding for work done in southeastManitoba. This reference is incorrect and Hydro should correct the public record with an appropriate reference.

Phipps, G., R.N. Betcher and J. Wang. 2008. Geochemical and IsotopicCharacterization of a Regional Bedrock/Surficial Aquifer System, SoutheasternManitoba. Conference proceedings of GeoEdmonton'08: 61st Canadian GeotechnicalConference and 9th Joint CGSIIAH-CNC Groundwater Conference, September 21-24,2008, Edmonton, Canada.

Cheers,Graham

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