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/
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
1