Encana Shallow Gas Infill Development in the CFB Suffield
Total Page：16
File Type：pdf, Size：1020Kb
EnCana Shallow Gas Infill Development in IR Due Date: the CFB Suffield National Wildlife Area CEAA File #05-07-15620 August 2nd, 2007 IR Requested By: Federal Government IR No. Page CEAA-EIS-001 1 #Terr – 2 –C Reference: Volume 1, Section 1.3.2.1, Page 1-8 Preamble: EnCana comments on the primary approvals required under the Regulatory Framework. Request: GOC recommends that EnCana specify the requirements of the Master Access Agreement and the Partial Assignment Agreement as they apply to the approval process for development applications within the National Wildlife Area, formerly known as the Riverbank Zone, Middle Sandhills, and Mixed Grassland areas; specify the role of the Base Commander and the Suffield Environmental Advisory Committee and how the Project will conform to the Agreements. Response: The above-referenced Agreements (the “Agreements”) speak for themselves. EnCana does not purport to limit, expand or otherwise interpret the Agreements. EnCana remains bound by, and committed to, the Agreements. However, the Agreements clearly prescribe that: (i) NWA development applications are to be made to the EUB; (ii) the EUB shall seek the opinion of SEAC (the “Opinion”) in respect of such applications within the Riverbank and Middle Sandhill zones; but, (iii) the EUB shall not be bound by the Opinion. The Base Commander has no role in the approval process but may “give or refuse consent to,” or “order the performance or cessation of,” an act or thing relating to NWA development only on the unanimous recommendation of SEAC and only in the following circumstances: (i) within the Riverbank and Middle Sandhill zones; and, (ii) for the purpose of “developing natural gas as discreetly as possible” following “the development of protection measures.” In EnCana's view its policies and procedures as detailed in the EIS conform to all requirements of the Agreements. EnCana Shallow Gas Infill Development in IR Due Date: the CFB Suffield National Wildlife Area CEAA File #05-07-15620 August 2nd, 2007 IR Requested By: IR No. Page Federal Government CEAA-EIS-001 1 #Terr – 4 –A Reference: Volume 1, Section 2.2.1, Page 2-15 Preamble: EnCana states, “Once preliminary locations are chosen and any outstanding potential environmental issues are identified, then all locations will be field-checked… to collect additional site-specific data and to ensure each location is suitable with respect to terrain, wildlife, vegetation, and other environmental concerns, before construction”. Request: GOC recommends that EnCana provide the size of the area (dimensions in metres) surrounding the proposed well location and the size of the area surrounding the proposed pipeline routing/access trail that will be field-checked to prevent proximity to rare/sensitive species, and the months in which these field-checks will occur. GOC recommends that EnCana explain how the time of year of the field-checks will affect the ability to identify rare/sensitive vegetative species and the steps to overcome any deficiencies in detectability. Response: Please see the response to Terr 189a. EnCana will hire professionally designated experts to conduct surveys during the plant growing season; therefore, EnCana is confident that rare plants will be identified. EnCana Shallow Gas Infill Development in IR Due Date: the CFB Suffield National Wildlife Area CEAA File #05-07-15620 August 2nd, 2007 IR Requested By: IR No. Page Federal Government CEAA-EIS-001 1 #Terr – 5 –A Reference: Volume 1, Section 2.2.2, Page 2-16 and Volume 1, Section I.4, Page I-15, Point 78 Preamble: EnCana states “that all equipment will arrive in a clean condition to minimize the risk of weed introduction”. EnCana also states that “prior to first entry of the NWA project area, and before entering specified areas, equipment must be clean and free of mud, vegetation and visible oil, gas and grease leaks”. Request: 1) GOC recommends that EnCana clarify the location (i.e. edge of base, edge of NWA, proposed well site, or other) that will be the location “that all equipment will arrive in a clean condition”. 2) GOC recommends that EnCana explain the mitigating measures to prevent undesirable weed seed collection, distribution and transport from existing NWA trails and pipelines with undesirable species to new well locations or other locations susceptible to invasion. 3) GOC recommends that EnCana outline the measures it will take to ensure that vehicles/machinery access the NWA in a clean condition. GOC recommends EnCana clarify the term “first entry” (i.e. first entry of the vehicle to the NWA and all subsequent entries unchecked, or all entries into the NWA, or other). Response: 1) Vehicles will arrive in a clean condition at first point of access to the Suffield Block. 2) By confining construction activities to the vegetative dormant season, access will be taken after the seed of undesirable vegetation has already matured and dropped, thus preventing vehicle transport. Potential distribution by operational access during the growing season is partially mitigated by the increased of risk of fire, thereby requiring operators to be diligent by regularly checking, inspecting and cleaning the vehicle undercarriages for any plant material that may have collected. Equipment and vehicles accessing the NWA during construction activities will be required to arrive in a clean condition, thereby limiting the risk of distribution. 3) Vehicle cleanliness is first the responsibility of the operator of the vehicle. Vehicles that do not meet the expectations of the environmental inspector will be required to leave the worksite. The environmental inspector will continually ensure vehicle cleanliness. First entry of vehicles has potential for introduction of undesirable species to the Suffield EnCana Shallow Gas Infill Development in IR Due Date: the CFB Suffield National Wildlife Area CEAA File #05-07-15620 August 2nd, 2007 IR Requested By: IR No. Page Federal Government CEAA-EIS-001 1 #Terr – 5 –A Block. That is not to say that “first entry” is the only point at which vehicles are evaluated for cleanliness. As previously mentioned, the environmental inspector will ensure throughout the project that vehicles are clean. EnCana Shallow Gas Infill Development in IR Due Date: the CFB Suffield National Wildlife Area CEAA File #05-07-15620 August 2nd, 2007 IR Requested By: IR No. Page Federal Government CEAA-EIS-001 1 #Terr – 6 –A Reference: Volume 1, Section 2.2.5.1, Page 2-23 Preamble: EnCana states that “on average, two industry (EnCana) vehicles enter the NWA each day”. Request: GOC recommends that EnCana provide the documentation of past vehicle access to the NWA to support this statement, and specify how vehicle access intensity will change during each phase of the Project. GOC recommends that EnCana provide the predicted change in the number of vehicles accessing the NWA for the proposed project, completed on a per month basis, as the impact will vary depending on the season. Response: Please note that the number referenced in the preamble is based on operation of the existing wells. The number of vehicles entering the NWA will vary with each phase of the Project. In the pre-construction phase, a limited number of crews will enter the NWA. These include baseline mapping crews and environmental specialists. This would occur during the spring/summer months (May to Aug). In the construction phase, as many as 30 vehicles per day may travel in and out of the NWA. This traffic is expected to have a minimal effect as there will be no increase in traffic volumes on SH 844 (the western route through CFB Suffield). If Box Springs Road is used instead of SH 844, 30 additional vehicles per day will increase traffic by 1%. Damage to roads will be insignificant as construction will occur during the winter months. During the spring thaw, vehicles will be required to obey posted vehicle weight restrictions and closures due to wet weather restrictions. During the operations phase, traffic will be minimal because there will be no change in the number of operators that EnCana currently employs, and thus minimal increases in traffic as the additional wells will be visited on the operator runs to the wells nearby. Traffic requirements for decommissioning and abandonment are not yet known, but will be less than during the operations phase (on average). Please see Volume 5, Table 4-15 for a summary of residual impact from traffic. EnCana Shallow Gas Infill Development in IR Due Date: the CFB Suffield National Wildlife Area CEAA File #05-07-15620 August 2nd, 2007 IR Requested By: Federal Government IR No. Page CEAA-EIS-001 1 #Terr – 14 –A Reference: Volume 1, Section H.2.2, Page H-4 Preamble: EnCana states that it will “handle topsoil and the soil seed bank in a manner that conserves soil quality to a standard that is at least equivalent to that which existed prior to disturbance and is of sufficient quality that a stand of native vegetation can be established that is self-sustaining and produces an accumulation of litter and an aerial canopy cover that is sufficient to maintain site stability to a level no greater than the Soil Loss Tolerance that is applicable for the site. Where topsoil has been lost or revegetation has failed because of poor soil quality, add organic matter amendment that does not contain seeds of unwanted species. Guidelines are contained in Attachments”. Request: GOC recommends that EnCana detail the steps taken to handle topsoil to maintain soil quality and where topsoil quality has been compromised, the steps taken to increase topsoil quality to a level of equal or greater quality and the methods used to determine said quality. GOC recommends that EnCana define the Soil Loss Tolerance as applicable to the NWA, a protected site.