Compliance Verification Activity Report: CV2122-178 - Westcoast Energy Inc.


Compliance verification activity type: Field Inspection

Activity #: CV2122-178
Start date: 2021-09-13
End date: 2021-09-17


Regulated company: Westcoast Energy Inc.

Operating company: Enbridge Inc.

Province(s) / Territory(s):


Related events:

Rationale and scope:

This inspection focused on the implementation of caribou habitat restoration measures associated with five Westcoast projects in Northeast BC: High Pine Expansion Project (High Pine), Wyndwood Pipeline Expansion Project (Wyndwood), Pine River Aerial Crossing Project (Pine River Project), 2BL Crossover Assemblies Replacement Project (2BL) and the Spruce Ridge Program (Spruce Ridge). This included measures implemented on right-of-way (RoW) for each of High Pine, Wyndwood and the Pine River Project, under the Caribou Habitat Restoration Plan (CHRP) for each project as well as the implementation of one Offsets Measures Plan (OMP) in the Bearhole Lake Protected Area to address habitat offset requirements for all five projects.

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Regulatory instrument number(s):

Observations (no outstanding follow-up required)

Observation 1 - On-Site Habitat Restoration

Date & time of visit: 2021-09-16 12:00

Discipline: Environmental Protection




Inspection of habitat restoration measures for the projects outlined below was largely undertaken via helicopter. Ground-based observations were made in some areas on Wyndwood and High Pine where conditions were suitable for landing and travel on foot.

Vegetation regeneration was variable on both High Pine and Wyndwood. The Inspection Officer determined that no immediate corrective action is necessary as post-construction environmental monitoring activities and oversight remain ongoing.

Pine River

The footprint for this project was a single location. The site was well vegetated, and mounding was visible from the air. Company Representatives indicated that the site had also been planted (seedlings).

The RoW parallels a third party RoW in this location. At the time of the inspection, it appeared that maintenance activities were underway, and the jersey barriers blocking access to the area had beenr removed and were placed in the restored area. See Information Request (IR) No. 1.


The line-of-sight (LoS) structure at approximately KP 11 + 700 appeared intact. Rollback measures were in place in several locations, includeing temporary workspace and the RoW at approximately KP 12 + 500 and across the full width of the RoW at KP 2 + 500. No areas were observed that were entirely bare of vegetation, though some areas were patchy (approx. 30-50% coverage). No evidence of erosion was observed and cattle were observed grazing in one area with patchy vegetation. 

Approx. KP 18

This area is the start of the caribou habitat restoration measures for the project. The area was generally well vegetated (>80% coverage) with grasses and shrubs and the planted seedlings appeared healthy. 

High Pine

Rollback was observed at several locations along the RoW. A breach of the rollback and a visible trail were observed at approximately KP 0, Company Representatives indicated access was required at times for ceremonial purposes.

Vegetation regeneration was variable on the RoW and temporary workspaces (TWS). Some TWS areas were largely (~90% bare), but seedlings were visible from the air. In general, the RoW had variable growth, with some areas bare and some areas nearing 100% coverage. 

Line of Sight (LoS) Break - Approx. KP 23

In general, the area had revegetated well, with approximately 90% coverage. The vegetation was largely grasses and planted seedlings (spruce and pine), which appeared healthy.

The LoS break was a fence constructed in a zig zag pattern and made of timber approximately 2-3 meters tall. The fence was in good condition and appeared effective as a visual barrier.

LoS Break - Approx KP 10 + 500

This LoS break consisted of two fences constructed of timbers, approximately 2-3 meters in height and in a zig zag pattern. Approximately 30-40 mature spruce trees (2 meters and taller) were planted in this location as well as seedlings (approx. 0.3 meters in height). The overall survival rate of seedlings and trees was approximately 90%.

The LoS break appeared to be effective in this location. 

Compliance tool used: No compliance tool used

Observation 2 - Offsetting Measures

Date & time of visit: 2021-09-15 14:00

Discipline: Environmental Protection




Westcoast has combined its offset requirements for the five projects into a single offset implementation program. Two roads assocated with seismic activities were selected within Bearhole Lake Protected Area as the offset location and is referred to as the "Bearhole Offset".

Offsetting measures were largely observed via helicopter flyover, however, the south end of one of the roads was accessed via a reclaimed well pad and observed from the ground. The approx. 100 m road leading to the Bearhole Offset  was compacted soil with patchy vegetation growth and bare areas.

At the start of the Bearhole Offset, the road had been broken-up/mixed into a rough surface that appeared consistent with the road-ripping and rough-and loose measures described in the Final Offset Measures Plan (OMP). Trees were laying across the road from either side using three methods described in the Final OMP: tree-bending, tree-falling and tree-hinging. Pine and spruce seedlings approximately 15 cm high were observed planted randomly throughout the loosened soil. The application of offset measures appeared consistent with what is described in the Final OMP. Foot travel within the offset area was not attempted as the loosened soil and trees provided obstacles of 1-1.5 meters in height. 

The rough and loose soil and the tree-bending/falling/hinging locations observed from the air appeared consistent with the locations outlined in the Final OMP.  


Compliance tool used: No compliance tool used

Observation 3 - Information Request No. 1 - Communication and Protection of Restoration Measures

Discipline: Environmental Protection




The RoW parallels a third party RoW in this location. At the time of the inspection, it appeared that maintenance activities were underway, and the concrete lock-blocks installed to block access to the area had been removed and were placed in the restored area.

Company Representatives were unsure whether the activities were being undertaken by another part of Westcoast operations or the third party company. 

The lock-blocks are part of a gate that blocks access to the restoration area. 

The Caribou Habitat Restoration and Offset Measure Monitoring Plan (CHROMMP) outlines the monitoring for access management at this location, and one of the targets and performance measures is "access control (i.e., gate) is not breached, damaged or by-passed".

Additinal information is required.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

1. Provide a high level description of the possible (potentially third-party) O&M activitiy (if known) at the location, including whether Westcoast was aware of the activity prior to its occurance.

2. Explain how/whether Westcoast's communication procedures for internanal activities and with third parties incorporates any messaging about the need to minimize access and disturbance in the restoration footprint.

3. Provide a "Caribou Habitat Restoration - Access Management and Line-of-Sight (LOS) Datasheet" for the Pine River Project (Appendix A of CHROMMP) that was completed in fall 2021. If one is not available for this time period, provide the most recently available.  

Due date: 2022-03-04

Date closed: 2022-04-08
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

Observations (company follow-up required)

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

- the condition of an authorization document that requires the implementation of that plan or procedure; or

- the relevant section of the regulations that requires implementation of that plan or procedure including those sections that require implementation of plans or procedures as a part of a Program