Motion to Compel KM to supply adequate responses to FER IR 2 Feb 26

Delivered via online Filing

This filing can be viewed at:
http://docs.neb-one.gc.ca/fetch.asp?language=E&ID=A66957

Or See the PDF version here: Motion to compel KM to supply adequate responses to FER IR 2 Feb 26

__________________________________________________

To: National Energy Board “NEB” 444 Seventh Avenue SW
Calgary Alberta. T2P OX8

From: Board of Friends of Ecological Reserves
C/O Mike Fenger,  President, Friends of Ecological Reserves
511 Foul Bay Road

Victoria BC V8S 4G9

Attention: Sheri Young

Re: Hearing order OH-001-2014
Trans Mountain Pipelines ULC (“ (“Trans Mountain”)
Application for Trans Mountain Expansion Project
Notion of Motion to Compel Full and Adequate Responses to Information Requests (IRs)

Please find enclosed the notice of motion to compel full and adequate responses to IRs, filed on behalf of the Board of Friends of Ecological Reserves (FER). The filing is in the form of a Table with colour coding as follows:

FER would like to take this opportunity to state that we reviewed all responses. For the inadequate responses we have provided clarification to support that claim. We have also retained all IRs and responses as we have learned from the adequately answered responses too, and these need to remain part of the record.

We have provided links to documents wherever possible through footnotes. We have used endnotes to display maps or portions of references provided by TMX when needed to support understanding of IRs.

Adequate Responses

Inadequate responses

4, 5, 10, 11, 14, 16, 18,21, 23, 25, 26

1, 2, 3, 6, 7, 8, 9, 13, 15, 17, 19, 20, 24, 28, 29, 30, 31, 32.

Mike Fenger
President of Friends of Ecological Reserves
Garry Fletcher
Board member of Ecological Reserves

Cc: Board of Friends of Ecological Reserves

1

Update on FER Board Intervenor Work on Kinder Morgan/TMX project

In late January , we found out that we had been granted some funding for our work as Intervenors in the National Energy Board, Kinder Morgan Trans Mountain Pipeline Expansion  Project. We had applied in May of 2014. This link shows the location of the Board of Friends of Ecological Reserves Documents. https://docs.neb-one.gc.ca/ll-eng/llisapi.dll/Open/2450919 KM/TMX Responses

Sufficiency Review of the Information on Effects of Underwater Noise and the Potential for Ship Strikes from Marine Shipping on Marine Mammals in the Facilities Application for the Trans Mountain Expansion Project

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