Labrador - Island Transmission Link Target Rare Plant Survey Locations

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Labrador-Island Transmission Link Environmental Impact Statement Addendum 4 CARIBOU Sustainable Development and Strategic Science Division 1 Sustainable Development and Strategic Science Division 2 Sustainable Development and Strategic Science Division 3 Wildlife Division - 1 Wildlife Division - 2 Wildlife Division - 3 Wildlife Division - 4 December 2012 Page 4-1

Information Requests Responses Labrador Island Transmission Link Requesting Organization: Department of Environment and Conservation Information Request No.: DEC, Sustainable Development and Strategic Science Division 1 Reference: Caribou and Their Predators Component Study; Volume 2B, Section 12.3 Caribou Information Requested: Incorporate temporal aspects of Newfoundland caribou distribution into the environmental assessment SDSS provided (on 5 October 2012) 100% and 66% kernel shape files of caribou telemetry data from 1979-2011 for Newfoundland. These files are organized temporally by four seasons spring, summer, fall and winter. Using the current (15 October 2012) ROW routing, Nalcor proposes to: calculate the amount of 66% and 100% kernel distribution by each of the four seasons for the Northern Peninsula and the Central and Eastern Newfoundland Study Areas for the area of the 60 m wide ROW to estimate direct habitat loss, plus a 500 m buffer on either side (i.e., 1.06 km wide assessment area), 2.06 km wide assessment area, and 4.06 km wide assessment area to examine potential indirect effects of the Project on caribou habitat; present values in tabular format for the 60 m wide ROW and for the 1.06 km wide assessment area, 2.06 km wide assessment area, and 4.06 km wide assessment area also indicating the percentage of each kernel for each of the regions (i.e., Northern Peninsula Study Area and the Central and Eastern Newfoundland Study Area); create a separate figure showing the 66% and 100% kernels for each season overlapping with the 60 m wide ROW and for the 1.06 km wide assessment area, 2.06 km wide assessment area, and 4.06 km wide assessment area and; the amount of kernel distribution will be calculated for kernels which represent areas of important habitat that are used year round (such as on the Northern Peninsula), in addition to specific seasonal use. describe implications of this additional information on the environmental assessment predictions for Newfoundland caribou in the EA. Response: To examine recent woodland caribou activity in Newfoundland, Nalcor completed the analyses requested by SDSS by using both the 1979-2011 and the 2005-2011 telemetry datasets. The comparison is presented in each relevant analysis below. Page 1

Information Requests Responses Labrador Island Transmission Link Table 1 (Northern Peninsula) and Table 2 (Central and Eastern Newfoundland) examines the direct disturbance (i.e., Project footprint) resulting from the construction of the 60 m wide right-of-way only. Table 1. Seasonal caribou occurrence in the Northern Peninsula Region Direct Habitat Alteration/Loss associated with the 60 m wide Right-of-way (reference Figure SDSS1-1 to SDSS1-4). Dataset Region (km 2 ) 100% Kernel 66% Kernel Rightof-Way (km 2 ) % in Rightof-Way Region (km 2 ) Right-of- Way (km 2 ) % in Rightof-Way Winter 1979-2011 10,319 8.2 0.08 2,111 3.4 0.16 2005-2011 9,806 8.5 0.09 1,978 3.2 0.16 Spring 1979-2011 8,808 8.1 0.09 1,867 3.4 0.18 2005-2011 8,582 8.2 0.10 1,558 3.5 0.22 Summer 1979-2011 7,914 7.0 0.09 1,738 2.0 0.12 2005-2011 6,734 7.0 0.10 1,562 2.1 0.13 Fall 1979-2011 8,685 8.6 0.10 2,051 2.1 0.10 2005-2011 8,188 8.7 0.11 1,713 1.8 0.11 Page 2

Buffers Northern Peninsula Region Boundary Trans-Canada Highway 60 m wide RoW 500 m buffer ± 1000 m buffer 2000 m buffer Caribou Aggregations (1979-2011)* 66% Kernel 99.9% Kernel FIGURE ID: HVDC_ST_641 0 20 40 * Source: Newfoundland Department of Environment and Conservation, 2012 Figure SDSS1-1 Winter caribou occurrence in the Northern Peninsula Region and assessment area buffers (1979-2011)

Buffers Northern Peninsula Region Boundary Trans-Canada Highway 60 m wide RoW 500 m buffer ± 1000 m buffer 2000 m buffer Caribou Aggregations (1979-2011)* 66% Kernel 99.9% Kernel FIGURE ID: HVDC_ST_642 0 20 40 * Source: Newfoundland Department of Environment and Conservation, 2012 Figure SDSS1-2 Spring caribou occurrence in the Northern Peninsula Region and assessment area buffers (1979-2011)

Buffers Northern Peninsula Region Boundary Trans-Canada Highway 60 m wide RoW ± 500 m buffer 1000 m buffer 2000 m buffer Caribou Aggregations (1979-2011)* 66% Kernel 99.9% Kernel FIGURE ID: HVDC_ST_643 0 20 40 * Source: Newfoundland Department of Environment and Conservation, 2012 Figure SDSS1-3 Summer caribou occurrence in the Northern Peninsula Region and assessment area buffers (1979-2011)

Buffers Northern Peninsula Region Boundary Trans-Canada Highway 60 m wide RoW 500 m buffer ± 1000 m buffer 2000 m buffer Caribou Aggregations (1979-2011)* 66% Kernel 99.9% Kernel FIGURE ID: HVDC_ST_640 0 20 40 * Source: Newfoundland Department of Environment and Conservation, 2012 Figure SDSS1-4 Fall caribou occurrence in the Northern Peninsula Region and assessment area buffers (1979-2011)

Information Requests Responses Labrador Island Transmission Link Table 2. Seasonal caribou occurrence in the Central and Eastern Newfoundland Region Direct Habitat Alteration/Loss associated with 60 m wide Right-of-way (reference Figure SDSS1-5 to Figure SDSS1-8). Dataset Region (km 2 ) 100% Kernel 66% Kernel Rightof-Way (km 2 ) % in Rightof-Way Region (km 2 ) Right-of- Way (km 2 ) % in Rightof-Way Winter 1979-2011 36,678 6.7 0.02 5,765 0.8 0.01 2005-2011 33,253 6.7 0.02 5,172 0.8 0.02 Spring 1979-2011 35,845 8.4 0.02 6,251 1.5 0.02 2005-2011 29,989 7.4 0.02 4,435 1.5 0.03 Summer 1979-2011 34,024 8.1 0.02 5,407 2.1 0.04 2005-2011 33,933 6.5 0.02 5,262 2.2 0.04 Fall 1979-2011 31,426 6.7 0.02 5,560 1.1 0.02 2005-2011 24,817 6.4 0.03 4,264 1.1 0.03 Analyses of the data indicate that the direct seasonal habitat altered/lost for either kernel is less than 0.3% for the Northern Peninsula and less than 0.05% for the Central and Eastern Newfoundland Regions. The term altered/lost is used, as not all of the right-of-way will need to be cleared of taller woody vegetation (e.g., wetlands) and the majority of the right-of-way will remain vegetated. Only the tower sites and the access trail will remain permanently disturbed; the remainder of the right-of-way will be allowed to support a native species vegetation cover comprised of species or individual plants that do not exceed 2 m in height at maturity (i.e., vegetation management required for safety). Table 3 (Northern Peninsula) and Table 4 (Central and Eastern Newfoundland) examines an assessment area with a 500 m buffer that is consistent with the findings of Dyer et al. (2001) for the avoidance of roads by caribou in open habitat and the Recovery Strategy for Woodland Caribou, Boreal Population (Environment Canada 2012). Environment Canada (2012) defines undisturbed habitat as that outside of burns 40 years old or younger and beyond 500 m from disturbances. For this scenario, the assessment area would be 1.06 km wide, including the 60 m wide right-of-way and a 500 m buffer on each side. Page 7

Northern Peninsula Region Boundary Trans-Canada Highway ± Buffers 60 m wide RoW 500 m buffer 1000 m buffer 2000 m buffer Caribou Aggregations (1979-2011)* 66% Kernel 99.9% Kernel FIGURE ID: HVDC_ST_641a 0 25 50 * Source: Newfoundland Department of Environment and Conservation, 2012 Grand Falls-Windsor! Gander! Clarenville! Figure SDSS1-5 Winter caribou occurrence in the Central and Eastern Newfoundland Region and assessment area buffers (1979-2011)

Buffers Northern Peninsula Region Boundary Trans-Canada Highway 60 m wide RoW 500 m buffer ± 1000 m buffer 2000 m buffer Caribou Aggregations (1979-2011)* 66% Kernel 99.9% Kernel FIGURE ID: HVDC_ST_642a 0 25 50 * Source: Newfoundland Department of Environment and Conservation, 2012 Grand Falls-Windsor! Gander! Clarenville! Figure SDSS1-6 Spring caribou occurrence in the Central and Eastern Newfoundland Region and assessment area buffers (1979-2011)

Buffers Northern Peninsula Region Boundary Trans-Canada Highway 60 m wide RoW 500 m buffer ± 1000 m buffer 2000 m buffer Caribou Aggregations (1979-2011)* 66% Kernel 99.9% Kernel FIGURE ID: HVDC_ST_643a 0 25 50 * Source: Newfoundland Department of Environment and Conservation, 2012 Grand Falls-Windsor! Gander! Clarenville! Figure SDSS1-7 Summer caribou occurrence in the Central and Eastern Newfoundland Region and assessment area buffers (1979-2011)

Buffers Northern Peninsula Region Boundary Trans-Canada Highway 60 m wide RoW 500 m buffer ± 1000 m buffer 2000 m buffer Caribou Aggregations (1979-2011)* 66% Kernel 99.9% Kernel FIGURE ID: HVDC_ST_640a 0 25 50 * Source: Newfoundland Department of Environment and Conservation, 2012 Grand Falls-Windsor! Gander! Clarenville! Figure SDSS1-8 Fall caribou occurrence in the Central and Eastern Newfoundland Region and assessment area buffers (1979-2011)

Information Requests Responses Labrador Island Transmission Link Table 3. Seasonal caribou occurrence in the Northern Peninsula Region Area for the 60 m RoW + 500 m buffer (reference Figure SDSS1-1 to Figure SDSS-4). Dataset 100% Kernel 66% Kernel Region (km 2 ) Area (km 2 ) % in Area Winter Region (km 2 ) Area (km 2 ) % in Area 1979-2011 10,319 145 1.4 2,111 61 2.9 2005-2011 9,806 149 1.5 1,978 58 2.9 Spring 1979-2011 8,808 142 1.6 1,867 61 3.3 2005-2011 8,582 144 1.7 1,558 62 4.0 Summer 1979-2011 7,914 122 1.5 1,738 37 2.1 2005-2011 6,734 121 1.8 1,562 38 2.4 Fall 1979-2011 8,685 153 1.8 2,051 37 1.8 2005-2011 8,188 153 1.9 1,713 34 2.0 Table 4. Seasonal caribou occurrence in the Central and Eastern Newfoundland Region Area for the 60 m RoW + 500 m buffer (reference Figure SDSS1-5 to Figure SDSS1-8). Dataset Region (km 2 ) 100% Kernel 66% Kernel Area (km 2 ) % in Area Winter Region (km 2 ) Area (km 2 ) % in Area 1979-2011 36,678 120 0.3 5,765 14 0.2 2005-2011 33,253 119 0.4 5,172 14 0.3 Spring 1979-2011 35,845 148 0.4 6,251 26 0.4 2005-2011 29,989 132 0.4 4,435 26 0.6 Summer 1979-2011 34,024 144 0.4 5,407 39 0.7 2005-2011 33,933 115 0.3 5,262 40 0.8 Fall 1979-2011 31,426 118 0.4 5,560 20 0.4 2005-2011 24,817 113 0.5 4,264 18 0.4 Page 12

Information Requests Responses Labrador Island Transmission Link Table 5 (Northern Peninsula) and Table 6 (Central and Eastern Newfoundland) show the assessment area if the buffer is 1,000 m on both sides of the right-of-way (i.e., 2.06 km wide). Table 5. Seasonal caribou occurrence in the Northern Peninsula Region Area for the 60 m RoW + 1,000 m buffer (reference Figure SDSS1-1 to Figure SDSS1-4). Dataset Region (km 2 ) 100% Kernel 66% Kernel Area (km 2 ) % in Area Winter Region (km 2 ) Area (km 2 ) % in Area 1979-2011 10,319 282 2.7 2,111 115 5.4 2005-2011 9,806 290 3.0 1,979 111 5.6 Spring 1979-2011 8,808 272 3.1 1,867 118 6.3 2005-2011 8,582 277 3.2 1,558 120 7.7 Summer 1979-2011 7,194 236 3.3 1,738 70 4.0 2005-2011 6,734 231 3.4 1,562 73 4.7 Fall 1979-2011 8,685 292 3.4 2,051 76 3.7 2005-2011 8,188 291 3.6 1,713 69 4.0 Table 6. Seasonal caribou occurrence in the Central and Eastern Newfoundland Region Area of 60 m RoW + 1,000m buffer (reference Figure SDSS1-5 to Figure SDSS1-8). Dataset Region (km 2 ) 100% Kernel 66% Kernel Area (km 2 ) % in Area Winter Region (km 2 ) Area (km 2 ) % in Area 1979-2011 36,678 232 0.6 5,765 28 0.5 2005-2011 33,253 231 0.7 5,172 27 0.5 Spring 1979-2011 35,845 288 0.8 6,251 48 0.8 2005-2011 29,989 256 0.9 4,435 49 1.1 Summer 1979-2011 34,025 281 0.8 5,407 75 1.4 2005-2011 33,933 222 0.7 5,252 77 1.5 Fall 1979-2011 31,426 228 0.7 5,650 37 0.67 2005-2011 24,817 218 0.9 4,264 33 0.8 Page 13

Information Requests Responses Labrador Island Transmission Link Table 7 (Northern Peninsula) and Table 8 (Central and Eastern Newfoundland) show the implications on the assessment area if the potential buffer is 2,000 m on both sides of the right-of-way (i.e., 4.06 km). Table 7. Seasonal caribou occurrence in the Northern Peninsula Region Area for the 60 m RoW + 2,000 m buffer (reference Figure SDSS1-1 to SDSS1-4). Dataset Region (km 2 ) 100% Kernel 66% Kernel Area (km 2 ) % in Area Winter Region (km 2 ) Area (km 2 ) % in Area 1979-2011 10,319 851 8.2 2,111 293 13.9 2005-2011 9,806 856 8.7 1,978 288 14.6 Spring 1979-2011 8,808 812 9.2 1,867 313 16.8 2005-2011 8,582 825 9.6 1,558 318 20.4 Summer 1979-2011 7,194 609 8.5 1,738 231 13.3 2005-2011 6,734 606 9.0 1,562 234 15.0 Fall 1979-2011 8,685 788 9.1 2,051 269 13.1 2005-2011 8,188 777 9.5 1,713 249 14.5 Table 8. Seasonal caribou occurrence in the Central and Eastern Newfoundland Region Area for the 60 m RoW + 2,000m buffer (reference Figure SDSS1-5 to SDSS1-8). Dataset Region (km 2 ) 100% Kernel 66% Kernel Area (km 2 ) % in Area Winter Region (km 2 ) Area (km 2 ) % in Area 1979-2011 36,678 708 1.9 5,765 72 1.2 2005-2011 33,253 709 2.1 5,172 71 1.4 Spring 1979-2011 35,845 808 2.3 6,251 157 2.5 2005-2011 29,989 703 2.3 4,435 160 3.6 Summer 1979-2011 34,025 857 2.5 5,407 191 3.5 2005-2011 33,933 666 2.0 5,262 197 3.7 Fall 1979-2011 31,426 687 2.2 5,650 88 1.6 2005-2011 24,817 646 2.6 4,263 78 1.8 Page 14

Information Requests Responses Labrador Island Transmission Link Nalcor focussed the examination of habitat affected within the 66% occupancy kernels, as this is where the collared caribou are concentrating; the 100% kernel represents the total distribution area of the collared caribou. The amount of directly affected habitat for Newfoundland used to inform the EIS, with the 20% contingency added to be conservative and precautionary, was 5 km 2 of Primary Core, 11 km 2 of Secondary Core, and 28 km 2 of Occupancy areas, as shown in Table 12.3.5-4 of the EIS. Using the 2005 to 2011 data from Table 1 and Table 2, the 100% kernel habitat (i.e., occupancy) directly affected by the Project (i.e., the 60 m wide right-of-way without the 20% contingency) was calculated to be 8.7 km 2 (fall) for the Northern Peninsula and 7.4 km 2 (spring) for Central and Eastern Newfoundland. As such, the actual habitat alteration/loss resulting from the Project will be much less than the amount used to inform the assessment in the EIS. This supports the findings of the EIS, which were conservative and precautionary. Habitat loss due to sensory disturbance of woodland caribou varies with location and disturbance type, as discussed in the EIS (Chapter 12, Section 12.3.5.2, Table 12.3.5-1 and Section 12.3.6.2, Table 12.3.6-1). For example, Dyer et al. (2001) found that avoidance of open habitat was significant only within 250 m from roads in northern Alberta. Polfus et al. (2011) found avoidance by mountain caribou of high-use roads by 2 km and low-use roads by 1 km. However, mountain caribou may respond differently to disturbance than woodland caribou, either due to actual behavioural differences or due to the effects of terrain amplifying sensory disturbance (for example the effects of acoustics and increased visibility on slopes adjacent to valley bottom roads). The actual sensitivity of woodland caribou within the Project area to sensory disturbance is unknown. However, taking all anthropogenic disturbances into account (including industrial facilities, mines and other large sources of sensory disturbance) Environment Canada applied a 500 m buffer to anthropogenic features to represent the combined effects of increased predation and avoidance on woodland caribou at the national scale (Environment Canada 2011). Therefore, as discussed and evaluated in the EIS, the 500 m buffer is likely precautionary and appropriate to determine the extent of disturbance from the Project (i.e., a transmission line) on caribou and their habitat. With increased assessment buffer widths (i.e., from 500 m to 1,000 m and 2,000 m) there is an increase in the size and percentage of each kernel overlapped, as expected. However, the additional information provided by examining the 1,000 m and 2,000 m buffers does not change any of the proposed mitigation or the conclusions of the EIS. The assessment areas for the 500 m buffer scenario for all the seasons, are less than 5% of the areas of each of the regions delineated in the EIS (i.e., the 15 km wide corridor that corresponds to the ELC habitat map). These values would be even less, if the entire RSA for the Island of Newfoundland was considered in the calculations. Further, the literature indicates that caribou exhibit reduced levels of use of the 500 m buffer, and not complete avoidance, which illustrates the conservativeness of the findings. The figures prepared from the two telemetry datasets (i.e., 1979-2011 and 2005-2011) exhibit similar characteristics especially for the Northern Peninsula as the routing is through core areas of the range. There are consistent patterns for Central and Eastern Newfoundland as well but the overlap with the range is more on the periphery. Regardless where there is overlap, there appears to be little change. Page 15

Information Requests Responses Labrador Island Transmission Link Nalcor did not compare the 1979 to 2004 with the 2005-to 2011 data, as the quality of the datasets were not comparable, and would have added a source of error that could not be quantified. The additional information presented by Nalcor in this response supports the predictions and findings of the environmental assessment as it relates to woodland caribou in Newfoundland and the conclusion that The effects of the Project relative to baseline are not likely to affect the viability or recovery of woodland Caribou populations in Central and Southeastern Labrador and Newfoundland. Therefore, the Project is not likely to result in significant adverse environmental effects on Caribou. As such, the mitigation and follow-up programs proposed in the EIS are considered appropriate and no changes are proposed by Nalcor. However, information in this response does suggest that the amount of habitat in the 66% occupancy kernel that overlaps with the right-of-way with a 500 m buffer is greatest in winter and spring in the Northern Peninsula Region (Table 3) and greatest in summer in the Central and Eastern Newfoundland Region (Table 4). This information can be considered during the scheduling of construction activities to minimize any potential adverse effects of the Project on woodland caribou. Page 16

Information Requests Responses Labrador Island Transmission Link Requesting Organization: Department of Environment and Conservation Information Request No.: DEC, Sustainable Development and Strategic Science Division 2 Reference: Caribou and Their Predators Component Study; Volume 2B, Section 12.3 Caribou Information Requested: Examine validity of Newfoundland caribou habitat quality description As part of the baseline environment description, Nalcor completed an Ecological Land Classification (ELC) of an approximate 15 km wide by 1,100 km long area at a scale of 1:50,000. Each ecotype identified in the ELC was qualified as to its importance for caribou during winter and during the calving/post-calving period. With these assigned values, Primary, Secondary, and Tertiary classed habitat were mapped so that the various areas of interest in terms of overlap with these different quality habitats could be quantified. To examine the validity of this approach using the new information provided by SDSS, Nalcor proposes to: Review all recently received information to ensure assigned habitat quality values for each ecotype are consistent with the latest understanding. Any changes, particularly those dealing with primary quality values, would result in a recalculation of the amount of Primary habitat affected by the proposed Project; The analysis will use the same seasons as the kernel analysis: Spring (May and June), Summer (July to Sept.), Autumn (Oct and Nov), and Winter (Dec to April), all dates inclusive. Overlay the 66% and 100% kernel shape files on the ELC (with the assigned caribou habitat values for the corresponding winter and calving/post-calving periods) to examine the relationship between distribution and habitat; Display, quantify and discuss the amount of 66% and 100% kernel shape files that overlap Primary habitat for winter and calving/post-calving periods for the Northern Peninsula AND for Central and Eastern Newfoundland regions; and Describe implications of this additional information on the environmental assessment predictions in the EA. Page 1

Information Requests Responses Labrador Island Transmission Link Response: All recently received information from the NLDEC was reviewed by Nalcor to ensure that the assigned habitat quality values for each ecotype were consistent with the latest understanding. Included with this information was the recently prepared ARGOS and GPS telemetry data set for Newfoundland caribou. Through the assistance of the Sustainable Development and Strategic Sciences branch (SDSS; K. Lewis 2012 pers. comm.), inferences of seasonal habitat preference were derived from a use versus availability analysis when the telemetry dataset was overlain on the Ecological Land Classification (ELC) completed for the Labrador-Island Transmission Link EIS). This analysis allows for a direct examination of the importance of each habitat type for a caribou population. Habitats that are used in greater proportion (> 15%) to their availability are considered to be primary quality habitat that is of greatest importance for that season. Those habitats used approximately in proportion (+ 15%) to their availability are considered to be of secondary quality for caribou. Habitats used in lower proportion (< 15%) to their availability are considered to be avoided by caribou for that season and are described as being of tertiary quality. The results of the use versus availability analysis completed by SDSS led to an adjustment in the seasonal importance or perceived quality of habitat types for caribou within the ELC. The seasonal habitat values were assigned for each region where they overlap the 99.9% and 66% woodland caribou probability of occupancy kernels. All relevant analyses were completed using the ARGOS and GPS telemetry datasets from 1979-2011 (Figure SDSS2-1 to Figure SDSS2-8) and from 2005-2011 (Figure SDSS2-9 to Figure SDSS2-16). Page 2