<html><head></head><body><div style="color:#000; background-color:#fff; font-family:HelveticaNeue, Helvetica Neue, Helvetica, Arial, Lucida Grande, sans-serif;font-size:16px"><div id="yui_3_16_0_ym19_1_1476970997218_6022">Hi folks</div><div id="yui_3_16_0_ym19_1_1476970997218_6022"><br></div><div id="yui_3_16_0_ym19_1_1476970997218_6022">At the hearing I figured out several new ways on how the public can stop oil pipes beyond the scope of the NEB process. This is based on my personal knowledge and experience of how these individual systems work over the 16 years I've been monitoring public participation. I've participated personally at different levels of governance from municipal, provincial, federal and First Nation's and that gives me a unique insight on this issue. </div><div id="yui_3_16_0_ym19_1_1476970997218_6022"><br></div><div id="yui_3_16_0_ym19_1_1476970997218_6022" dir="ltr">1. Weakest point of these projects is Hydrology and Geo Engineering data. Work is NOT needed to be reasonably competed before an application for a project is filed with the NEB. In this case they only had 30% of the Engineering work done and it was by touching all issues lightly. Enbridge said 10% was completed, 20% forthcoming very soon, 90% is anticipated to be completed June 2017. So the need is there to focus on the actual criteria for submission standards at the NEB which could be implicated via the Environmental Bill of Rights or other policy mechanism.</div><div id="yui_3_16_0_ym19_1_1476970997218_6022" dir="ltr"><br></div><div id="yui_3_16_0_ym19_1_1476970997218_6022" dir="ltr">2.Quality of data for Engineering required for licencing fees for Municipalities, Hydro and Crown land owned properties demand 90% completeness of Engineering and Geotechnical reports. We can reasonably argue that the standards should be the same upon submission to avoid delay for all parties. In fact there is a Supreme Court ruling that was part of a First Nation's lawsuit that took place called the Regis Case that demands that all parties are informed of study results at the same time. That logic can be reasonably applied and the argument made that anything less than 90% completion is premature data. </div><div id="yui_3_16_0_ym19_1_1476970997218_6022" dir="ltr"><br></div><div id="yui_3_16_0_ym19_1_1476970997218_6022" dir="ltr">3. Enbridge claims the reason they file early is to identify issues early so they can craft their response specific to concerns but this is rubbish. They are doing this to limited the scope and save themselves money as a means to negate studying the totality of the actual footprint of the project which is why we should demand the 90% completion standards. Mandatory test times and methods are needed here. </div><div id="yui_3_16_0_ym19_1_1476970997218_6022" dir="ltr"><br></div><div id="yui_3_16_0_ym19_1_1476970997218_6022" dir="ltr">4.Beyond the scope of the NEB are continued opportunities for public engagement on these decisions because licencing agreements still have to be made at the Municipal level for tracts owned by Municipalities and Conservation Authorities. The public should have a say on that because Municipalities have Official Plans that bind them to critical habitat protection, source water protection, no net loss to wetlands etc. It might be easier to get the public to demand the city says no or to demand the implementation of further protective provisions to be implemented. Either process could kill a project with either a "no" or by simply bumping up the requirements for conditions of approval to render the project uneconomical. </div><div id="yui_3_16_0_ym19_1_1476970997218_6022" dir="ltr"><br></div><div id="yui_3_16_0_ym19_1_1476970997218_6022" dir="ltr">5. Because tracts owned by the Ministry of Transportation and Hydro are on Crown Lands, it likely requires further input from Indigenous people where the Crown and Territories overlap so there's oppertunity for further engagement with First Nation's people as well to seek accommodations with these groups before licencing agreements are approved. The Crown has the duty to consult according our Treaty Laws and I am certain Hydro and Ministry of Transportation have policies specific to these needs. It also reveals a possible motive behind the plans to privatize Hydro. </div><div id="yui_3_16_0_ym19_1_1476970997218_6022" dir="ltr"><br></div><div id="yui_3_16_0_ym19_1_1476970997218_6022" dir="ltr">Personally, as a strategist on a zero budget I would suggest these ideas as a way forward.</div><div id="yui_3_16_0_ym19_1_1476970997218_6022" dir="ltr"><br></div><div id="yui_3_16_0_ym19_1_1476970997218_6022" dir="ltr">1. Demand that the criteria for NEB applications to have that 90% completion before applications are submitted.</div><div id="yui_3_16_0_ym19_1_1476970997218_6022" dir="ltr"><br></div><div id="yui_3_16_0_ym19_1_1476970997218_6022" dir="ltr">2. Let First Nation's fight the good fight and economically support key cases like Chipppewas of the Thames vs. Line 9. </div><div id="yui_3_16_0_ym19_1_1476970997218_6022" dir="ltr"><br></div><div id="yui_3_16_0_ym19_1_1476970997218_6022" dir="ltr">3 Make sure the licencing agreements are in compliance with local source water protection, PPS and Municipal policies including provisions for critical habitat delineation, no net loss to wetlands etc. before licencing approvals are completed. Get the public engaged and vocal! We have until June 2017 before the Line 10 data is even ready to review at the municipal level so there is plenty of time. </div><div id="yui_3_16_0_ym19_1_1476970997218_6022" dir="ltr"><br></div><div id="yui_3_16_0_ym19_1_1476970997218_6022" dir="ltr">4. Demand that Hydro and MTO comply to provincial and federal laws specific to habitat protection and First Nation's Accommodations. </div><div id="yui_3_16_0_ym19_1_1476970997218_6022" dir="ltr"><br></div><div id="yui_3_16_0_ym19_1_1476970997218_6022" dir="ltr"><br></div><div id="yui_3_16_0_ym19_1_1476970997218_6022"><br></div><div id="yui_3_16_0_ym19_1_1476970997218_6022"><br></div></div></body></html>