EnCana Shallow Gas Infill Development in the CFB Suffield National

Wildlife Area – Assessment of Impacts to Soils, Vegetation, Rare Plants,

Reclamation Planning and Ecosystem Integrity –

Report No. 2 (Interveners Submissions)

Prepared for

Joint Review Panel - EnCana Shallow Gas Infill Development in the

Suffield National Wildlife Area

Prepared by

Jay Woosaree

Alberta Research Council

PO Bag 4000

Vegreville, AB

August 15, 2008

TABLE OF CONTENTS

TABLE OF CONTENTS................................................................................................................ i

EXECUTIVE SUMMARY ............................................................................................................ ii

1.0 INTRODUCTION............................................................................................................ 1

1.1 Review Objectives ........................................................................................................... 2

2.0 DOCUMENT REVIEWED.............................................................................................. 3

3.0 GENERAL OBSERVATIONS AND COMMENTS ..................................................... 5

3.1 Government of Canada .................................................................................................. 5

3.1.1 Department of National Defence .................................................................................. 5

3.1.2 Natural Resources Canada........................................................................................... 13

3.1.3 Department of Fisheries and Oceans.......................................................................... 14

3.1.4 Agriculture Canada....................................................................................................... 15

3.1.5 Environment Canada .................................................................................................... 15

3.1.6 Parks Canada ................................................................................................................. 21

3.1.7 Brad Stelfox’s Comments on Cumulative Effects Assessment of EnCana

Shallow Gas Infill Development.................................................................................. 21

3.1.8 NWA’s Management plan............................................................................................ 25

3.1.9 Suffield Environmental Advisory Committee/Suffield Industry Range

Control Ltd. .................................................................................................................... 26

3.1.10 Cheryl Bradley’s Submission Regarding Footprint, Soils and Vegetation............ 27

4.0 CONCLUSION .............................................................................................................. 27

5.0 REFERENCES ................................................................................................................ 31

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EXECUTIVE SUMMARY

The Canadian Forces Base Suffield National Wildlife Area (CFB Suffield NWA) is an

ecologically unique area of mixed grass prairie that is home to over 1,100 species of

plants, mammals, birds, reptiles, amphibians and insects and of which 14 species are

listed as species at risks in Canada. In 2003, the CFB Suffield NWA was declared a

protected area to assert the Government of Canada’s intention to preserve critical

wildlife habitat and to protect species at risks.

The proponent “EnCana Corporation” proposed to drill 1275 shallow gas wells within

the boundaries of its existing developed shallow gas field in the CFB Suffield NWA.

Jay Woosaree of the Alberta Research Council was contracted to provide advisory

services to the Joint Review Panel on analysis of the Environmental Impact Statement

(EIS), with regard to its impacts, and proposed mitigation measures pertaining to soils,

vegetation, rare plants and reclamation planning.

After reviewing the submissions from the Government of Canada and the major

environmental groups, several concerns with regard to EnCana’s Environmental Impact

Statement (EIS) were raised. The main issues included the following:

1. incomplete or insufficient information on the description of the proposed project

and related activities;

2. incomplete information on the description and characterization of the baseline

information;

3. uncertainties regarding environmental effects, predictions and analysis, and

cumulative effects;

4. uncertainties regarding effectiveness of the measures to mitigate significant

adverse environmental effects and the timeline for ecosystem recovery;

5. uncertainties regarding the effects of the project on species at risk (SAR) and their

critical habitat;

6. key environmental effects of the project on Base activities, including ecological

research capacity and cattle grazing;

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7. the NWA is a reservoir of a rare prairie habitat and associated biota; last remnant

of mixed grass prairie in North America and implies that the proposed gas infill

project should not proceed.

Department of National Defense (DND), especially as the land owner is overly

concerned of cumulative effects and wants to ensure that the capacity of the land, taking

into account military training, oil and gas, livestock/wildlife is not surpassed.

There are 14 species at risk in the Suffield NWA. A recovery plan for many of the species

identified within the NWA has to be developed, in order to abide by legislation at

described in Species at Risk Act (SARA). EnCana will have to apply for a permit before

any activities are conducted near a habitat that is deemed critical to the survival of

wildlife and plants, although many of the rare plants preferred disturbed areas, like

roadsides. EnCana have to demonstrate that its activities will help with conservation if

these species and that their habitat are protected. It will be a challenge to address the

needs of all the species in the area during well installation and operation.

A huge problem with invasive plant and weedy species already exists in the Suffield

NWA. Disturbed areas associated with roads and trails are the prime contributor. With

the proposed gas infill project, there is the potential that increased traffic will further

exacerbate the situation through the dispersal of seeds.

Information contained in the Suffield Industry Range Control (SIRC) and Suffield

Environmental Advisory committee (SEAC) report raise some concerns with operational

issues, compliance and with inadequate vegetation on some sites. However, these

reports also point to some good examples of best practices and revegetation techniques

leading to some sites fully recovered to nearly its pre-disturbed condition. There is also

an indication of EnCana’s willingness to cooperate with the CFB Base by funding several

research projects for a variety of wildlife studies in the NWA, including seed caches

created by Ord’s kangaroo rat and improved seed mixes. Reclamation practices, as they

relate to oil and gas activities, have evolved over the past three decades. Coupled with

best practices (erosion control, weed management strategies and reduced well visits

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(remote metering SCADA - Supervisory Control and Data Acquisition), avoidance of

critical habitat and obeying setback distances, effects from infill drilling can be

minimized.

The DND management plan is deficient in many respects. It has a vision but lacks

strategy on how to achieve its goals – preserving the integrity of the Suffield NWA. To

protect diversity, there should be some desired outcomes of what one wants and also the

feasibility and constraints. The Government of Canada is concerned with the integrity of

the Suffield NWA but have taken “a laissez faire approach” when it comes to the

management of invasive species and weeds in the NWA.

There is indication that bench mark data were being collected by DND staff and that

information could be better used to prevent impact if it was made available to the land

users, including EnCana. It also appears that a certain level of mistrust has been

developing since about 1999, which serves no good when it comes to protecting the

Suffield NWA.

Mitigation, at best should have taken into account the potential for restoration the land

to the pre-disturbance conditions. Depending on aspects and influences within the

landscapes and given the engineering constraints, the PDA (Pre-development Site

Assessment) approach is justifiable. DND staff must participate in that process.

Mitigation measures at best will sensitize us to the “trade-offs” that come with industrial

development, whether military or oil and gas on this unique landscape.

With regard to seeding disturbed areas, wild harvest seeds are sometimes not advisable

due to the difficulty in controlling weed seed content given so many weed and invasive

species were identified in the Suffield National Wildlife Area.

With regard to the effectiveness of the EIS, regular monitoring will be essential to

discover and rectify any impacts that were not predicted and to also ensure compliance

with restoration efforts and guidelines as set by the SARA and DND.

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v

On a final note, the Government of Alberta has stated that environmental liabilities from

mining and conventional oil recovery will not be passed on to future generations.

Protected areas such as the CFB Suffield NWA are designated so that future generations

can know the Majesty of the Earth as we know it today.

Recommendations

This is not to say the project is going to go ahead, but should the project proceed, the

following recommendation might be useful:

1. Constrained areas such as steep gullies and slopes are avoided as they can be

difficult to reclaim.

2. Setback distances so as to minimize project activities on species at risk ought to

be adhered to if an estimated 50 to 100 preliminary well locations are predicted

to fall within the specidfied 100m buffer.

3. Analysis of gaps indentified in the EIS to be completed in order to get an

understanding of the level of impact already occurring in the NWA.

4. Habitat loss and fragmentation have large impacts on wildlife and these should

be minimized whenever possible.

5. Appropriate management plans to ensure the protection of ecosystems within

the NWA must be in place to ensure that gas extraction activities do not impact

wildlife and their habitats.

6. Loss of habitat critical to species-at-risk should not be permitted.

7. To reduce cumulative effects of industrial activity, it may be useful to require

that abandoned or decommissioned sites are restored before additional sites can

are established.

8. A simplified quasi process to handle issues with operating in the NWA.

Sometimes the role of SEAC, SIRC and SGAC is not clear.

9. There should be a close scrutiny of all project activities as it appears that in the

past there was a lack of environmental inspectors to monitor environmental

effects.

1.0 INTRODUCTION

Jay Woosaree of the Alberta Research Council was contracted to provide advisory

services to the Joint Review Panel on analysis of the Environmental Impact Statement

(EIS), its impacts, and proposed mitigation measures pertaining to soils, vegetation, rare

plants and reclamation planning with regard to EnCana’s proposed Shallow Gas Infill

Drilling Project at CFB Suffield’s National Wildlife Area. Report # 2 dealt with the

similar matters based on information received from the interveners and through the

information requests.

Canadian Forces Base (CFB) Suffield National Wildlife Area (NWA) is part of a network

of NWAs established in June 2003 to protect critical habitats that are important to a wide

range of species that fall under the Species At Risk Act (Canadian Forces Based Suffield

NWA Management Strategy, Pp. 1-3). Examples of such species include: Burrowing

Owl, Peregrine Falcon, Loggerhead Shrike, Ord’s Kangaroo Rat – (Endangered) Sage

Grouse, tiny cryptanthe and sand verbena. In addition to the uniqueness of this habitat

in Canada the NWA also provides numerous goods and services such as military

training, resource extraction and cattle grazing. However, the Suffield NWA also

represents the last remaining of contiguous native mixed-grass prairie, an ecosystem

type which has been largely destroyed by agriculture and other human activities in

Canada. Thus, the Suffield NWA plays a critical role in the maintenance, and potential

recovery, of species unique to prairie habitats, and the mandate of Department of

National Defense (DND) is to ensure the long-term sustainable ecological carrying

capacity of this area.

Natural gas exploration and development began in 1975 in CFB Suffield, including the

NWA. However, drilling for deep gas and oil were prohibited in the NWA because of

the high degree of disturbance associated with this activity. Recently, EnCana

submitted a proposal to drill, over a period of three years, up to 1275 new shallow gas

wells in the Suffield NWA. This work would include construction, operation,

decommissioning, abandonment, and reclamation of wells sites and all associated

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infrastructure (e.g. roads) and activities. In addition, EnCana would like to drill three

wells at surface locations within the Suffield NWA.

Industrial activity within the Suffield NWA is prohibited without a permit, and permits

are only issued if the proposed activity does not interfere with the conservation of

wildlife (including direct mortality, habitat loss, etc.). EnCana commissioned an

Environmental Impact Statement (EIS) to determine if the proposed project would

impact wildlife in the NWA, the degree of that impact, and potential mitigation

approaches. In response to the EIS report, a variety of agencies (Department of National

Defence (DND), Environment Canada (EC), Natural Resources Canada (NRC),

Department of Fisheries and Oceans Canada (DFO), and Parks Canada (PC)) involved in

managing the Suffield NWA and the wildlife and habitats found in the area provided

written evaluations of the EIS, including identification of gaps in study design, data

collection, analyses, conclusions, and proposed management approaches.

The various stakeholders are directly concerned with ecological integrity and protecting

ecosystem components of the Suffield NWA and that the impacts from existing

development are still being observed. The key question with the proposed shallow gas

infill project in the Suffield NWA is “how can we respect and protect the qualities of the

NWA while still recognizing and allowing development and other land uses on this

pristine and endangered landscapes”?

1.1 Review Objectives

The primary objective of this technical review is to examine the materials provided by

the major interveners, namely the Government of Canada and the Environmental

Groups as they relate to the quality of information presented in the EIS.

The second objective is to provide advisory services to the Joint Review Panel (JRP) on

matters related to adverse impacts on the natural ecological processes of the Suffield

NWA.

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This review was undertaken not to present an answer to the question, “Should the

proposed EnCana shallow gas infill development in the Suffield NWA be approved?”

I have examined all the related materials, however not all of them are specifically

discussed in this technical review. For example, I have reviewed the submission made

by Garry Trottier, June 16th, 2008 as to why the “EnCana application should be denied

and that the JRP is not the place for making dispositions on well licenses (page 2,

paragraph 2)”. However, I could not comment on the JRP. My goal was to provide

advisory services to the JRP. I have also liaised with Dr. Troy Whidden, the JRP

independent consultant on wildlife issues with matters related to habitat suitability for

wild life in post reclamation and in general with regard to the EIS and by the

interveners. In addition, I have also consulted with (Brian Eaton, my colleague at the

Alberta Research Council) on issues related to ecosystems, habitat, and biota.

2.0 DOCUMENT REVIEWED

In addition to information provided in the EIS, the materials reviewed include those

presented by major interveners that are filed with the Canadian Environmental

Assessment Agency (CEAA). These are:

a. Government of Canada Submission 420, including submissions from the

Department of National Defence, Environment Canada, Natural Resources

Canada, Fisheries and Oceans Canada, Agriculture Canada, and Parks

Canada; updates on above submissions, including those from Natural

Resources Canada, and Environment Canada;

b. “Ecosystem impacts of historical shallow gas wells within the CFB Suffield

National Wildlife Area” by J. Rowland (2008);

c. Environmental coalition, submissions 421 , 422 and 550;

d. Suffield Environmental Advisory Committee (SEAC) - Olaf Jensen and Rob

Kennedy, submission. Submission 470;

e. Suffield Industry Range Control Ltd. Submission 445;

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f. Canadian Forces Base Suffield Range Standing Orders. Chapter 7-Oil and gas

activity protocols. 31 pp;

g. Brent Smith, March 2007 - Assessment of agronomic species invasion from

pipeline right-of-way at CFB Suffield National Wildlife;

h. Brent Smith and Andrew Taylor. December 21, 2007. Assessment of residual

crested wheatgrass lease site footprint and invasion from old pipelines to

new pipelines.

i. Brent Smith and Andrew Taylor. December 21, 2007. Comparison of

vegetation parameters between on and off lease areas after minimal

disturbance shallow gas development within the CFB Suffield National

Wildlife.

j. Canadian Forces Base Suffield National Wildlife Area Management Strategy.

k. Alberta Wilderness Association- Cliff Wallis; re: critical habitat for species at

risk;

l. Entomological Society of Alberta – Re: insect fauna;

m. EUB Application No. 1435831;

n. Federation of Alberta Naturalists, submission 411 and 548;

o. Entomological Society of Alberta, submission 545;

p. Garry Trottier, submissions 430 and 533;

q. Society for Grassland Naturalists – Thomas Michael Power;

r. Society for Grassland Naturalists – Henry Binder;

s. Alberta Wilderness Association and Nature Canada – Cleve R. Wershler:

Rare plants and rare ecological communities: wetland, wildlife, biodiversity;

t. Nature Canada – Johanna McNulty; the vision of National wildlife

management plan;

u. SEAC – Minutes of the AGM June 2006;

v. Douglas Hutton. Submission 423;

w. Nature Canada. Submission 407;

x. Federation of Alberta Naturalist. Submission 411;

y. Jacques Whitford AXYS Ltd. Inventory of selected wetlands in the CFB

Suffield Main Training Area. May 2008;

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z. EnCana’s response Miss Collier ‘s email of April 13th, April 17t h and letter of

May 1st. EnCana’s letterhead was not dated;

aa. Suffield Environmental Advisory Committee. 1999 – 2006. Minutes of

meetings with the Base Commander and industry;

bb. Suffield Grazing Advisory Committee. 2006. Context and Guiding Principles

for SGAC. Annex E of 2006 Report to DND;

cc. Rob Longair, Submission 427;

dd. Dennis Baresco, submission 408;

ee. Environment Canada – Setback distance guidelines. Prairie Plant Species at

Risk;

ff. Office of the Auditor General. 2008. Status Report of the Commissioner of the

Environment and Sustainable development to the House of Commons;

gg. Trican Well Service Ltd. Submission 401;

hh. Calfrac Well Services Ltd. Submission 383;

ii. Joyce Hildebrand. Submission 414;

jj. Weatherford partnership. Submission 393;

kk. Alberta Energy. Submission 406;

ll. Review of the proposed 2005 Oil and Gas drilling programs for CFB Suffield.

1262-1 (G3 Bio);

mm. Biological Survey;

nn. Northern EnviroSearch Ltd. 2008. Effects of oil and gas development on

grassland birds;

oo. Flint Energy Services Ltd. Submission 403;

pp. Milt Roney. Submission 400;

qq. Beacon Oilfield Services Ltd. Submission 432.

3.0 GENERAL OBSERVATIONS AND COMMENTS

3.1 Government of Canada

3.1.1 Department of National Defence

The Department of National Defence as the responsible authority for the Suffield NWA,

found that the information contained in the EIS (Volume 3, Terrestrial Biophysical

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Assessment) was insufficient to assess the potential for the proposed project to cause

significant adverse environmental effects, and that substantial additional information is

required before the review panel can reach a conclusion regarding the proposed shallow

gas infill project (page 11, last paragraph). DND provided a list of 61 recommendations

to the proponent, which provides an indication of the extent to which the EIS was

lacking key information (pages 122-131). The request for additional data is justified

when the potential impact of the project and the lack of key information in the EIS are

considered as a whole.

The main issues that DND had with the EIS for the proposed project included the

following (page 10, third paragraph):

1) incomplete or insufficient information on the description of the project and

related activities

2) incomplete information on the description and characterization of the baseline

information

3) uncertainties regarding environmental effects, predictions and analysis, and

cumulative effects

4) uncertainties regarding effectiveness of the measures to mitigate significant

adverse environmental effects

5) uncertainties regarding the effects of the project on species at risk (SAR) and their

critical habitat

6) incomplete information on alternative means analysis

7) key environmental effects of the project on Base activities, including ecological

research capacity and cattle grazing

DND examined the impacts of historical shallow gas wells in the NWA to determine the

short- and long-term effects of this type of activity on the ecology and biota of the area

(Rowland 2008). This study examined the impacts of wellsites and pipelines on various

ecological components in the Suffield NWA. The percent cover of native plant species,

for example, was found to be significantly higher on control transects than on impacted

transects for 8 of 10 comparisons (comparisons were made between two treatment types

[well, pipeline], 3 year classes [1985, 1997, 2000], and 2 soil types [loam, sand]). Percent

6

cover of non-native species was higher on impacted transects than control transects in 6

of 10 comparisons; for the remaining 4, there was no difference between control and

treatment transects. There was significantly lower native species diversity on impacted

transects than control transects in 8 of 10 comparisons, with the other 2 being non-

significant, and significantly higher non-native species diversity on impacted transects

in 6 of 10 comparisons.

Taken together, these findings suggest that there are both short- and long-term impacts

related to gas extraction activities in the NWA. Increase in bare ground areas at

impacted sites was generally related to a decrease in native species percent cover, and an

increase in non-native plant species percent cover (Rowland 2008, page 27, paragraph 2).

The production of bare ground, which provides a route of invasion by non-native plant

species, results in a potentially serious impact to the ecological integrity of the NWA

(Rowland 2008, page 27, paragraph 3). Impacts after 22 years of development are still

being observed in the NWA (Rowland 2008; page 27, paragraph 3)

In addition, the establishment of wellsites and associated infrastructure in close

proximity to ephemeral and permanent wetlands in the NWA was seen as a cause for

concern, as wetlands are a valued ecosystem component in the NWA and can be

compromised by nearby development (Rowland 2008, page 28, paragraph 3).

Overall, Rowland (2008) concludes that there are a number of long-term effects to the

ecological integrity of the CFB Suffield NWA related to installation and operation of

shallow gas wells in the area. Therefore, appropriate management plans to ensure the

protection of ecosystems within the NWA must be in place to ensure gas extraction

activities do not impact wildlife, and wildlife habitat.

Reclamation Plan

The efficacy of the mitigation and compensation measures to be used when installing,

servicing, and de-commissioning shallow gas wells in CFB Suffield NWA is a cause for

concern. Environment Canada anticipates the proposed project will expand the existing

footprint (page 194, paragraph 2) as mitigation might take longer than 50 years.

7

Once the soil is disturbed there is always potential for the introduction of invasive

species and weedy species. Mitigation and compensation measures must take into

account the potential for the introduction of non-native species, soil erosion, direct and

indirect impacts on wildlife, long-term sustainability of the site. By sustainability I am

referring to the ability of the plant communities to reproduce themselves, biomass

production, litter production and nutrient cycling.

Although DND has requested that the proponent provide “definitive timelines for the

return to pre-disturbance conditions” (page 131, bullet f), there is much evidence

(Rowland, 2008; DND Audit, 2005) to suggest that impacted sites are not comparable to

pre-disturbance conditions even after approximately 10-20 years. Restoration is a long-

term process and at times can be difficult (Suding et al. 2004), or to predict the success of

restoration activities based on short-term monitoring or trajectories (Zedler and

Callaway 1999; Cortina et al. 2006; Herrick et al. 2006). Factors that can reduce the

restoration success include frequent burning, lack of or low organic content in the soil,

time of seeding, erosion issues and adapted plant species.

Reclamation is usually just the planting of some form of cover to stabilize the soil and

prevent erosion and provide function, while restoration aims to return a degraded site to

a plant cover that is protective, but also valuable in a conservation sense, and has long-

term sustainability (Hobbs and Norton 1996). Restoration is important for a number of

reasons. Restoration can increase the rate at which sites approach reference sites in

terms of similarity of species composition (McLachlan and Knispel 2005), and should be

considered as a viable approach when restoring impacted lands related to the proposed

project.

DND describes that “The Proponent states that “Reclamation will seek to maintain or

improve range health. Disturbed areas will be re-seeded immediately following cleanup

of the disturbance or as soon as possible to stabilize soil and reduce non-native species

invasion on exposed areas” (page 120, last paragraph) . Using adapted native species

whether from local harvesting or cultivated ecotypes, one can restore disturbances to a

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state comparable to pre-disturbed conditions, thus maintaining the characteristics

(composition, structure, function and withstanding Nature’s disturbance regimes) of the

ecosystem. I see it difficult to understand why some impacts (lack of vegetation or

increased bare ground) are still being felt in certain areas of the NWA. Figure 1 shows a

site in the “Special Areas” near Hanna, Alberta where re-grassing (convert back from

non-native forages) and better farming methods 12 years ago have led to a native

pasture that fairs much better than the pre-disturbed area.

Figure 2. Restored plains rough fescue grassland in the mixed grass prairie near Hanna

(Photo taken first week of October 2007).

During my visit to the Suffield NWA (February 5th , 2008) it appeared that DND had

some test plots of various plant species. Information on provenance testing could be

valuable if incorporated in seed mixes that the proponent can use. It will also address

concerns with the genetics of the seeds that we proposed for the NWA. If harvested hay

from a nearby field is to be acquired, one has to ensure that the area is free from crested

wheatgrass, weedy species and other non-native species.

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Timeline to reclamation success

If the restoration objectives include the ability to “jump start” the natural succession

pathway by means of using late seral species in the seed mix, we can shorten the length

of time required for a disturbed site to recover to its natural state. Therefore I have to

agree with EnCana statement that it is possible to improve range health if proper

mitigation techniques are implemented. With proper monitoring, impacts of the

proposed gas infill along with other land use can be measured by evaluating its effects

on the flora and fauna. Biological effects to monitor included but not limited to: effects

on plant productivity, fitness of the seeded mixtures (how it withstands the elements),

litter amount and decomposition and occurrence of weedy and non-native species.

Therefore, EnCana should focus more on a restoration approach as to how to accelerate

the recovery process. Example of successful reclamation is described in SEAC’s notes

with reference to Site 1 (ANNEX G, 4500-12, Jul 04, paragraph 2). Using EnCana’s long

history in the Suffield area, EnCana has baseline data to build up restoration efforts and

determine some trajectory timelines. A revised reclamation plan should provide

information on how the restoration plan will proceed and potential endpoints, including

timelines, followed with monitoring and an action plan in case indicators of successful

restoration are not observed.

Cummulative effects

With regard to cumulative effects, DND; Cleve Wershler, page 21, paragraph 5) the

approach EnCana used to determine incremental footprint was not appropriate. The

anthropogenic footprint created by features detectable using digitized air photos could

not differentiate habitat types such as those that include crested wheatgrass. Ground

truthing would have differentiated between the crested wheatgrass and other native

vegetation cover.

With regards to effects of wellsite density on prairie integrity, it is impossible to

determine if a reference condition approach has not been used. Thus, if there is a

threshold function in terms of how wellsites affect native range condition (e.g. 4 wells

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per section has a great impact, but incremental wells has relatively little impact) it was

not to be detected by the sampling design and analysis used in the EIS.

It should have been compared to a control area. In a “Sand Country Almanac”, Aldo

Leopold says that “we do not know how good a performance to expect of a healthy land

unless we have a wild for comparison”. Even in the 1940’s, it was known that we need to

have a control area to relate to as otherwise we would not know how healthy or sick the

land was. I raise this point because the incremental footprint size is estimated at

approximately 0.5% (EIS Volume 3,page 7-1) for now, should EnCana decide in the

future (let’s say 10-20 years), to increase the number of wellsites, a claim can be made

that footprint size is still negligible where in fact potential impact could have been

increased. To establish a cause-and-effect relationship, it is important to have some

controls or benchmark data to which we can measure performances of potential

mitigation techniques.

In addition, to reduce cumulative effects on this sensible landscapes, it would be

appropriate if some of the impacted areas including abandoned wellsites, sites that do

not have adequate cover ( (DND Audit, 2005; series of photos in the Appendix;) and

trails could be revegetated using a appropriate native seed mixes.

Invasive species

Cleve Wershler claims that “EnCana fails to recognise the deterioration of the grassland

ecosystem (page 13, paragraph 6) … and the proposed planting of a mixture of grasses,

including non-native forms will create a community that is different in structure and

species”. Similar concerns with regard to native prairie integrity by environment

Canada (Government of Canada, page 155, paragraphs 2, 3, and 4) were raised.

The spread of invasive species and weeds is one of the greatest factors that will influence

the integrity of the Suffield NWA. Between 1977 and 1982, a network of natural gas

pipelines and wells were installed in native mixed grass prairie at the CFB Suffield

NWA in southeastern Alberta, Canada. Crested wheatgrass was seeded and seeds

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dispersed onto adjacent undisturbed native prairie have led to more occurrences of

crested wheatgrass. It was not clear (Rowland, 2008) how the influence of grazing and

military manoeuvres contribute to the spread of these non-native species. While

monitoring aids in bringing awareness to the issue, there should be an action plan

involving all land users to assist in controlling existing crested wheatgrass. Furthermore,

due to their prolific seed production, invasive species will target sites that have even

slight disturbances and especially those sites that have fine soils. It is important to

eradicate the new seedlings before they become prolific (Brent Smith, 2007 page 18,

paragraph 1).

The Suffield Grazing Advisory Committee (SGAC) identified crested wheatgrass

introduction during reclamation of industrial sites as a threat to future integrity (SGAC

Report 2006, Annex D) in the Suffield NWA. Attention should also be paid to the control

of many agricultural weedy species and non-native species found within wetland areas

in the Suffield NWA. Bradley ([2008] page 23-25) and Jacques Whitford AXYS Ltd.

(2008) described many of the introduced species found in the Suffield NWA. These

include: Bromus inermis (smooth awnless brome grass), Bromus tectorum (downy chess

brome), Dactylis glomerata (orchard grass), Elytrigia repens [=Agropyron repens](quack

grass), Phleum pretense (timothy), Poa pratensis (Kentucky bluegrass), Polypogon

monspeliensis (rabbitfoot grass), Setaria viridis (foxtail), Polygonum arenastrum (common

knotweed), Rumex stenophyllus (narrow-leaved dock), Axyris amaranthoides (Russian

pigweed), Chenopodium album (common lambsquarters), Kochia scoparia (kochia), Salsola

kali (Russian thistle), Alyssum desertorum (yellow alyssum), Capsella bursa-pastoris

(Shepherd’s purse), Descurainia sophia (flixweed), Erysimum cheiranthoides (wormseed

mustard), Sisymbrium altissimum (tumble mustard), Thlaspi arvense (field pennycress),

Medicago lupulina (black medic), Medicago sativa (alfalfa), Melilotus officianilis (yellow

sweet clover), Trifolium hybridum (alsike clover), Euphorbia esula (leafy spurge), Lappula

squarrosa (bluebur), Linaria dalmatica (broad-leaved toad-flax), Linaria vulgaris (butter-

and-eggs), Plantago major (common plaintain), Artemisia absinthium (absinthe wormwood

[another invasive species]) , Cirsium arvense (creeping thistle), Crepis tectorum (annual

hawk’s beard), Gnaphalium uliginosum (low cudweed), Lactuca serriola (prickly lettuce),

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Sonchus arvensis (perennial sow-thistle), Taraxacum officinale (common dandelion) and

Tragopogon dubius (common goat’s-beard).

3.1.2 Natural Resources Canada

The comments of Natural Resources Canada were largely restricted to geology and

groundwater impacts of the proposed project. However, some of these comments are

relevant to biota and ecological integrity. For example, EnCana proposes to work in

areas of active sand dunes, which are important habitat for Ord’s Kangaroo Rat and

other dune dependant species. Although EnCana states that the potential impact on

these dunes is insignificant, Natural Resources Canada concludes that declines in this

habitat type in the NWA make it important that potential impacts on sand dune habitat

stemming from the proposed project be examined more thoroughly (page 343, last

paragraph). Natural Resources Canada also suggests that EnCana provide a constraints

map for the entire NWA where proposed wellsites would be located, and including all

roads and trails used to access wells during the operational phase of the project (page

346, first paragraph), and provide additional detail on the Environmental Effects

Monitoring Plan that is required as part of the EIS (page 347, first paragraph). The

overall conclusion of Natural Resources Canada appears to be that additional detail is

required for some aspects of the proposed project, though adequate information was

provided for other aspects, such as climate change trends (page 348, first paragraph) and

impacts on quantity and quality of groundwater (page 351, fifth paragraph).

Natural Resources Canada reviewed the supplemental submission of an Environmental

Protection Plan and Environmental Monitoring Plan by EnCana and concluded that a

variety of problems existed with these plans. These included the fact that, despite clear

rules for constraints mapping to avoid placement of wells and access features in

environmentally sensitive areas, the preliminary well locations actually proposed were

located to optimize natural gas reservoir recovery (Natural Resources Canada’s review

of EPP and EMP, page 28, paragraphs 4 and 5). In addition, NRC concluded that the

requirements of the monitoring program were not clearly outlined in the EPP (NRC’s

review of EPP and EMP, page 30, third paragraph), and that the EMP did not appear to

fulfill the requirements of a follow-up program (NRC’s review of EPP and EMP, page

13

30, fifth paragraph). NRC concluded that additional detail was necessary before the

adequacy of the EMP could be fully assessed.

Environmentally sensitive areas such as wetlands or “prairie potholes” as it is often

referred on the prairies are important habitat for wildlife as it provides them with water,

food, cover and serve as breeding ground. There is also a greater number of plant

species that are associated with these wetlands, leading to greater productivity.

Furthermore, wetlands play an important role in the hydrogeological cycle. In the EIS,

approximately 400 wellsites were to occur within wetland boundaries. EnCana stated

that no well sitings will occur within a wetland (IR No. CEAA-EIS-019; Fan-23).

Setback distances for both wetlands and for “valued ecosystem components” such as for

those species affected by SARA (Recovery Team for Plant Species at Risk in the Prairie

Provinces, 2008, pages 2-3) must be observed. These serve two purposes. In case there is

a spillage during development, these important habitats are protected from

contamination and more importantly we do not know the population sizes that are

required to maintain a viable population for both endangered plants and wildlife.

3.1.3 Department of Fisheries and Oceans

The Department of Fisheries and Oceans, after reviewing the proposed EnCana project,

concluded that the project was unlikely to cause “significant adverse effects to fish and

fish habitat” as long as the suggested mitigation measures were implemented during the

project (page 355, paragraph 3). The measures suggested such as minimized vegetation

removal, site revegetated immediately, spill contingency plan, etc. (pages 358-359)

included efforts to minimize production of sediment that could enter water courses, and

prevention of waste materials and chemicals from entering water courses (page 358,

paragraph 4). Overall, DFO had no major concerns with the proposed project and I

agree that if the proposed mitigation techniques are properly implemented, the proposal

would not result in any impacts to fish habitat in the South Saskatchewan River.

14

3.1.4 Agriculture Canada

Agriculture Canada personnel reviewed the EnCana EIS and supplementary materials,

focusing on the potential impact of the project on grazing in the area. Agriculture

Canada concluded that, if EnCana followed the mitigation and consultation measures as

outlined in the EIS and supplementary documents (e.g. Supplemental Information

Requests) the project should not have significant effects on grazing in the area (page 371,

paragraph 2). My only suggestion is that livestock stocking rates may have to be

adjusted depending on mitigation effectiveness and carrying capacity of the area during

the early years of revegetation.

3.1.5 Environment Canada

CFB Suffield NWA is one of the few large contiguous areas of native prairie left in

Canada, and its ecological integrity must be preserved. Environment Canada, through a

detailed review process, found that the information provided by EnCana EIS was not

adequate to assess the potential detrimental effects of the proposed project to this

important area, and provided a list of 16 areas in which the EIS was considered

inadequate (pages 232-242). The independent analyses done by Environment Canada

suggested that negative effects from current industrial activities in the Suffield NWA

have already occurred, and that further activity in the area would exacerbate these

effects, and potentially endanger the recovery and survival of several species-at-risk that

occur in the area. Therefore, Environment Canada concluded that no additional

industrial activity should be permitted until it could be demonstrated by EnCana that

this activity would not negatively affect any species-at-risk, critical habitat, or the

ecological integrity of the area (page 144, paragraph 2).

Environment Canada, following a review of a supplemental submission of an

Environmental Protection Plan and Environmental Monitoring Plan by EnCana,

concluded that there were significant uncertainties in the plans regarding impact

analysis, mitigation, cumulative effects, and the potential for negative environmental

effects, especially for species-at-risk.

15

Species at Risk

EnCana’s response to the Federation of Alberta Naturalist (IR No. CEAA-EIS-019; Fan-

23) states that “EnCana will not drill any wells in wetlands….will never have wells

within 15 m of a wetland and in exceptional cases, will only have wells between

15-100 m of a wetland. By not having wells within a wetland help to address concerns

raised with regard to birds (Alberta Wilderness Association June 27, 2008), setback

distances for species at risk habitat (Government of Canada, page 191) and insects

habitat (CEAA document 545). My only concern is that some of the setback distances is

debateable until research is completed to fill some of the uncertainties associated with

“how far is far enough” before there is an impact to any endangered species and until a

recovery plan is completed for species that fall under SARA’s jurisdiction.

I completely agree with Environment Canada that SARA permits should be obtained for

all species at risk as identified (Table 1) in the Suffield NWA. The needs of each species

should be assessed, and appropriate buffers established (Goates et al. 2007). In addition,

critical activity periods (e.g. emergence of snakes from dens, movement periods for

pronghorns) should be considered when planning industrial activities.

Table 1. List of species that are of concern/threatened or endangered in the Suffield

NWA

Slender Mouse-Ear Cress Threatened Schedule 1

Smooth Goosefoot Threatened Schedule 1

Tiny Cryptanthe Endangered Schedule 1

Small flowered Sand Verbena Endangered Schedule 1

Western Harvest Mouse Endangered Schedule 3

Ord's Kangaroo Rat Endangered Schedule 1

Burrowing Owl Endangered Schedule 1

Gold-edged Gem Endangered Schedule 1

Lake Sturgeon Endangered Not Listed

Sprague's Pipit Threatened Schedule 1

Loggerhead Shrike Threatened Schedule 1

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Common Nighthawk Schedule 1 Not Listed

McCown's Longspur Special Concern Schedule 1

Long billed Curlew Concern Schedule 1

Northern Leopard Frog Concern Schedule 1

Great Plains Toad Concern Schedule 1

Ferruginous Hawk Special Concern Schedule 3

Short eared Owl Special Concern Schedule 3

For species for which a recovery plan does not exist, appropriate setback distances for

known wildlife species should be observed or even such areas be avoided until research

gaps (effects on wildlife, avoidance responses, distribution shifts, habituation, migration

barriers and decreased productivity) is completed. Mitigation measures in the EPP and

the EEMP I can address some of these issues as seen in EnCana’s past experiences

(ANNEX G, 4500-12 Jul 04 (page 6, paragraphs 1 and 2).

It is important to manage and minimize impacts in the Suffield NWA as it is one of few

remnants of natural mixed grass prairie. Parameters such as species richness can be

maximized if disturbances mimic natural disturbances, such as fire and grazing (Collins

and Barber 1985). Cattle grazing, for example, is a good mimic of historical bison

grazing, and helps maintain biodiversity in grassland ecosystems (West 1993). In a

landscape being used to extract resources, it is imperative that connectivity across

ecological units be maintained, that keystone and threatened species be conserved, and

that invasive species be controlled (Fischer et al. 2006). Connectivity is essential,

especially for small animals to sustain flow of organism, genes, nutrients, water, energy

plus materials that builds and sustain habitat (Forman et al., 2003, page 227).

I supported DND’s remarks (Brent Smith, 2007; page 23) that research is required to

determine how birds and other small wildlife populations are affected and how rare and

provincially/federally listed species found adjacent to pipelines are affected.

17

With regard to the “Pre-disturbed assessment” (PDA), DND must be present when such

activity is being conducted, so that there is consensus as to the final siting of a particular

wellsite or pipeline.

Project footprint

The lack of baseline surveys and identification of potential project-related impacts , size

of footprint as reflected by site seeded with crested grass between 1977 and 1982

(Government of Canada, page 192, paragraph 6; Bradley, page 20, paragraph 2) were

considered a cause for concern (Environment Canada’s review of EPP and EMP, page 1,

paragraph 1). Environment Canada concluded that the EPP and EMP were insufficient

to warrant approval of the proposed project at the present time.

There is evidence that these disturbed areas are important routes of penetration by

invasive species (Larson 2003), from which they can spread (Hansen and Clevenger

2005), and that vehicles are important vectors of non-native seed dispersal (von der

Lippe and Kowarik 2007). Care must be taken to minimize introduction of non-native

and invasive native species during well construction, operation, and decommissioning.

It is interesting to note that 25 years ago, limited or no native seed sources existed for

seeding on native landscapes. The prescription of the day was to use non-native species

or tame forages as it is often referred, be used to control erosion, provide cover and for

forages. The Suffield NWA was no exception. Much crested wheat grass was planted on

the prairies to prevent wind erosion. Later, tame forages became popular for

revegetation as there were no commercially available alternative seeds. On my visit to

the area, I noticed that much of the road allowances had been seeded in the past to

crested wheatgrass and with brome grass near the river banks and a number of weed

species near the cattle pen. It is known that the spread of crested wheatgrass can lead to

reduction of biodiversity, yet over the previous years DND did not have a plan to deal

with the eradication of crested wheatgrass.

18

Today, there exists various native seed sources and along with new technologies one can

go a long way to reduce cumulative impacts. The reclamation plan includes “Canada

bluegrass” as one of the species that could be used in the seed mix. That seed mix will be

revised and in the February 7th workshop, EnCana stated that all disturbances including

those in the Suffield NWA will be seeded to native species.

With regard to the lack of information on seed mixes (Bradley, 2008; page 32, bullet 11),

there is nothing wrong with using slender wheatgrass as a rapid colonizer. It is a native

species, competes well with weeds, it is a short lived species (~5 years) and it does allow

late seral species to occur naturally in the area in which it was seeded. Its appearance

may not blend with the natural landscapes, but it provides the required landscape

function.

DND is considering harvesting seeds for its own use mixes (Bradley, 2008; page 32,

bullet 11), one has to be careful that more weeds and non-natives are not spread.

Proponents of wild harvesting seed sources believe that maintaining the integrity of

lineages adapted to local conditions is important because crossing with foreign genetic

materials leads to outbreeding depression (Guerrant, 1996). On the other side,

proponent believe that using multiple source materials combine a species genetic within

an individual site or ecologically similar sites (Jones, 1997) and this approach reduce

risks for revegetation failure and provide the genetic diversity that allows species to

adapt to future conditions.

Thus there is a need for an improved management plan involving all land users

(including EnCana) to address funding to control the spread of invasive and weedy

species in the Suffield NWA and to change focus from reclamation to restoration.

Combined with revegetation of decommissioned sites, and improved revegetation tools

(new seed mixes, erosion control measures, and minimum disturbances) footprint sizes

can be kept to a minimum.

19

Concern over mitigation effectiveness

Environment Canada stated “despite a long history of operating on CFB Suffield, the

proponent has not demonstrated that it can effectively reclaim large disturbed areas.”

Consequently, Gary Trottier’s (Submission 533; page 4,) is concerned that “SEAC does

not support further drilling in the NWA until such time as the recommended

environmental assessment and monitoring program has been developed and

implemented” and Bradley (page 28, paragraph 2) disagrees with the mitigation

measures proposed in the EnCana EIS (Vol 3, sec 2.8.2 and Sec 3.7) .

The following is a statement from the minutes of SEAC’s meeting. (Annex G, 4500-12,

Jul 4, 2004 Reece Operational Observations) makes note of how Wellsite 1 is reclaimed. It

reads:

“The reclamation of this particular wellsite appears to be progressing

very well. Assuming this site is reflective of the overall reclamation

practices being employed by the industry, it aptly demonstrates the

effective incorporation of an abandoned industrial site back into

surrounding natural landscape. This should provide all parties with the

confidence and certainty “end of life” obligations are being properly

addressed”.

Furthermore, ANNEX G, 4500-12 Jul 04 (page 6, paragraph 1 and 2) reads:

“EnCana’s record on environmental actions is excellent. Low impact

drilling, lease clearance, expansion of SEAC protocols to south block of

NWA, snake conservation plans including rerouting and seasonal drilling

restriction zone to all of the snake conservation area. Support for several

wildlife studies on the Base. Supported 1999 deep rights agreement

excluding the NWA from surface access”… “Military initiatives /

recognition are also outstanding” (page 9, paragraph 2). Annex A,

August 2005 (page 6, paragraph 2).

Recently, it seems that there is a disconnect between EnCana and the CFB Suffield

(SEAC’s Minutes of the AGM June 2006; page 7, paragraph 2).

20

With regard to minimal disturbance techniques (Bradley, page 29, paragraph 2) there are

some indications (SEAC’s Minutes of the AGM June 2006; ANNEX D, 4500-1-49, April

13, 2007; Serial 10, 12, 13) that mitigation measures were not to be overly effective

(braided trails, soils issues related to winter drilling, no attempt to control crested

wheatgrass on access trails ). Due to landscapes influences (steep slopes, decreased top

soil, reduced organic matter and wind) might impede revegetation success, thus

requiring additional efforts from the proponent.

3.1.6 Parks Canada

Parks Canada reviewed the EnCana EIS was limited to consideration of heritage

resources, and did not consider ecological attributes. One of their suggestions is to

consult First Nations with regard to archaeological site in the Suffield NWA (page 384,

paragraph 2).

With regard to Siksika Nation’s concern over traditional lands use (IR Siksika 2),

Traditional Ecological Knowledge (TEK) regarding vegetation (IR Siksika 3, 5),

importance of wetlands to the Siksika’s cultural and spiritual way of life vegetation (IR

Siksika 9), and Siksika’s historical presence in the Suffield NWA (IR Siksika 11), EnCana

is negotiating a Memorandum of Agreement with the Siksika Nation to dealt with the

issues raised (EnCana’s response August 2nd, 2007).

3.1.7 Brad Stelfox’s Comments on Cumulative Effects Assessment of EnCana Shallow

Gas Infill Development

With regard to methodologies used to address cumulative effects including the “natural

range of variability (Page 3, paragraph 3) , I agree with the statement that without solid

data prior to the arrival of industrial land uses, it is difficult to make reference against

which one can compare any future landscapes influence. Actually, there is a lack of

baseline data in both space and time in Alberta that we can relate to. We learned from

Rowland (2008) that impacts of industrial activities 20 years ago are still being felt in the

Suffield NWA. The use of the Monte Carlo method despite its randomness and

uniformity is still based on assumptions; however it can provide a “proactive approach”

to an environmental management plan.

21

Although ALCES is gaining popularity (page 3, figure 1) among land managers

(Southern Alberta Landscape project, page 3 paragraph 3), I am not sure if it is “the

preferred methodology” in determining cumulative effects. As the range of natural

variability is approximated, it provides an attribute of some pre-disturbance landscapes

to post disturbance landscapes. I would prefer to see some studies on thresholds for the

NWA. Thresholds are desired as they allowed certain activities to proceed until the

magnitude of the effects reach a point at which we have to take actions.

With any new project, there is biological and a social component (Thomas et al, 1993)

and there is no common view of what level of risk is acceptable. With implementation of

an “EIS Environmental effects monitoring plan and having an adaptive environmental

management strategy for the Suffield NWA, it should not reach a point where the

integrity of the landscapes is further compromised. The map time series (page 5, figure

2) illustrate how land use trajectories, even at a 2 to 3% growth per year can compound

and a have a significant impact on the landscapes. This landscape is already impacted by

current activities. I would rather see resources geared towards addressing issues that

can further affect the integrity of the landscapes such as the spread of invasive species,

lack of vegetation cover and implementation of practices (remote monitoring, avoidance

of critical habitats, better tires on vehicles, etc.) that when combined lead to decreased

footprint sizes.

The EIS provides a theoretical explanation of the range of natural variability (fire,

wildlife grazing, wind erosion, weather patterns, etc). We need an approach that can in

reality take into account the natural range of variability and use that information to

determine some timelines as to when we can expect a particular site to be fully restored.

Having to wait 20-50 years for a site to adequately recover is too long and jeopardizes

the status of the Suffield NWA as a wildlife sanctuary. In the EIS EnCana did not

attempt to model the pre-industrial landscape with respect to ecosystem processes and

valued ecosystem components. Such concern (Bradley, Page 4, paragraph 5) argues the

need for modeling to define whether the landscape in the Suffield NWA already

experienced a significant change because of cumulative effects of other anthropogenic

22

(man-made) disturbances? What is the current trajectory of ecosystem processes and

components?

Apparently, there seems to be no benchmark data for CFB, (although at some point in my

review it appears that CFB Suffield was collecting biophysical data). In order to model

impact of development in the Suffield NWA, I would suggest that EnCana use the 30

years experience in the Suffield area. Using these vegetation data (plant cover, species

richness, bare ground, weedy species occurrences, plant density, etc) we can construct a

detrended correspondence analysis ((DCA), McCune and Grace, 2002) that ordinates

sample units and species in time. DCA can be used to examine the change in plant

communities over time, based on the time the wellsites were revegetated, how they

appear now and how they compared to our target, which is a reference area in the NWA.

The reference area can be from a number of transects in an undisturbed area of the

Suffield NWA. As an example (Figure 1) I introduce a DCA analysis from one of my

studies, where plant stands are grouped by year and 67% confidence ellipses are

produced using the using the JMP statistical package (SAS 2000).

23

Figure 1. Detrended Correspondence Analysis showing the plant community changes

from 2002 to 2006 from a revegetated wellsite in the Ribstone Creek Ecological Area

Control

At least with the DCA analysis, we have used known data that incorporates the range of

natural variability of the area through the year the data were collected. By evaluating the

trends, we can then derive some meaningful references as to where the mitigation

techniques are directing the dynamics of the plant stand with regard to the plant

community trajectories.

This type of cluster analysis follows a stepwise discriminant analysis, which is estimated

to be 95% accurate (Uresik, 1990). The use of ordination is sensitive to determine

changes in ecological stages (Uresik, 1990) and is precise, time-efficient and meet the

goals of resource managers, without the bias.

24

Ecosystems are diverse, complex and variable. The need for simplification and accuracy

is essential if we are to effectively remediate effects from industrial activities. Having a

suite of response/recovery indicators such as soil bulk density, organic matter content,

litter amount, presence of weeds, etc that reflects the facets of landscapes of the Suffield

NWA can lead to proper ecological risk assessment.

3.1.8 NWA’s Management plan

The Canadian Forces Base Suffield National Wildlife Area Management Strategy

describes the vision of the Suffield NWA (page 1, paragraph 5) and characterizes the

attributes and services of the NWA (page A-1). The plan appears to have been prepared

“on the fly”. I could not find more information to include benchmark data by which the

Suffield NWA can be sustainably managed, performance goal for the Suffield NWA,

measures and methods that were used to evaluate activities in the area. Examples: how

does the Base manage its own activities so that ecological integrity is maintained? What

methods are used to control weeds like Russian thistle and tumble weeds and invasive

species such as brome grass and crested wheatgrass? What research is ongoing in the

NWA and how do we communicate the results to all land users? How does DND deal

with issues arising in the NWA? How does DND elicit the land users, including

EnCana? What options are provided to the land users if a certain activity is deemed to

impact the landscapes? Example with setback distances. There will be times that there

will be no options due to the preservation of a critical habitat, but these approaches have

to be specified and communicated to all land users.

Many of the practices stated in the “Canadian Base Suffield Range Standing Orders”

(Chapter 7, Oil and Gas Activity Protocol) can be incorporated in the Suffield NWA

management plan. At least this way, all the information governing Suffield is contained

in one document and information can be easily located. It appears that there is too much

of a spider-web of quasi bodies (SEAC, SIRC, SGAC, SARA, etc). A properly develop

management plan can go a long way in de-conflict issues arising in the NWA and help

with mutual understanding.

25

3.1.9 Suffield Environmental Advisory Committee/Suffield Industry Range Control

Ltd.

The Suffield Environmental Advisory Committee (SEAC) was created to provide

advisory services to the Base Commander at CFB Suffield (page 2, paragraph.1) with

respect to environmental issues. The SEAC illustrates examples of concerns related to

the current oil and gas activities such as well in wetland (page 23, serial 21) proliferation

of trails; multiple trails; trail braiding (page 18, serial 16), crested wheatgrass along

wellsite access road (page 15, serial 10), concern over source of top soil (page 26, serial

27), hydrocarbon spills and effects near a wetland (page 25, serial 26).

Comprehensive monitoring is an essential function during the life cycle of a major

project such as the proposed shallow gas infill project to ensure mitigation measures as

proposed in the Environmental Effects Monitoring Plan are fully implemented and to

evaluate their effectiveness. There should also be severe and immediate consequences

implemented for project activities that do not respect the EEMP, such as cut concrete left

on site, garbage on site, hydrocarbon spill left on site, etc.

The SEAC’s commented that Alberta Environment has no statutory or regulatory role at

CFB Suffield (page 9, paragraph 1) and did not participate in the preparation of the

SEAC’s submissions. I believe that Alberta Environment’s participation is essential as

water permits fall under AENV jurisdictions. The Joint Review Panel (JRP) should ask

AENV how the proposed infill project would impact wetland conservation (re: water

extraction for the infill drilling). Jacques Whitford AXYS (May 2008) found that

disturbances may already affect many wetlands in the CFB Suffield (page3-80,

paragraph3) and that previous land use, namely agriculture and over-grazing, resulted

in range modification. Current land use is also influencing wetland health and function.

Additionally, Jacques Whitford AXYS (May 2008, page 3-32, paragraph 2) found 13

provincially/federally species at risk associated with various wetlands.

26

3.1.10 Cheryl Bradley’s Submission Regarding Footprint, Soils and Vegetation

A summary of the submission by Alberta Wilderness Association points to the fact that:

• Cumulative effects from increased development activity on the landscape are an

issue that must be addressed in land use planning. Also, that the decreased well

spacing for shallow gas development allowed by the EUB is of particular

concern, and should be addressed by SREM.

• The impact of the intensive level of activity for shallow gas development on

other traditional land uses, (i.e. livestock grazing) prairie recovery from the

impact of industrial disturbance and fragmentation, combined with current

stocking rates and grazing practices are unknown.

• Steep slopes, choppy sandhills and solonetzic or saline soils can be difficult to

reclaim and revegetate in the Dry Mixedgrass.

• There is a lack of field supervision of contractors by industry, resulting in

unnecessary impact and disturbance.

• Research and monitoring is required to accurately evaluate current minimal

disturbance procedures.

• There is insufficient research and information on reclamation and revegetation

strategies, and how they affect Species at Risk. It is recommended that

comparative studies be implemented to evaluate the effects of different

revegetation strategies on Species at Risk.

Many of these points are discussed in previous sections, namely under the Government

of Canada.

4.0 CONCLUSION

The CFB Suffield NWA is an ecologically unique area of mixed grass prairie that is home

to over 1,100 species of plants, mammals, birds, reptiles, amphibians and insects and of

which 14 species are listed as Species at Risk in Canada. In 2003, the CFB Suffield NWA

was declared a protected area to assert the Government of Canada’s intention to

preserve critical wildlife habitat and to protect Species at Risk.

27

After reviewing the submissions from the Government of Canada and the major

environmental groups, several concerns with regard to EnCana’s Environmental Impact

Statement (EIS) were raised. The main issues included the following:

1. Incomplete or insufficient information on the description of the proposed project

and related activities;

2. Incomplete information on the description and characterization of the baseline

information;

3. Uncertainties regarding environmental effects, predictions and analysis, and

cumulative effects;

4. Uncertainties regarding effectiveness of the measures to mitigate significant

adverse environmental effects and the timeline for ecosystem recovery;

5. Uncertainties regarding the effects of the project on Species at Risk (SAR) and

their critical habitat;

6. Incomplete information on alternative means analysis;

7. Key environmental effects of the project on CF Base activities, including

ecological research capacity and cattle grazing;

8. The NWA is a reservoir of a rare prairie habitat and associated biota; the last

remnant of mixed grass prairie in North America and implies that the proposed

gas infill project should not proceed.

The Department of National Defense (DND), especially as the land owner is overly

concerned of cumulative effects and wants to ensure that the capacity of the land, taking

into account military training, oil and gas, livestock/wildlife is not surpassed.

There are 14 species at risk in the Suffield NWA. A recovery plan for many of the species

identified within the NWA has to be developed, in order to abide by legislation as

described in Species at Risk Act (SARA). EnCana will have to apply for a permit before

any activities are conducted near a habitat that is deemed critical to the survival of

wildlife and plants. EnCana has to demonstrate that its activities will help with

conservation of these species and that their habitats are protected. It will be a challenge

to address the needs of all the species in the area during well installation and operation.

28

There is a huge problem with invasive plant and weedy species already existed in the

Suffield NWA. Disturbed areas associated with roads and trails are a prime contributor.

With the proposed gas infill project, there is the potential that increased traffic will

further exacerbate the situation through the dispersal of seeds.

Information contained in the Suffield Industry Range Control (SIRC) and Suffield

Environmental Advisory committee (SEAC) report raise some concerns with operational

issues, compliance and with inadequate vegetation on some sites. However, these

reports also point to some good examples of best practices and revegetation techniques

leading to some sites recovered to nearly pre-disturbed condition. There is also an

indication of EnCana’s willingness to cooperate with the CFB Base by funding several

research projects for a variety of wildlife studies in the NWA, including seed caches

created by Ord’s kangaroo rat and improved seed mixes. Reclamation practices, as they

relate to oil and gas activities, have evolved over the past three decades. These combined

with best practices (erosion control, weed management strategies and reduced well

visits through remote metering SCADA - Supervisory Control and Data Acquisition),

avoidance of critical habitat and obeying setback distances minimize effects from infill

drilling.

The DND management plan is deficient in many respects. It has a vision but no strategy

on how to achieve its goal – preserving the integrity of the Suffield NWA. To protect

diversity, there should be some desired outcomes and also the feasibility and

constraints. The Government of Canada is concerned with the integrity of the Suffield

NWA but have taken “a laissez faire approach” when it comes to management of

invasive species and weeds in the NWA.

There is indication that bench mark data were being collected by DND staff and that the

information could better be used to prevent impact, if it was made available to the land

users, including EnCana. It also appears there is a certain level of mistrust that has been

developing since 1999, which impedes protection of the Suffield NWA.

29

Mitigation should have taken into account the potential for restoration of the land to

pre-disturbance conditions. Depending on aspects and influences within the landscape

and given the engineering constraints, the PDA (Pre-development Site Assessment)

approach is justifiable and DND staff must participate in that process. Mitigation

measures will sensitize us to the “trade-offs” that come with industrial development,

whether military or oil & gas on this unique landscape.

With regard to seeding disturbed areas, wild harvest seed are sometimes not advisable

due to the difficulty in controlling weed seed content, given so many weed and invasive

species were identified in the Suffield National Wildlife Area”.

With regard to the effectiveness of the EIS, regular monitoring will be essential to

discover and rectify any impacts that were not predicted and to also ensure compliance

with restoration efforts and guidelines as set by SARA and DND.

On a final note, the Government of Alberta has stated that environmental liabilities from

mining and conventional oil recovery will not be passed on to future generations.

Protected areas such as the CFB Suffield NWA are designated so that future generations

can know the Majesty of the Earth as we know it today.

Recommendations

This is not to say the project is going to proceed, but should the project be undertaken,

the following recommendation might be useful:

1. Constrained areas such as steep gullies and slopes are avoided as they can be

difficult to reclaim.

2. Setback distances so as to minimize project activities on species at risk be

adhered to although an estimated 50 to 100 preliminary well locations are

predicted to fall within the specified 100m buffer.

3. Analysis on gaps indentified in the EIS to be completed in order to have an

understanding of the level of impact already occurring in the NWA.

30

4. Habitat loss and fragmentation have large impacts on wildlife and these should

be minimized wherever possible.

5. Appropriate management plan in place to ensure the protection of ecosystems

within the NWA to ensure gas extraction activities do not impact wildlife, and

their habitats.

6. Loss of habitat critical to Species-at-Risk should not be permitted.

7. To reduce cumulative effects of industrial activity, it may be useful to require

that abandoned or decommissioned sites are restored before additional sites can

be established.

8. A simplified quasi process to handle issues with operating in the NWA.

Sometimes the role of SEAC, SIRC and SGAC are not clear.

9. There should be a close scrutiny of all project activities as it appears that

historically there has been a lack of environmental inspectors to monitor

environmental effects.

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