Compliance Verification Activity Report: CV1920-108 - Manitoba Hydro-Electric Board - Régie de l'hydro-électricité du Manitoba

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2463

Regulated company: Manitoba Hydro-Electric Board - Régie de l'hydro-électricité du Manitoba

Operating company: Manitoba Hydro-Electric Board - Régie de l'hydro-électricité du Manitoba

Province(s) / Territory(s):

• Manitoba

Discipline(s):

• Environmental Protection

Related events:

• CV1920-477

Rationale and scope:

Canada Energy Regulator (CER) Environmental Protection Program construction inspection of Manitoba Hydro’s Manitoba-Minnesota Transmission Project (MMTP or Project) near Winnipeg, MB. The Project consists of the construction of a 500 kV AC transmission line and upgrades to the Dorsey, Riel, and Glenboro converter stations. The transmission line work is divided into two sections: Section 1 is approximately 92 km long and runs from the Dorsey Converter Station northwest of Winnipeg to Tower #225, and Section 2 is approximately 121 km long and runs from Tower #226 to the USA border where it will connect with the Great Northern Transmission Line.

Compliance tool(s) used:

• Information Request (IR) (2)
• Corrected Non-compliance (CNC) (3)
• Notice of Non-compliance (NNC) (1)

Facility details

Facilities:

Facility Types

• International Power Line (IPL)
• Right of way

Life-cycle Phases

• Construction

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Act (CERA)
• Plans And Procedures
• Project-specific Environmental Protection Plan (EPP)
• Construction Environmental Protection Plan (May 2019)

Regulatory instrument number(s):

• EC-059

Observations (no outstanding follow-up required)

Observation 1 - MMTP Section 1

Date & time of visit: 2019-10-22 10:15

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Erosion
• Soil Handling
• Biosecurity
• Soil Integrity
• Chemical Spills/Releases
• Surface Water Management
• Containment and Drainage Structures
• Vegetation
• Destruction of Vegetation
• Access Control
• Housekeeping
• Waste Management
• Temporary Structures

Facility:

Observations:

General

• Located on primarily agricultural and floodway land.
• Only work observed on this section was foundation work (drilling helical pile foundations).
• Still in the process of clearing, installing foundations and assembling towers.
• Section 1 has a centralized cleaning station for access mats.
• Observed a large number of muddy access roads and challenging wet weather conditions during the inspection.

• Upon arrival to site, safety personnel provided a brief visitor’s orientation to CER Inspection Officers (IOs).
• Project involves work on station expansion and termination point; observed that a gravel pad was down and foundation work was ongoing.
• Observed stripped organics piles, including a separated pile with low-grade contamination separated waiting for disposal.
• Observed large containment structure for pumps.
• A berm surrounded the gravel pad. Company Representatives indicated that a section of the berm will have to be moved around a footing installation for Tower #1. Observed containment bins for berm dewatering pumps.
• Company Representatives stated that fish were observed in the berm during recent wet weather conditions, which were subsequently relocated.
• Observed spill trays placed underneath portable heaters keeping freshly poured concrete (hoarded in) from cold temperatures while it cures.
• Large appropriately sized spill kit present at site.
• Outside of the station, observed a large organics pile immediately adjacent to the gravel access road, with a small pile of gravel in contact with organics. Company Representatives indicated that these soils would also be hauled (or disposed of) off site.
• Tower #1 was partly assembled in two pieces in a nearby agricultural field leased from Manitoba Hydro.
• Access matting present from the graveled access to the tower site.

• Tower site located in agricultural field leased from Manitoba Hydro, to the south of the Dorsey Converter Station.
• Observed a biosecurity station at the access point with a brush and disinfectant solution.
• Bulk bags filled with cement washout material were observed at the access road entrance.
• Company Representatives stated that the casing hole was sloughing in and they had to re-backfill the hole, and worked was stalled while they waited on a different drill rig to complete the excavation.
• Access matting was laid directly on topsoil from the road access to the Tower #2 site. Due to recent extreme wet weather events, conditions were extremely muddy and muddy topsoil was seeping through the mats.
• A work and equipment trailer was located adjacent to the Tower #2 site.
• A subsoil pile from the casing hole was placed directly on topsoil. Please refer to CNC #1.

• No ongoing work activities at this site at the time of inspection.
• Some large woody debris and garbage/construction waste was left on site. Company Representatives explained that construction waste was from a discovered tree-house/tree-stand and has yet to be disposed of. 
• Company Representatives indicated that workers would be coming back to complete clearing work at this site, which includes proper disposal of the large woody debris.
• Observed that select clearing was implemented within the riparian buffer area.
• Company Representatives indicated that a stick nest was found in the area, and that they had received provincial approval to remove stick nests outside of restricted activity periods.

• No ongoing work activities at this site at the time of inspection.
• Appropriate signage, temporary fencing and gate were present at the roadway access.
• Portable toilet and waste storage bin were present.
• Access conditions were very muddy, and rutting was observed.

Compliance tool used: No compliance tool used

Observation 2 - MMTP Section 2

Date & time of visit: 2019-10-23 12:00

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Erosion
• Biosecurity
• Soil Integrity
• Water Bodies - Non-Fish-bearing
• Sedimentation/Turbidity
• Reclamation
• Erosion
• Temporary Access Structures
• Water Bodies - Fish-bearing
• Sedimentation/Turbidity
• Erosion
• Temporary Access Structures
• Vegetation
• Destruction of Vegetation
• Access Control
• Housekeeping
• Waste Management

Facility:

Observations:

Tower #481

• No ongoing activities or work crews present at the time of inspection.
• Access matting in place from the roadway to Tower #481.
• Bio-control materials (boot brush etc.) and signage were present at roadway access.
• Stakes and flagging were present.
• Three tracked excavators were parked onsite next to the access matting; spill trays were present under equipment and fire extinguishers were present on equipment.
• Organic materials (woody debris) and topsoil stockpiled adjacent to stripped area.
• Stripped area flooded with water, and a running portable pump was in place pumping water out of the inundated area.

• No ongoing activities or work crews present at the time of inspection.
• Access matting was in place from the roadway to Tower #480.
• Two tracked excavators were parked onsite near Tower #480.

• No ongoing activities or work crews present at the time of inspection.
• Some felling of trees had occurred along planned field access.

• No ongoing activities or work crews present at the time of inspection.
• Access matting was in place from the roadway to the tower location.
• One tracked excavator and mobile crane were parked onsite near the tower location.

• No ongoing activities or work crews present at the time of inspection.
• Access matting was in place from the roadway to the tower location.
• Bio-control materials (boot brush etc.) and a large spill kit were present near signage at access from the roadway.
• Three tracked excavators were staged onsite next to access matting.
• Stakes and flagging were present.
• Pallets of equipment and tower pieces were present near the tower location.

• No ongoing activities or equipment movement in the area at the time of inspection.
• Access was along an existing dirt/farm access road.
• A tracked dozer parked at the access point near the roadway had a spill kit and fire extinguisher present.
• Flagging was present near the roadway marking the international boundary.
• Manitoba Hydro Environmental Inspectors were present and completing site visits/assessments at the time of inspection.
• Unmatted areas along the dirt access road had extremely muddy conditions, however most of the access route was matted to tower location #495.
• The western arm of Pine Creek had a culvert in place along the existing dirt/farm access road, the eastern arm did not.
• Company Representatives and Environmental Inspectors explained that due to existing difficulties and concerns with the current temporary crossing at the eastern arm of Pine Creek, as well as impacts of unusually wet weather conditions, further assessments had to be completed and modified approaches were possible for a new temporary or permanent crossing to replace the existing one. Please refer to NNC #1.

• No ongoing activities or work crews were present at the time of inspection. Company Representatives confirmed that this fly site, a tower assembly staging area, was not currently in use due to wet weather conditions.
• Access matting was in place from the roadway access heading northwards beyond tower location #385.
• Several pallets of equipment present were adjacent to access matting in a pasture field.
• Several areas of the pasture field were inundated with surface water.
• Two large waste receptacle bins, a large spill kit, and portable toilets (Porta Potties) were present near the site entrance.

• Observed ongoing tower assembly work at this location.
• Access from the roadway to the Tower #351 location was matted.
• A large spill kit and portable toilets (Porta Potties) were present.
• Observed the cleaning of a vehicle (pick-up truck) exiting the site, which consisted of a fine clean with a high pressure water wash and disinfectant spray consistent with high risk site cleaning requirements.
• The biosecurity site risk was posted on the access entrance signage.
• A third party biosecurity monitor was present conducting inspection and monitoring of vehicle and equipment cleaning.

• No ongoing activities or work crews were present at the time of inspection.
• Clearing work along the tree line of the roadway had already occurred.
• Some rutting was observed from equipment utilized in clearing and mulching activities.
• Flagging and marking was in place to identify known areas of invasive species that required specific mitigation.

• Access matting was in place from the roadway to the tower location.
• Goal posts with flagging was in place over the access from the roadway to identify the limits of approach to an overhead powerline.
• Portable toilets (Porta Potties) were present near the site entrance. 
• Pallets of equipment and tower pieces were present throughout the site.
• Several pallets of equipment present were adjacent to access matting in a pasture field.
• Several assembled or partly assembled towers were present along the western side of the field.

• Access to Towers #302-306 utilized an unmaintained road allowance (existing dirt road).
• Conditions were extremely muddy, however a tracked dozer was present at the access entrance and available to maintain the access.
• Observed a tracked excavator with a rotary drum mulcher head clearing and mulching near the location for Tower #306 in a limited clearing area.
• Between locations for Towers #302-304, clearing work of the centerline stringing corridor (24 m in width) had begun, although no equipment was working at the time of inspection.
• This area was identified as having salvageable timber within golden winged-warbler habitat, an environmentally sensitive area.
• Piled salvageable timber in this area appears to have been cut with a feller buncher.
• Proposed stockpile areas have been identified. Company Representatives confirmed that these sites would be validated once again with the landowner prior to the areas being cleared.
• RoW flagging was present, and the tower footing locations were staked and flagged.

• No ongoing activities or work crews were present at the time of inspection.
• Observed a temporary matted vehicle and equipment access crossing to the tower site over Edie Creek. There was clearance between the mats and water, however the mats directly over the creek did not appear stable and had separated slightly. Company Representatives stated that they planned to install a permanent access at this crossing to replace the mats.
• RoW boundaries have not yet been flagged off at this location.
• Company Representatives stated that they had received approval to install a culvert at the creek crossing, which had been ordered and was expected to arrive soon.

• No ongoing activities or work crews were present at the time of inspection. A stationary tracker feller buncher was observed on site.
• Tower sites are located within golden-winged warbler habitat, the only clearing that had taken place so far was over the centreline.
• Company Representatives stated that they would be salvaging firewood for the landowner at this location.
• RoW boundaries, centreline and footing locations were flagged.
• Some equipment tracks through soil were noted between tower locations.

• No ongoing activities or work crews were present at the time of inspection.
• Observed an unused culvert lying in the ditch at the access road entrance. Permanent access has yet to be installed at this entrance.
• A temporary access ramp constructed of mats crossed through a ditch filled with water; the mats were piled from the ground up in the ditch.
• The RoW centreline and tower foundation area had been bunched and mowed, and trees were piled in a row along the edge of the centreline.
• A field-delineated wetland was identified northwest of Tower #260, where some willows and tall trees adjacent to the centreline had been left standing by the clearing crew. Heavy rutting was observed through the wetland area. Company representatives stated that as it was not a designated wetland the riparian buffer clearing requirements did not automatically apply, and also stated that further work in this area would wait until frozen ground. It was confirmed that the rutting had occurred prior to Manitoba Hydro issuing a non-conformance to the contractor for failing to implement the wet weather contingency plan, which was issued prior to the inspection.

Compliance tool used: No compliance tool used

Observation 3 - Information Request (IR) #1 - Addressing Deficiencies/Non-Conformances

Date & time of visit: 2019-10-24 14:30

Discipline: Environmental Protection

Categories:

• Training and Documentation
• Documentation Available/Up to Date
• Training

Facility:

Observations:

Several deficiencies and non-conformances previously identified by Manitoba Hydro were observed throughout the inspection, including rutting observed adjacent to access matting in several areas, rutting observed adjacent to wetlands, and areas of rutting on dirt or field access trails.

Compliance tool used: Information Request (IR)

Regulatory requirement:

• Project-specific Environmental Protection Plan (EPP)
• Construction Environmental Protection Plan (May 2019)

Relevant section(s):

• Condition 4 of Certificate EC-059, Manitoba-Minnesota Transmission Project (MMTP) Construction Environmental Protection Plan (CEPP) states the following on page i: “Environmental protection can only be achieved with the engagement of Manitoba Hydro employees, consultants, local communities and contractors at all stages of projects from planning and design through construction and operational phases. As stated in the corporate Environmental Management Policy: “Manitoba Hydro is committed to protecting the environment by: • Preventing or minimizing any adverse impacts on the environment, and enhancing positive impacts • Continually improving our Environmental Management System • Meeting compliance obligations • Considering the interests and recognizing the knowledge of our interested parties who may be affected by our actions • Reviewing our environmental objectives and targets regularly to ensure improvement in our environmental performance • Documenting and reporting our activities and environmental performance” Manitoba Hydro’s Environmental Management Policy has been used to guide the development of the Environmental Protection Program for the proposed project. Implementation of the program is practical application of the policy and will demonstrate Manitoba Hydro’s dedication to environmental stewardship.” Condition 4 of Certificate EC-059, Manitoba-Minnesota Transmission Project (MMTP) Construction Environmental Protection Plan (CEPP), Section 1.4 Roles, Responsibilities and Reporting, Table 1-1: Environmental Roles and Responsibilities of Personnel during the Construction Phase states the following: • MH Environmental Specialist: “Responsible for implementing and ongoing compliance monitoring to ensure consistent and accurate reporting into EPIMS.” • MH Environmental Officer/Inspector: o “Provides advice and guidance to the Construction Supervisor for non-compliance situations, environmental incidents and emergencies. o Monitors the project for compliance of the CEnvPP, Environmental License and other environmental regulatory requirements. o Responsible for ongoing compliance monitoring of project activities to ensure consistent implementation of the CEnvPP and accurate reporting into the Environmental Protection Information Management System.” • MH Construction Supervisor(s): “Facilitates construction contractors implementation of remedial actions or responses to non-compliance situations or incidents are implemented as required.” • Construction Contractor(s): “Report any discoveries of non-compliance, accidents or incidents to the construction supervisor and Environmental Officer/Inspector.”

Company action required:

Provide a response outlining how Manitoba Hydro will work with its prime contractor and sub-contractors to ensure that a process is in place to track, monitor, and correct identified deficiencies/non-conformances in a timely fashion (taking the changing seasons into consideration).

Due date: 2019-11-15

Date closed: 2019-11-18
Note: the date closed is the date that the inspector completed their review of the company corrective actions for adequacy and determined that no further actions are required.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 4 - IR #2 - Perch Site Trees

Date & time of visit: 2019-10-24 14:30

Discipline: Environmental Protection

Categories:

• Wildlife
• Species of Concern

Facility:

Observations:

Manitoba Hydro was unable to demonstrate that it has measures in place to ensure the proper implementation of specific mitigation requiring retention of perch site trees in forested golden-winged warbler (GWW) habitat. CER Inspection Officers noted that perch site trees are to be located along the edge of the right-of-way. Company Representatives had indicated during the inspection that clearing along the edge of the RoW in GWW habitat had yet to occur.

Compliance tool used: Information Request (IR)

Regulatory requirement:

• Project-specific Environmental Protection Plan (EPP)
• Construction Environmental Protection Plan (May 2019)

Relevant section(s):

• Condition 4 of Certificate EC-059, Manitoba-Minnesota Transmission Project (MMTP) Construction Environmental Protection Plan (CEPP), Section 2.4 Wildlife and Habitat, 2.4.1 Birds and Habitat states the following: “Areas within the Construction Environmental Protection Plan Mapbook have been identified as Golden-winged Warbler habitat and the Clearing Management Plan outlines the clearing prescriptions for retention of understory vegetation and perch trees.” Condition 4 of Certificate EC-059, Manitoba-Minnesota Transmission Project Golden-Winged Warbler Habitat Management Plan states the following on page 10: “On the outer edges of Zone 2, clearing equipment operators will work closely in real-time with Manitoba Hydro environmental inspectors in an effort to develop a feathered edge by selectively clearing vegetation in an uneven pattern to create a mosaic of habitats as described in Petzinger et al. (ND), Artuso et al. (ND) and GWWAWG (2013). The conceptual vegetation clearing prescription described above applies to forested habitat.”

Company action required:

Provide a response outlining how Manitoba Hydro will work with its prime contractor and sub-contractors to ensure that appropriate monitoring and oversight is in place when implementing the clearing prescription for perch site trees in GWW habitat.

Due date: 2019-11-15

Date closed: 2019-11-15
Note: the date closed is the date that the inspector completed their review of the company corrective actions for adequacy and determined that no further actions are required.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 5 - Corrected Non-Compliance (CNC) #1 - Soil Separation

Date & time of visit: 2019-10-22 11:20

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Soil Integrity

Facility:

Observations:

At the excavation for a foundation at Tower #2, it was observed that subsoil from the casing hole was being stored directly on topsoil. CER Inspection Officers (IOs) confirmed that it was a contractor requirement to salvaged topsoil and stockpile it separately from subsoil to prevent loss and admixing. Company Representatives notified the contractor about the issue and provided a copy of this communication to the IOs.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

• Project-specific Environmental Protection Plan (EPP)
• Construction Environmental Protection Plan (May 2019)

Relevant section(s):

• This is in non-compliance with Condition 4 of Certificate EC-059. Specifically, the Manitoba-Minnesota Transmission Project (MMTP) Construction Environmental Protection Plan (CEPP), Section 5.2 General Mitigation Tables – Transmission towers and conductors (PC-10), PC-10.02 states the following: “During tower foundation excavation the A horizon soils (black or dark in color/organic layer) shall be stripped and stored separately from other soils. When back filling, these soils are to be replaced as the surface soils to encourage site re-vegetation.”

Company action required:

Provide a copy of the associated communication from Manitoba Hydro to the contractor regarding the issue observed, as well as the associated corrective action submitted by the contractor.

Due date: 2019-10-24

Date closed: 2019-10-28
Note: the date closed is the date that the inspector completed their review of the company corrective actions for adequacy and determined that no further actions are required.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 6 - CNC #2 - Incorrectly Felled Timber

Date & time of visit: 2019-10-23 16:35

Discipline: Environmental Protection

Categories:

• Vegetation
• Destruction of Vegetation

Facility:

Observations:

In a work area in the vicinity of Tower #304 within golden-winged warbler habitat, where mulching operations had not yet been completed to clear the tower footprint, CER Inspection Officers (IOs) observed that trees had been felled into remaining standing timber around the area’s perimeter. During the inspection, Company Representatives issued a corrective notice to the primary contractor which was verified by IOs.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

• Project-specific Environmental Protection Plan (EPP)
• Construction Environmental Protection Plan (May 2019)

Relevant section(s):

• This is in non-compliance with Condition 4 of Certificate EC-059. Specifically, the Manitoba-Minnesota Transmission Project (MMTP) Construction Environmental Protection Plan (CEPP), Section 5.2 General Mitigation Tables – Clearing (PA-3) states the following: PA-3.07 – “Cleared trees and woody debris will not be pushed into (or adjacent) to standing timber, or within the high-water mark of wetlands or waterbodies.” PA-3.24 – “Trees will be felled toward the middle of rights-of-way or cleared area to avoid damage to standing trees. Trees will not be felled into waterbodies.”

Company action required:

Manitoba Hydro shall provide IOs with a copy of the correction notice that was given to the primary contractor regarding the issue observed.

Due date: 2019-10-24

Date closed: 2019-10-24
Note: the date closed is the date that the inspector completed their review of the company corrective actions for adequacy and determined that no further actions are required.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 7 - CNC #3 - Rutting and Admixing on RoW Access Trails

Date & time of visit: 2019-10-23 17:25

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Soil Integrity

Facility:

Observations:

CER Inspection Officers and Company Representatives identified rutting and early stages of admixing along a RoW access trail between Towers #304 and 305. During the inspection, Company Representatives issued a corrective notice for the issue to the primary contractor.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

• Project-specific Environmental Protection Plan (EPP)
• Construction Environmental Protection Plan (May 2019)

Relevant section(s):

• This is in non-compliance with Condition 4 of Certificate EC-059. Specifically, the Manitoba-Minnesota Transmission Project (MMTP) Construction Environmental Protection Plan (CEPP), Appendix H – Saturated/Thawed Soils Operating Guidelines, Section 7.5 Forest, Tame Pasture and Grasslands states the following: “Thresholds for immediate implementation of Work Modification(s): • When rutting depth exceeds 30 cm for more than 15 m in length; • Admixing (mixing of topsoil and subsoils)…”

Company action required:

Manitoba Hydro shall provide IOs with a copy of the correction notice that was given to the primary contractor regarding the issue observed.
 

Due date: 2019-10-24

Date closed: 2019-10-24
Note: the date closed is the date that the inspector completed their review of the company corrective actions for adequacy and determined that no further actions are required.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 8 - Notice of Non-Compliance #1 - Eastern Arm of Pine Creek Access Crossing

Date & time of visit: 2019-10-23 13:00

Discipline: Environmental Protection

Categories:

• Water Bodies - Fish-bearing
• Temporary Access Structures

Facility:

Observations:

CER Inspection Officers (IOs) observed inadequate temporary access measures in place where an existing dirt road being utilized for access to the southernmost towers (#494-496) of Section 2 crosses the eastern arm of Pine Creek (LSD SW-4-1-12-E) along the U.S. border. Under current water flow conditions (at the time of inspection), access matting used for the temporary crossing was impeding natural stream flows which may lead to detrimental effects to the environment, including fish and fish habitat.

Company Representatives and the IOs discussed that the temporary crossing would be removed in a manner that minimizes potential disturbance to bed and banks of the watercourse and/or fish and fish habitat as soon as reasonably practicable, and once the current wet weather conditions had sufficiently improved. It would then be replaced by an appropriate temporary or permanent crossing that meets the applicable federal and provincial requirements. It was also discussed that this work would be conducted under the guidance of a qualified person(s).

Compliance tool used: Notice of Non-compliance (NNC)

Regulatory requirement:

• Project-specific Environmental Protection Plan (EPP)
• Construction Environmental Protection Plan (May 2019)

Relevant section(s):

• This is in non-compliance with Condition 4 of Certificate EC-059. Specifically, the Manitoba-Minnesota Transmission Project (MMTP) Construction Environmental Protection Plan (CEPP), Section 5.2 General Mitigation Tables – Water Crossings (PC-9), ID PC-9.04 states the following: “Construction of stream crossings will follow the Manitoba Stream Crossing Guidelines for The Protection of Fish and Fish Habitat (DFO and MNR 1996).”

Company action required:

Manitoba Hydro shall provide the following information to IOs as soon as available but no later than 15 December 2019:

1. A response outlining the methods or techniques utilized for the removal of the existing temporary crossing, as well as a copy of environmental inspection report(s) from the Environmental Inspector(s) and/or Monitor(s) having monitored that activity.
2. Upon ensuring that a qualified person(s) has assessed the site and determined an appropriate temporary crossing method (i.e. Bailey bridge, clear span bridge, etc.), provide a response outlining the proposed replacement access crossing as well as the intended installation completion date.
3. A copy of environmental inspection report(s) from the Environmental Inspector(s) and/or Monitor(s) having monitored the replacement crossing installation activities.

Due date: 2019-12-15

Date closed: 2020-02-21
Note: the date closed is the date that the inspector completed their review of the company corrective actions for adequacy and determined that no further actions are required.

Reason closed: Full relief granted

Compliance achieved: Yes

Observations (company follow-up required)

Identified non-compliances to company plans or procedures are non-compliances either to: