Encana Shallow Gas Infill Development in the CFB 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: 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.

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

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.

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.

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. GOC recommends that EnCana clarify the location (Volume, Section, Figure, Table, Page) of the “Guidelines… contained in the Attachments” documents in regards to increasing soil quality. GOC recommends that EnCana detail previous efforts in preserving topsoil and soil seed bank, and the success of the efforts with respect to soil organic matter, and native species diversity.

Response: Steps taken to maintain soil quality: See Section H2.2, page H-4 of Appendix H; also the following supplemental information is provided:

Because oil and gas related disturbances are generally of relatively limited and contiguous areal extent and in some cases (such as pipelines) are of relatively short- term duration, topsoil is often replaced directly over a portion of the area from which it was stripped. For this reason, topsoil is typically stored as near as possible to the stripped or active operating area, but out of the way of construction or operations activities. In this way, topsoil handling is minimized, thereby minimizing the potential for losses in topsoil quality and quantity (AMEC 2001). For pipelines, topsoil is stored as one or more windrows, within the right-of-way.

In general, topsoil storage, specifically in stockpiles, has not had any severe or long- term effects on topsoil quality (AMEC 2001). The literature shows that most chemical changes can be rectified with the careful application of chemical fertilizers or manure, and that soil biota will revert to near pre-disturbance levels of activity within 1 to 3 years. Physical degradation of topsoil can be avoided by minimizing handling of 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 2 #Terr – 14 –A

topsoil by heavy equipment, stripping to proper depths and undertaking appropriate erosion control measures for stockpiles (AMEC 2001). Topsoil storage time should be kept to a minimum to improve the chances that seeds, rhizomes and microbes in the soil survive. Topsoil storage piles should have a low profile and must be revegetated or protected as soon as possible to prevent erosion and to sustain biological activity (Thurber et al, 1990). Stockpiles can also become contaminated with weeds and weed seeds that can cause revegetation problems on reclaimed areas later.

The preferred method of soil stabilization should take into consideration the duration of storage, the availability of services and materials and the potential for erosion based on the location’s climatic and topographical setting (AMEC 2001). In areas prone to wind erosion, soils stored, even for short periods of time, should be protected. Stabilization of stockpiles can be achieved by applying tackifiers or geotextiles, use of wind fences, or seeding with an appropriate cover crop (at half the normal rate) (Sinton and Pitchford 2002). They can prevent erosion for a few days through several weeks, depending on the product.

Methods used to determine soil quality: procedures outlined in the 1995 Reclamation Criteria for Wellsites, Batteries and Associated Facilities should be followed. Soil quality is determined through assessment of on and off-site soil depth, texture, compaction.

Soil Loss Tolerance (equals the rate of soil formation): see Appendix H; Section H2.2; Page H-4 Rangeland (upland): 4 t/ha/yr Connected to a waterbody: 2 t/ha/yr

Increasing Soil Quality (location of guidelines in documents): Volume 1; Appendix N; Section N.1; Pages N 3 and 4.

Use of minimal disturbance techniques such as ploughing in laterals and minimizing the overall well site footprint has contributed to the conservation of topsoil and the native seedbank. Paired pipeline sampling conducted by EnCana during the summer of 2006 has shown that the recovery of native vegetation using these techniques has facilitated the recovery of native plant integrity and by extension, soil quality and productivity.

References: Alberta Environment. 1995. Reclamation Criteria for Wellsites, Batteries and Associated Facilities. 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 3 #Terr – 14 –A

AMEC Earth and Environmental Ltd. 2001. Review of Revegetation Practices for Oil and Gas Disturbances in Western Canada. Submitted to: Petroleum Technology Alliance Canada. 100 pp.

Sinton, Heather and Christine Pitchford. 2002. Minimizing the Effects of Oil and Gas Activity on Native Prairie in Alberta. Published by Prairie Conservation Forum, Occasional Paper Number 4, 39 pgs.

Thurber Consultants Ltd., Land Resources Network Ltd. and Norwest Soil Research Ltd. 1990. Review of the Effects of Storage on Topsoil Quality.

Alberta Land Conservation and Reclamation Council Report No. RRTAC 90-5. 116 pp.

Reference: Volume 1, Section H.3.6.1, Page H-8

Preamble: EnCana states, “wild harvest seed is NOT recommended for vegetation because of the difficulty in controlling weed seed content and because of the uncertainty of the impact that harvesting may have on the donor site, especially if collected within the Suffield National Wildlife Area”.

Request: GOC recommends that EnCana explain with supporting documentation/evidence to qualify the claim that wild harvest seed from the Suffield NWA is not a viable option.

Response: On August 16, 2000, under the authorization of Base Commander Major Stuart Gibson (DND, Suffield) and field guidance of Sergeant Rick Smith (DND, Suffield), Dr. David Walker (revegetation consultant, Calgary), Dean Nernberg (Canadian Wildlife Service, Saskatoon), Andy Hammermeister (Native Plant Society of Saskatchewan, Saskatoon) and Etienne Soludre (University of Alberta graduate student, Edmonton) toured the NWA with the express purpose of locating sites suitable for harvesting native seed. Despite the fact that drought conditions had severely curtailed seed production, the group concluded that they had not seen any sites on the tour that met conditions necessary for harvesting wild seed efficiently and safely with mechanized equipment (tractor-drawn seed stripper, Prairie Habitats Inc., Argyle MB). The lack of large tracts of ground level enough for safely operating equipment, widespread presence of undesirable plants within stands of potential target species, and the paucity of relatively dense and contiguous stands of target species were all cited as reasons for the conclusion.

EnCana is not aware of any studies on the environmental impact on natural ecosystems of harvesting native seed but at least one regional environmental advocacy group, the Bow Valley Naturalists, has publicly objected to the practice in Banff National Park.

AEC Pipelines (a division of Alberta Energy Company, now part of EnCana) constructed pipelines to the west of the Suffield Block (AEC Express Pipeline in 1996) and across the Suffield Military Training Area (AEC Suffield Pipeline South in 1998 and AEC Suffield Pipeline North in 2000). An attempt was made to utilize wild harvested native seed on these projects. Certificates of analysis of seed considered for acquisition revealed that all seed lots contained seed of unwanted species and some were completely unsuitable and not purchased.

For example, a seed lot of a mixture of wild harvested needle and thread (Stipa comata) and porcupine grass (Stipa curtiseta) contained 1 seed of golden bean (Thermopsis 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-011 2 #Terr – 15 –B

rhombifolia), which, although a native legume, was listed at that time as a Prohibited Noxious Weed under the Canada Seed Act. Another example is a seed lot of wild harvested needle and thread that contained seed of downy brome (Bromus tectorum) and, although not restricted under the Canada Seeds Act nor the Alberta Weed Control Act, CFB Suffield has required no downy brome meaning that the seed lot was rejected for purchase. Another seed lot of needle and thread harvested by Dean Nernberg revealed that the 52 g sample contained 74 seeds of 3 exotic grasses, crested wheatgrass, Kentucky bluegrass, red fescue, and several exotic annual weeds.

Reference: Volume 1, Section H.3.6, Pages H-8 to H-10

Preamble: EnCana describes the advantages and disadvantages of each seed source (Wild-Harvest Seed, Cultivated Wild Harvest Seed, Unregistered Varieties (Cultivars) and Registered Varieties (Cultivars)).

Request: GOC recommends that EnCana define the type of seed source it will use for reclamation. GOC recommends that EnCana provide the location and source of its native seed mixtures with respect to provenance specificity if EnCana’s seed source is native. GOC recommends that EnCana explain how the proposed seed mixtures comply with DND seed mixture standards. Finally, GOC recommends that EnCana describe the proposed reclamation in the context of genetic-level conservation, and self-sustaining biologically diverse ecosystems.

Response: (1) Type of seed source

EnCana will consider all types of seed using the regulatory framework of the Canadian seed industry as a means to identify source and quality. The Canadian Seed Grower's Association (CSGA), under the authority of the Canadian Food Inspection Agency (CFIA), administers a system to track and label seed products that provide a guarantee of quality for seed products identified by cultivar name. The cultivar name and seed lot harvest number is displayed on the Certificate of Seed Analysis and corresponds with the Pedigreed Seed Label on the bag. This provides a means of identifying the place of origin (source), the location where the seed was produced (grown), and the purity (absence of undesirable species) and viability (germination).

Pedigreed seed materials used for food production, including native species, are termed Registered Varieties (cultivars). Pedigreed seed materials used for some other purpose than food production are termed an Unregistered Varieties. Both designations carry the same guarantee of quality and consistent performance.

Walsh western wheatgrass is an example of a Registered Variety of native grass. It was developed by Agriculture Canada, Lethbridge from an initial population of 468 plants collected from sites throughout southeastern Alberta and southwestern Saskatchewan. Other examples include Elbee northern wheatgrass, and two cultivars, Adanac and Revenue, of slender wheatgrass. Sodar streambank wheatgrass originated seed collected in a dry region of Oregon and after extensive testing by Agriculture Canada, Swift Current was designated a Registered Variety.

Native grass cultivars developed by the Alberta Research Council, Vegreville and currently marketed exclusively by Brett Young Seeds Ltd. are examples of Unregistered Varieties. Native grass Ecovars® developed through Ducks Unlimited (Native Plant Solutions, Inc.) and marketed exclusively as pre-designed seed mixtures by Agricore United are examples of Unregistered Variety Mixtures. The cultivar or mixture name assigned to these products is the guarantee of quality and consistent performance of the material.

Under Canadian legislation and by international agreement, seed originating and/or grown outside Canada may also be sold as pedigreed seed with the cultivar name on the Certificate of Seed Analysis and on the Pedigreed Seed Label. The guarantee of quality and source of material is the same as for plant products developed in Canada. Examples include Lodorm green needlegrass, developed by the US Department of Agriculture (USDA), Bismark ND and Critana thickspike wheatgrass developed by USDA, Bridger MT from seed collected near Havre, MT. Other cultivars from the US commonly used for reclamation in Alberta include Nortran tufted hairgrass, Sherman big bluegrass, Goshen prairie sandreed, Nezpar and Rimrock Indian ricegrass. and Rosana western wheatgrass

EnCana may consider the use of wild-harvest or cultivated wild-harvest seed if the source can be identified. An example is blue grama grass seed grown by local producer, Ted Harms of Brooks. This seed material is harvested from a naturally occurring dense stand of blue grama grass that has been managed for seed production by weed control, infill seeding of harvest material, and soil fertility amendments. Seed material could qualify as "source-identified" if the seed production is verified by field inspection by a qualified professional and seed is directly acquired from the grower. Seed material not pedigreed by cultivar name must still be tested and meet the same high standards for quality and undesirable species content but is graded as "common" on the Certificate of Seed Analysis and the Seed Label. In all other cases, EnCana will attempt to avoid the use of seed material designated as "Common" quality.

(2) Provide the location and source of native seed with respect to provenance

Under both the Canadian and US plant product protection system, a unique cultivar name is assigned when the product is registered and, in addition to other information, the location where the seed was collected is recorded. The information is published and becomes a matter of public record.

Cultivar name and the corresponding location where original seed material was collected is contained in Volume 1, Appendix H, Attachment H9, beginning on page 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-011 3 #Terr – 16 –B

H-47.

The USDA Agricultural Research Service maintains a database of plant germplasm resources with a description of seed collections and the source of all cultivars used in Canada and the US (USDA GRIN)

(3) comply with DND seed mixture standards

EnCana will consider any information from DND on sources of seed material and results from monitoring the performance of seed mixtures used on CFB Suffield. Relevant information considered in designing seed mix.

EnCana takes the position that the repeated multi-year use of the same, narrow combinations of species in seed mixtures does not meet the goals of the conceptual reclamation plan. EnCana will revise seed mixtures on an approximately annual basis by replacing cultivar-species components in a manner that maintains the functionality of each key component of the mix and thus maintain performance of the mixture as a whole (Section H.3.9, Table H-2, page H-11). This approach provides the flexibility to choose the cleanest possible seed material that is available on the market and at the same time avoid the potential of genetically swamping local species.

(4) describe genetic-level conservation and self-sustaining biologically diverse ecosystems

The use of cultivars of native species could possibly introduce a large number of genetically similar plants into the landscape where the same species may already be present, which has the potential to alter the frequency of alleles (alternative forms of a gene) in the population and cause an artificial occurrence of a natural process termed “genetic drift”. The consequence of genetic drift could be dilution or loss of genes necessary for survival under local environmental conditions that may be unique.

Another consequence of genetic drift might be a loss of genetic diversity (because so many of the plants may be genetically similar). A loss of genetic diversity could, according to one argument, result in inbreeding depression (higher rates of genetic defects, seedling mortality, infertility, and disease susceptibility). Another argument predicts a similar outcome but from outbreeding depression (incompatibility resulting from genes pairs at different chromosome locations and unable to pair during DNA replication). Although not impossible, genetic drift and the potential consequences are very unlikely to occur with the native grass cultivars recommended by EnCana for the NWA. 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-011 4 #Terr – 16 –B

During development, native cultivars are initially improved by selecting for traits that allow for economical seed production. These traits, however, may not improve competitive ability under the conditions of a natural ecosystem. Native cultivars may differ from wild populations in traits (gene combinations) that maximize seed production but these traits for high seed yield under agricultural conditions (high fertility, controlled pests, and adequate moisture) are not an advantage under natural conditions (low fertility, uncontrolled pests).

For example, an upright growth habit is an advantage for seed harvesting but a disadvantage under natural conditions where a prostrate growth habit can help a plant avoid being grazed or desiccated by the wind. Uniform seed ripening is an absolute necessity for economical seed production but a serious disadvantage under natural conditions where indeterminate ripening might prevent seed predators from consuming an entire crop. Low shattering (seeds retained on the plant when ripe) is a plus for agricultural production but not an adaptive feature under natural conditions where seeds are spread by wind. Heavy seed weight and high forage yield are preferred traits for agricultural productivity but these traits are detrimental if limited resources are directed away from the root development necessary for drought tolerance. The aggressive species that invade natural ecosystems are non-native species that are genetically isolated, have no local relatives with which to cross-pollinate.

Genetically improved native cultivars are not developed from new genetic material nor are the gene combinations new. The same or very similar gene combinations very likely are present in numerous individual plants within a regional population. Most native cultivars are the result of simple genetic improvement methods such as mass selection, a method that involves simply removing unwanted traits. The genetic combinations of traits that define a cultivar segregate (lose the traits) within a couple of generations. Each successive generation increasingly resembles that of the whole population.

For example, pedigreed seed growers are allowed to produce a limited number of generations (typically 4) before the cultivar has lost the desirable traits through genetic segregation and the cultivar description (and the name) is no longer valid. Seed producing fields have a specified life span before losing pedigreed status (age of stand typically 6 years). The population size of common native plants is generally very large (i.e. gene pool is very large) compared to the population size of plants seeded onto a disturbance. The introduction of genetically improved plants will have an insignificant impact on gene frequencies in these types of populations.

In plant breeding terminology, the Ecovars® developed by Ducks Unlimited are 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-011 5 #Terr – 16 –B

referred to as “synthetics”, which are simply cultivars composed of any number of genetically distinct individuals (clones). Usually, synthetic cultivars are groups of clones that have been combined together for the purpose of good performance and economical seed production. Whether a cultivar is a synthetic or a single clone depends on the species and the problems that must overcome for utilization. For some species, a single plant may contain a large proportion of the genetic diversity present in the population. If so, this may be more than enough for use as a cultivar.

For other species, a synthetic cultivar may be the best solution. By combining several clones, all traits are present for good performance and economical seed production. Ecovars are synthetic cultivars that attempt to incorporate a very large amount of genetic diversity (without knowing how much is really necessary) at the expense, usually, of sacrificing economical seed production. Some native grass cultivars currently on the market are synthetics, such as the northern wheatgrass cultivar Elbee (8 clones) and the western wheatgrass cultivar Walsh (20 clones). Some examples of cultivars developed from a single clone include the slender wheatgrass cultivars Adanac, Revenue, Highlander, and Mountaineer, and the alpine bluegrass cultivars Blueridge and Glacier. The Sodar cultivar of streambank wheatgrass is an example of a cultivar that started as a single plant (best specimen selected from 11) and then genetically improved through several generations of mass selection for economical seed production (although prices are still comparatively high because of low seed yields).

The issue of provenance specificity and the movement of native plant material has been a hotly debated topic for over 30 years. Jones and Johnson (1998) provide an insightful discussion on the topic and make recommendations that have been fully integrated into the EnCana conceptual reclamation plan.

Jones, T.A. and Johnson, D.A. 1998. Integrating genetic concepts into planning rangeland seedings. Journal of Range Management. 51(6):594-606.

USDA, ARS, National Genetic Resources Program, Germplasm Resources Information Network (GRIN). available at http://www.ars-grin.gov.

Reference: Volume 1, Section H.4.1, Page H-12

Preamble: EnCana states that it will be “evaluating annually the effectiveness of the prevention plan so appropriate adaptations can be implemented the following year”.

Request: GOC recommends that EnCana detail the methodology that will be used to evaluate the prevention plan and quantify the term “effective” and “appropriate adaptations”, so that successful weed control can be measured.

Response: The effectiveness of the prevention of undesirable plants will be based on the results of the Environmental Effects Monitoring Plan (EEMP). Final details of the EEMP have yet to be determined. EnCana will provide further details regarding its proposal for appropriate monitoring at the forthcoming hearing; further, the EEMP will be developed based on direction from the Joint Review Panel.

vi Reference: Volume 1, Section I.3.4, Page I-9, Point 17

Preamble: EnCana states that “the environmental inspector’s main responsibility is to ensure that all environmental commitments, undertakings and conditions of approval and authorizations are met and that work is completed in compliance with applicable regulations and EnCana policies”.

Request: GOC recommends that EnCana clarify the number of environmental inspectors necessary to monitor the NWA, the number of individual leases monitored by a single inspector, and the amount of time spent at each individual lease to monitor compliance during each phase of well installation and post-installation reclamation. GOC recommends that EnCana provide a details and applicable sections of all applicable regulations and EnCana policies.

Response: EnCana will evaluate the number of environmental inspectors upon completion of the PDAs for the upcoming construction season. The results will identify any sensitivities to the ecosystems, landscape and appropriate mitigation. This information will be used to identify the number of inspectors and the scope of competencies required.

One of the mandatory competencies will be familiarity with applicable regulations and EnCana’s policies as executed through the EPP.

Details of applicable regulations are publicly available. EnCana’s policy regarding environmental performance is included in Volume 1, Section 4.2; also please reference the response to General 55.

Reference: Volume 1, Section I.5.6, Page I-23, Point 134

Preamble: EnCana states that “a buffer distance may be reduced in exceptional circumstances where resource extraction would be severely compromised”.

Request: GOC recommends that EnCana clarify “severely compromised” by explaining and providing a list of circumstances which fall under this category in reference to wildlife.

Response: “Severely compromised” means not being able to extract the resource in an economic, efficient and environmentally responsible manner. The most likely circumstance where EnCana would consider an alteration to the setback distance due to resource extraction requirements is the construction of looplines. Looplines are necessary to transport the gas to the existing gas gathering system. Due to their length there is a potential that an alternative route that maintains all applicable setback is not possible. For example, if not reducing the setback distance would result in being unable to extract the resource in its entirety, this would be an example of where resource extraction would be “severely compromised”. As such, it is possible that a route would be chosen that is within the setback distance.

EnCana has assessed the environmental effects on wildlife as negligible to insignificant including the effects of reducing the setbacks in exceptional circumstances. As the Project is proposed to be within a National Wildlife Are, EnCana will prioritize listed wildlife and wildlife habitat in determining which setbacks are reduced in the event that there is multiple sensitive species or environments in proximity to a location.

While the siting of looplines is the most likely activity where setbacks may be reduced in extremely exceptional circumstances (where a significant loss relative to resource recovery would occur), EnCana may propose setback reductions in accordance with its PDA process. It is impossible to anticipate such exceptional circumstances until the PDA process has commenced.

Reference: Volume 1, Section I.5.6, Page I-24, Point 138 (Point 148 of I.5.7 is the preamble)

Preamble: EnCana states that “setback distance may be reduced in exceptional circumstances where resource extraction would be severely compromised” and “an estimated 50 to 100 preliminary well locations are predicted to fall within the 100m buffers established around wetlands”.

Request: GOC recommends that EnCana clarify “severely compromised” by explaining and providing a list of circumstances which fall under this category in reference to wetland setback distance and explain how this relates to DND policy on wetland buffers.

Response: EnCana has assessed the environmental effects on wetlands as negligible with the reduction of setbacks in exceptional circumstances. As the Project is proposed to be within a National Wildlife Area, EnCana will prioritize wildlife and rare plants over wetlands in determining which setbacks are reduced in the event that there is multiple sensitive species or environments in proximity to a location.

“Severely compromised” means not being able to extract the resource in an economic, efficient and environmentally responsible manner. The most likely circumstance where EnCana would consider an alteration to the setback distance due to resource extraction requirements is the construction of looplines. Looplines are necessary to transport the gas to the existing gas gathering system. Due to their length there is a potential that an alternative route that maintains all applicable setback is not possible. For example, if not reducing the setback distance would result in being unable to extract the resource in its entirety, this would be an example of where resource extraction would be “severely compromised”. As such, it is possible that a route would be chosen that is within the setback distance. Therefore, EnCana may reduce the setback distance and implement appropriate mitigation measures in accordance with its proposed PDA process (see attached decision-making process). The reduction of setback distances will still comply with the “no net loss” requirement of the “Federal Policy on Wetlands” in accordance with the proposed PDA process. While the siting of looplines is the most likely activity where setbacks may be reduced in extremely exceptional circumstances (where a significant loss relative to resource recovery would occur), EnCana may propose setback reduction in accordance with its PDA process. It is impossible to anticipate such exceptional circumstances until the PDA process has commenced. Please also see the response to Terr 25.

GO No

f Yes Is control weed inside the buffer thezone buffer a factor? Weed elimination within 100 m if pre-existing weeds by mowing o tumble weedsby or wick application. Weed monitoring and control after construction No Yes zone a factor? Is the spread invasive of species inside the buffer - Mandatory- Seeding Heighten- monitoring (Spring, Summer, Fall Check-ups) Clean- Vehicles (EPP) No SUCCESSFUL MITIGATION SUCCESSFUL Vac Truck Vac Yes factor? Is Wetland Fluid Control (EPP / ERP) (EPP contamination a Clean immediately No Yes Is soil soil Is factor? (EPP) erosion a erosion a Erosion Controls Yes No dry or Are the frozen? conditions Yes 100 m Yes setback 75 - between - 15 100m Well or Pipeline setback STOP No Well Well 75 m setback setback between - 15 (SEAC Approval) Consult Specialist wetland 15 m of a 15 m of Buffer DistanceBuffer 100 m of Piepline or wells withing withing wells 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-011 1 #Terr – 29 – A

Reference: Volume 1, Section I.6.1, Page I-28, Point 171

Preamble: EnCana states that “the Project will avoid sandy soil or steep gradient slopes with erosion potential (>15%). Where slopes cannot be avoided, site specific plans will be created”.

Request: GOC recommends that EnCana provide a list of potential situations where slopes are encountered (based upon different gradient and erosion potential combinations) and detail the plans to address each situation.

Response: Please see the response to Gen 73.

Reference: Volume 1, Chapter 2, Section 2.2. Emergency Response Plan

Preamble:

Request: GOC recommends that EnCana provide the Emergency Response Plan including a description of the interactions between the Proponent, DND and the emergency response personnel.

Response: A copy of EnCana’s ERP can be viewed in the attachment contained in IR Health-9-A. Communications protocols are referenced therein.

Reference: Volume 1. Section 2.2.2.4

Preamble: EnCana states “ Disturbed ground will be recontoured, where necessary, and reseeded or left to recover naturally, depending on site conditions”. Appendix H, page H-6 states that “Natural recovery is not recommended as a general practice for the project”, but continues by stating the conditions where natural recovery can be used.

Request: GOC request EnCana to clarify under what circumstances and site conditions that natural recovery will be used within the NWA.

Response: The preamble, specifically the statement that “Natural recovery is not recommended as a general practice for the Project”, refers to a portion of the discussion contained in Volume 1, Appendix H, page H-6 which continues in the pages that follow. As such, please see the entirety of Appendix H, which provides the additional context of the natural recovery discussion.

Upon consultation with independent, peer-recognized experts in environmental reclamation practices, and having regard to its own significant and unique experience on the ground at Suffield (having operated there for over 30 years, and having committed to continuously improving its practices), EnCana has developed the basis for a very strong conceptual reclamation plan for the Project. The plan is designed to address the best and most appropriate reclamation practices in different geographical areas of the NWA, and also has regard to categories soil types, as follows:

1. Natural recovery will be utilized in areas with sandy soils (course textured soils) such as in Amiens and the Middle Sandhills where quick recovery is anticipated with low density weed growth. In areas where there is greatest potential for blowouts (areas with high erosion potential), seeding may be warranted. 2. In areas where there are sandy veneers or dunal soils, such as those soils found in the Sandy Plains/ D6/D8 areas, natural recovery will also be utilized as quick recovery is still anticipated; however, there is a higher potential for weed growth that may require additional remedial measures. In areas where there is greatest potential for blowouts (areas with high erosion potential), seeding may be warranted. 3. Finer textured soils (loamy/glacial soils) such as those soils that are found in the southern portion of the NWA will require more aggressive reclamation. This will consist of a combination of "assisted" natural recovery methods utilizing both mowing and seeding in an effort to 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-012 2 #Terr – 36 – A

curtail the anticipated highest potential for weed growth. 4. Seeding with native vegetation will occur in seeded pastures (for example, the south end of the NWA). A "buffer" area beyond the seeded area would also be seeded with native seed mix (mixture to be determined on a site-specific basis) in areas that otherwise would be chosen for natural recovery. Propagule pressure (from the surrounding area) and the size of the surrounding seeded pasture will be an important consideration in determining the seed mix composition and appropriateness for using native seed.

One key factor in determining the appropriate reclamation method is the Pre- Development Assessment (“PDA”) to be undertaken for each location contemplated for use in the Project. Further, EnCana continues to be bound by and will respect all of its statutory and contractual obligations with respect to reclamation (see the response to Gen 11 ).

Reference: Volume 1.

Preamble: The EIS Guidelines Section 2.2 requires the examination of alternatives to the project. Section 3.1 also requires examination of alternative means of carrying out the project. EIS Volume 1, Section 1.4.2 states that delaying the project would not substantively change the environmental costs.

Request: GOC suggests EnCana provide further justification that the extension of the project timeline would not minimize the impacts to the ecosystem. As well, GOC requests EnCana identify the environmental effects for alternate timelines of the Project, such as the use of project infill timelines of 10, 20 and 30 year.

Response: The existing uses of the NWA would still exist in the foreseeable future (30 years); therefore, there is no suitable reason to delay the project. The effects of the Project would be the same provided that there are no technological advances.

Additionally, delaying the project may cause greater impact if to do so would require additional infrastructure. Existing infrastructure may need to be replaced or augmented. At this time, no new compressor stations are required and the existing gas gathering system is adequate to handle the additional gas from the Project. If the Project were delayed long enough so that the existing infrastructure or portions of it had to be decommissioned, increased impacts on the ecosystem could reasonably be predicted due to future construction. These increased impacts could result from the construction of additional new infrastructure required to replace the old decommissioned gas gathering system or compressor stations.

Reference: Volume 1, Section 2.4.3, Page 2-37

Preamble: EnCana states that “all waste storage systems do and will comply with applicable EUB guidelines”.

Request: GOC recommends EnCana provide documentation supporting that all waste storage systems comply with applicable federal guidelines. GOC requests a list of all applicable guidelines that EnCana believes that they (EnCana) are expected to follow.

Response: Directive 50 of the EUB governs the waste that is handled through remote sump sites, which is what EnCana has proposed to use for the Project. These are the only waste “storage” systems per se that apply to the Project. EnCana’s plans comply with EUB regulations as this is standard practice for all EnCana projects.

Reference: Volume 1, Section 2.8.3, Page 2-44

Preamble: EnCana states that “laterals and loop line pipeline routes have not been finally selected”.

Request: GOC recommends that EnCana provide the final lateral and loop pipeline routes so that environmental impacts can be determined and assessed.

Response: Given that the well location and planning process cannot occur until the spring / summer before the construction season, the information requested is not available. After the project has been approved (in the event approval is obtained), it will not be available until shortly before the commencement of the construction season. EnCana embarks on a lengthy planning process in advance of determining final locations. See section 2.2.1 of Volume 1 for a description of the preconstruction activities.

Environmental assessment is conducted early in the planning stages of a project. This permits changes arising from the environmental assessment and consultation process to be incorporated into the final design. It is not possible for EnCana to submit a “final” design at this time.

Reference: Volume 1, Section 2.8.7.1, Page 2-50

Preamble: EnCana states that “mix-bury-cover method (MBC) disposal method may be utilized in combination with remote sumps to dispose of the drilling wastes. This method involves mixing drilling solids (and sometimes fluids or the total waste) with subsoils, at a depth below either 1 or 1.5m, to form stabilized soils and waste mass below the main rooting zone”.

Request: GOC recommends EnCana identify the locations where this will occur, and if on CFB Suffield lands, the projected environmental impact on plants, wildlife and ground water.

Response: Given that the well location and planning process cannot occur until the spring / summer construction season, the locations requested are not available. The location of sumps is influenced by well locations as the driving distance to the sumps is a factor in locating sumps After the project has been approved (in the event approval is obtained), it will not be available until shortly before the commencement of the construction season. EnCana embarks on a lengthy planning process in advance of determining final locations. See section 2.2.1 of Volume 1 for a description of the preconstruction activities.

EnCana can advise that remote sump locations will be located on CFB Suffield lands outside of the NWA. Remote sump locations are chosen to be located in areas of previous disturbance and typically where there is evidence of crested wheat grass present. This prevents disturbance of native prairie wherever possible.

An environmental overview is conducted on these sites to ensure no impact on rare plants or species at risk. Soil conditions are tested to ensure that the sump is located in clay and not permeable sand, and test holes are carried out to ensure the sump is located above the ground water table. In addition, Directive 50 of the EUB outlines requirements for waste disposal that EnCana will follow in this process.

EnCana has evaluated the Project and has concluded that the environmental effect on plants, wildlife and groundwater is insignificant or negligible. Reclamation of the 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-012 #Terr – 45 – A

sumps may result in improved habitat for wildlife as invasive/undesirable species may be replaced with appropriate vegetation.

Reference: Volume 1. Pg. 4.1

Preamble: EnCana states “Environmental plans have or will be developed and regularly revised as required throughout the life of the Project…. Proposed plans will be developed based on final project design and in consultation with the applicable regulatory agencies”.

Request: GOC requests the details as to who will be consulted for each of the plans listed in Volume 1, Section 4, as well as a plan for updating and completing each of the components as well as the follow-up monitoring.

Response: As part of the CEAA process, EnCana anticipates all stakeholders will have a chance to provide input into the development of the EPP and EEMP. EnCana commits to finalizing these plans shortly after the Panel issues its report.

Reference: Volume 1, Section 4, Page 4-1

Preamble: EnCana states that “proposed plans will be developed based on final Project design and in consultation with the applicable regulatory agencies”.

Request: GOC recommends that EnCana provide a list of all regulatory agencies EnCana believes are required for consultation and provide a final Project design for reviewing.

Response: Please see s. 6.1.2, Table 6-1 of the EIS for a discussion of consultation with Project Stakeholders. Regulatory agencies included in this group are: • Department of National Defence, • Alberta Environment, • Alberta Energy and Utilities Board, • Alberta Sustainable Resource Development, • Agriculture and Agri-Foods Canada, • Environment Canada, • Fisheries and Oceans Canada, • Health Canada, • Natural Resources Canada, and • Parks Canada.

Given that the well and pipeline location and planning process cannot occur until the spring/summer before the construction season, the final Project design is not available. After the Project has been approved (in the event approval is obtained), it will not be available until shortly before the commencement of the construction season. EnCana embarks on a lengthy planning process in advance of determining final locations. See section 2.2.1 of Volume 1 for a description of the preconstruction activities.

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Reference: Volume 1, Section 4.6, Page 4-5 EnCana states it “has in place a computer and web based incident management system that controls the response to any emergency or accident and tracks the corrective actions. A summary of the system including example of the system functions will be provided upon request”.

Preamble:

Request: GOC recommends that EnCana provide the summary of the system including example of system functions, and provide the computer and web based incident management system for review.

Response: EnCana’s ERP which can be viewed in the response to IR Health-9-A, controls the response to any emergency. EnCana’s ERP is available to staff through EnCana’s internal web site.

The Incident Management System (IMS) application is web based and is used to capture incident information as well as help manage incidents to closure. Please see attachment.

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Incident Management System (IMS)

Basic User Guide Canadian Divisions

IMS Presentation - Rev.7.2, March 2007

Incident Management System (IMS)

Overview – What is IMS?

IMS Workflow Process & Roles

IMS Home Page

Initial Report Form

Investigation Report Form & Root Cause Analysis

Corrective Actions Form

Incident Closure

Email Notifications

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What is IMS?

IMS was rolled out on Oct. 1st, 2005 to meet the following objectives:

Provide an effective incident tracking and management process that replaces ITS

Web-based application accessible anywhere with internet connectivity

Accessible via ECN from Services & Support / Environment, Health, Safety/ Incident Management System (IMS)

Effectively manage incidents by providing a full audit trail to improve incident follow-up and closure by using workflows & associated roles

Email notifications when incidents are submitted & corrective actions are assigned

Improved Risk Management and Root Cause Analysis process

Remedy the cause of an Incident

Enhanced reporting & search capabilities

IMS Workflow Process & Roles EnCana Role*

All employees Any Individual can report an incident. 1 Submit Initial (Reporter/ General User) Report Once incident is submitted for Investigation it is no longer accessible to individual

EnCana Supervisor receives Initial 2 Person responsible Create Report and is responsible for the for Investigation Investigate Corrective Action (P.R.I.) Incident Investigation where at least (Investigator) ONE CORRECTIVE ACTION must be assigned

Field Safety Coordinators are 3 Person responsible for Review Close responsible for the Investigation Investigation Investigation Investigation Review Review (P.R.I.R.) (Reviewer)

The Person Responsible Email notification reminders are sent Close Corrective out when Investigation and/or that has been assigned the Action Person responsible Corrective Actions must Corrective Actions have not been 4 for Incident Closure close them before the completed (P.R.I.C.) Incident can be closed. (Closer) BU assigns appropriate personnel (Field Safety Coordinator, Production Field Coordinator, Close Incident Supervisor or Superintendent) to *NOTE: EnCana roles must be individuals that reside review and close incident when all in the EnCana yellow pages. corrective actions have been closed. 4

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Incident Report Forms

Initial Report – The Initial Report is only available to the general user – The Initial Report can be saved as a Draft Report before it is submitted for Investigation. Only the person entering the incident & IMS administrators can see draft reports. – Once Initial Report is submitted for Investigation, the form is no longer accessible to the general user – The Initial Report is to be submitted to the Onsite Supervisor as being the person “Responsible for Investigation” – Classifications are categorized as Incident, Near Miss & Hazard Identification – Incident Types (Injury, Motor Vehicle, etc.) are only “recordable” if classified as an “Incident” (not recordable if classified as Near Miss or Hazard Identification)

Investigation Report – The investigation report is only available to individuals that are “Responsible for Investigation”, “Investigation Review” and “Incident Closure”

“Responsible for Investigation” – Onsite Supervisor

“Investigation Review” – Field Safety Coordinator

“Incident Closure” - Field Safety Coordinator, Regional/Corporate Administrators – Investigation Report will contain different information, based on the Incident Type (i.e. – Injury, Spill, etc.) 5

Click on Incidents to view NO LOG IN required for IMS all incidents for the areas in which you have access IMS Home Page User logged in will appear on upper right side of Search and Filter functions can be screen Click on “Report Incident” used to search on specific incident to enter an new Incident, criteria that can be exported to Excel Can enter the Incident Near Miss, or Hazard Number Identification (i.e. “I2005-00729”) to search and locate an Incident (number must be entered exactly as entered in IMS)

Click “Download blank form” to print off a blank copy of the Incident Form or access an online version of the form

‘Report Incident’ – to enter a new Incident, Near Miss, or Hazard Identification ‘Add Corrective Action’ - DO NOT USE “Add Correction Action” button as these are corrective actions that are not directly linked to an Incident. Corrective Actions are to be identified on the Investigation section on the Incident Investigation Form. ‘My Incidents’ – lists all incidents that a person is currently responsible for (i.e. Investigation, Review, Corrective Actions) ‘Incident Types’ – lists specific Incidents rather than all Incidents ‘Corrective Actions’ – lists all open & closed corrective actions that an individual is delegated as the Person Responsible or the Person Delegated “Reports” – to access canned IMS reports (IMS Summary & Statistical Reports are the most common)6

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Initial Report Incident Classification: Incident, Near Miss, or Hazard Identification

Incident Type: Injury, Fire/Explosion, Motor Vehicle, etc. These selections are only “recordable” if “Incident” is selected as the classification (not recordable if classified as Near Miss or Haz ID) Person Involved: Enter information pertaining to the person involved in the incident. Mandatory field for Injury, Occupational Illness and Motor Vehicle incidents. Relationship to Company: Select “Other” if not an EnCana “recordable” incident (individuals not on EnCana duty) Activity: Completions/Workovers, Construction – Facilities & Pipelines, Construction – Lease & Road, Drilling, Geophysical, Operations – Plant & Batteries (DOT NOT USE Operations – Gathering System or Operations - Wells) Basic Information: Incident Date, Time, Region, Business Unit, Sub Business, Area, Equipment. NOTE: Equipment field can be used to enter any type of equipment, LSD, etc. Incident Description: Enter description of incident (mandatory field). Incident Description and Description of task or activity at time of Incident: Enter activity at time of incident (mandatory field)

Cause: Enter cause of Incident (Direct Causes from the Root Cause Analysis Legend). NOTE: A NEW LEGEND and process is being developed for Root Cause Analysis.

Immediate Action Taken: Enter immediate response to incident.

Parties Involved: Enter any witnesses and relationship to the company. Reported By: Person entering the incident. Responsible for Investigation: Enter person responsible 7 for investigation (Onsite Supervisor in most cases).

Investigation Report

Investigation: Standard information required for Investigation

Information Section: This information will change based on Incident Type (Injury, Spill, etc.)

Costs: Enter cost and currency, if applicable to Incident

Risk Management: Risk Assessment are mandatory fields that must be filled in prior to submitting the incident for Investigation Review. The ranking should be based on the probability and likelihood of this incident from occurring again, not on the corrective actions to rectify the occurrence. The Risk Level is calculated based on Value, Probability, and Impact that are selected.

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Investigation Report

Root Cause Analysis: Enter one or multiple Root Cause Analysis and one primary area where preventative or corrective actions should be focused.

(hold down the CTRL key while clicking the mouse to select or deselect multiple causes).

These boxes replace the Indirect Causes from the Root Cause Analysis Legend. NOTE: A NEW LEGEND and process is being developed. The Direct Causes are to be identified on the Initial Report, under the “Cause” field.

This section replaces the Systemic Cause from the Root Cause Analysis Legend.

Corrective Action Assignment: Enter at least ONE corrective action per Incident. Incident cannot be closed until ALL corrective actions have been completed.

Person Responsible must be filled in. Person Delegated is optional (they can be the same person). The Person Responsible must be designated as EnCana personnel and the Person Delegated can be assigned to anyone. Email reminders will be sent out when corrective actions are overdue.

Additional Information:

•Management Review: Indicates who was responsible for Incident Review and Incident closure. Must be a SER Coordinator that reviews the •Notes: To record additional information pertaining to the Incident. SER Coordinator, or BU incident. representative, closes the Incident. •Attachments: Can attach any type of file or picture to the incident. •Status Log: Records the status of the incident – i.e. at Initial Report, Investigation, Investigation Review stage. •Edit Log: Records each time an incident has been edited and by whom. 9

Corrective Actions Form

Indicate Action to be performed and appropriate Description.

Person Responsible for the correction action item can delegate the action item to other individuals or themselves. Assigned by is the person who assigned the actions which can be the same as Person Responsible.

Date Assigned: Date action item was assigned. Due Date: Date action is due. Priority: Rate action item as High, Medium, or Low

Email Reminders and Overdue Notifications are sent out when corrective actions are overdue.

Enter time to complete action item and percent complete.

Progress Notes: Enter additional notes pertaining to action item.

These fields must be filled in order to Completion Date: Enter date that action close a corrective action item. item was completed. The “Mark Complete” button must also be selected in order to close out a Completed By: Enter who completed the Corrective Action. action item.

Marked Complete By: Enter who signed off on the action item being completed. 10

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Incident Closure

ALL corrective actions must be completed before an Incident can be closed.

Email notifications will be sent out when corrective action items are overdue. The button must be selected in order to close corrective actions so that overdue email notifications are NOT sent out.

When all corrective actions items are completed, only the Field Safety Coordinators, Group Leads, and Corporate & Regional Administrators can close incidents

IMS Email Notifications

Stages of notification when Initial Report is submitted, Investigation, Investigation Completed and Investigation Closed. When Recipients Initial Report submitted PR* for Investigation (Supervisor), Field Safety Coordinator Investigation completed PR for Investigation Review (Field Safety Coordinator) (Reverted to Investigation) PRI Investigation closed PR for Incident Closure (Field Safety Coordinator) 14 days after incident occurred if not Supervisor, Field Safety Coordinator closed 21 days after incident occurred if not Supervisor, Field Safety Coordinator, closed Regional EHS (Group Leads)

* PR – Person Responsible, PRI – Person Responsible for Investigation 12

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Corrective Action Email Notifications

When Recipients Corrective Action created Person Responsible, Person Delegated Change in due date, person responsible, or PR, PD, Assigner person delegated 7 days before due date PR, PD On due date PR, PD 3 days overdue PR, PD, Assigner, Supervisor

30 days overdue PR, PD, Assigner, Supervisor, Field Safety Coordinator * PR – Person Responsible, PD – Person Delegated

Reference: Volume 1, Section H.3.2, Page H-7, Point 5

Preamble: EnCana states that “desirable species must dominant the composition in terms of canopy cover, basal cover, or reproductive success”.

Request: GOC recommends that EnCana provide a list of all desirable species that “must dominant the composition” and provide a list of all species which are not dominant but whose presence are acceptable but not in a dominant state.

Response: Section H.3.2 of the Conceptual Reclamation Plan in Volume 1, describes natural recovery, the practice of not seeding a disturbance if the topsoil has been adequately salvaged and the soil seed bank contains sufficient propagules of desirable species that will produce a plant cover adequate for restoring functionality.

With respect to item 4 in the list of criteria for judging if a site is suitable for natural recovery, the desirable species that "must dominate the composition" is a reference to those species that produce propagules conducive to rapid re-establishment of the site stability (erosion control) and watershed (infiltration) attributes of a functional landscape.

For natural recovery, EnCana defines desirable species as those that are prolific seed producers or those that expand vigorously from rootstocks. Examples include most native grasses and many of the native forbs. Desirable native shrubs include species such as prickly rose (Rosa acicularis) and willow species (Salix spp.) that are capable of rapid reproduction by rootstock. Undesirable native shrubs include species such as silver sage (Artemisia cana) and silverberry (Elaeagnus commutata) that reproduce slowly from seed and poorly from rootstocks. Prairie selaginella (Selaginella densa) often forms a dense, dominant cover after a period of sustained heavy grazing. These species are undesirable on a site under consideration for natural recovery site because the lack of seeds and vigorous rootstocks would result in a slow recovery of the site stability and watershed attributes of functionality.

With respect to item 5 in the list of criteria for selecting sites suitable for Natural Recovery, undesirable species would include the tumbling weed species: Russian thistle (Salsola kali), kochia (Kochia scoparia), and tumbling mustard (Sisymbrium altissimum). Species that require control under the Alberta Weed Control Act are also undesirable. Exotic forage species include crested wheatgrass (Agropyron cristatum and A. desertorum).

The reclamation target of restoring the attributes of a functional landscape is the same regardless of the method employed. Therefore any plant species that contribute to that target are desirable and those that don't are not.

References Consulted

Looman, J. 1964. The distribution of some lichen communities in the Prairie Provinces and adjacent parts of the Great Plains. The Bryologist. 67:209-224.

Looman, J. and Best, K.F. 1979. Budd's Flora of the Canadian Prairie Provinces. Agriculture Canada Research Branch Publication 1662, Ottawa, Ontario. 863 p.

Ralphs, M.H., Pfister, J.A., Welsh, S.L., Graham, J.D., Purvines, J., Jensen, D.T. and James, L.F. 2003. Locoweed Population Cycles. Rangelands. 25(5):14-18.

Whitson, T.D., Burrill, L.C., Dewey, S.A., Cudney, D.W., Nelson, B.E., Lee, R.D. and Parker, R. 2000. Weeds of the West. Western Society of Weed Science and University of Wyoming, 0-941570-13-4. 628 p.

Reference: Volume 1, Section H.3.9, Page H-10

2 Preamble: EnCana states that “a target density of 50-75 seedlings/m at the end of the growing season is generally an adequate density to provide sufficient ground cover for erosion control but still allow ingress of native species from seeds in the topsoil seed bank and from offsite plants”.

Request: GOC recommends that EnCana provide documentation to support the target seed 2 density of 50-75 seedlings/m in the NWA and the proposed course of action where initial seeding is not of an “adequate density to provide sufficient ground cover for erosion control”.

Response: The target density of 50-75 seedlings/m2 at the end of the first growing season was developed from the results of field data collected near the NWA and also from data collected from similar environments. Seedling establishment data is documented in references listed below.

Computer spreadsheet programs to assist with the calculations involved in designing seed mixtures based on target seedling density, seed purity, germination, weight, and vigor are available from Alberta Agriculture (2007) and from Walker (2007) at links listed below.

EnCana will reseed any areas that do not meet a minimum density of 10 seedlings/m2 with a frequency of 90% after one full growing season. Seedlings from seeded species and from local seed bank species are included. Seedlings of undesirable species are excluded from the count. Reseeding will be deferred if drought conditions prevail.

References

Alberta Agriculture. 2007. Forage Seed Mixture Calculator. Available online at http://www.agric.gov.ab.ca/app19/calc/forageseed/forageseedintro.jsp

Walker, D.G. 2007. Reclamation Seed Mixture Calculator. Spreadsheet Program available online at www.cpesc.ca

Reference: Volume 1, Section H6, Page H-36

Preamble: EnCana states that it plans to “raise the organic matter content by at least 1%“.

Request: EnCana states that it plans to “raise the organic matter content by at least 1%“. GOC recommends that EnCana provide documentation to support raising organic matter content to 1% and all other possible organic matter percent increases and outline the impacts of raising organic matter content on NWA grassland species and soil types to each potential organic matter percent content level.

Response: EnCana states that "where topsoil has been lost or revegetation has failed because of poor soil quality, add an organic matter amendment…” (Volume 1, Appendix H, Section H.2.2, page H-4). According to the following guidelines, (Volume 1, Appendix H, Attachment H6, Soil Loss Mitigation Plan), the objective of the amendment is to mitigate the loss of topsoil EnCana regrets any misunderstanding created concerning the intent to raise the soil organic matter content in the NWA by 1%. In the event that organic matter must be used, EnCana will amend organic matter only to sites disturbed by erosion of soils related to the Project activities.

Soil organic carbon levels of sandy rangeland soils are commonly less than 2% and are seldom above 0.5% on active dunes (Hulett and others 1966, Walker 1987). The target level of 1% was selected because it is sufficient for native sand-adapted species to flourish but not high enough for exotic, high-nitrogen consuming species to gain a competitive advantage.

EnCana predicts that the impact of raising the organic matter content on eroding sites will be positive for increasing population size of NWA grassland species, mitigate aeolian erosion processes, and, by extension, increase ecosystem functionality.

Information Sources

Hulett, G.K., Coupland, R.T. and Dix, R.L. 1966. The vegetation of dune sand areas within the grassland region of Saskatchewan. Canadian Journal of Botany. 44:1307- 1331.

Walker, D.G. 2001. Revegetation Research in The Great Sand Hills of Saskatchewan. IN: Canadian Land Reclamation Association Alberta Chapter 2001 Fall Tour and Annual General Meeting, "Extreme Reclamation" Program, Medicine Hat AB, October 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-012 2 #Terr – 53 – B

1-2.

Walker, D. 1987. Pipeline revegetation studies in the Great Sand Hills of Saskatchewan. NOVA Corporation of Alberta, Calgary, Alberta. 126 pp

Reference: Volume 1, Section I.3.3, Page I-7

Preamble: EnCana states that in reference to the “pre-job meeting”, “representatives from construction, engineering, environmental, field inspection and appropriate regulatory personnel will be invited”.

Request: GOC recommends that EnCana provide a list of persons/groups which meet the “appropriate regulatory personnel” description. Response: A pre-job meeting will be a brief overview occurring immediately prior to construction, and after the PDA process and environmental training has taken place. Without any restrictive intent, EnCana suggests appropriate regulatory personnel may include (but must not necessarily include) Alberta Sustainable Resource Development, Alberta Environment, the Alberta Energy and Utilities Board and the Department of National Defence.

Reference: Volume 1, Section I.5.1, Page I-17, Point 102

Preamble: EnCana states that “the contractor will be held responsible for all effects and damages that occur without specific instructions from EnCana construction management”.

Request: GOC recommends that EnCana clarifies and explains its roles and responsibilities in enforcing the mitigation and remediation of any damaged areas by contractors, and where contractors refuse liability for damages.

Response: Under EnCana’s Master Service and Supply Agreement (MSSA) and Contractor Services Agreement (CSA), Contractors are liable for any claims or damages suffered by EnCana which are attributable to Contractor (or its personnel) engaging in either: (i) a breach of the Agreement; or (ii) a negligent act or omission or wilful misconduct (the MSSA also includes tortuous acts and strict liability offences) in the course of performing (or failing to perform) the services (as defined) under the respective agreement.

Contractors are not liable for any act or omission performed or omitted due to either the gross negligence of EnCana, or at the specific instruction of EnCana, which remain the responsibility of EnCana. Contractors are also not liable for consequential damages (or, under the CSA, for indirect, incidental or special damages) arising from such claims or damage. Under the CSA, Contractor liability is expressly limited to the greater of (i) Contractor’s actual insurance coverage; or (ii) the insurance coverage Contractor is required to obtain under the Agreement.

Under these agreements, the provisions regarding Contractor liability are expressly provided to survive termination of the Agreement or any service order (under an MSSA).

Reference: Volume 1, Section I.6.1, Page I-28, Point 175

Preamble: EnCana states that “the access routes will attempt to stay 1 metre above the water table in relation to low wet areas, and will maintain a minimum setback of 15 metres from wetland vegetation”.

Request: GOC recommends that EnCana provide documentation to support the claim the any vehicle travel between 15m and 100m of wetlands and the high water mark has no impact on wetlands and wetland function.

Response: Wetlands will be avoided by 100 meters or more, except under exceptional circumstances. In these situations, there will be a minimum setback of 15 meters from wetland vegetation. A pre-disturbance assessment (PDA) at each wetland will be done to delineate the wetland including the outer rings/zones that will be defined based on wetland-species presence. The PDA will include also an amphibian and reptile surveys if the wetland has standing water. Together with the wetland delineation, the surveys are sufficient to identify any potential issues related to the siting of the access route. The potential issues will be mitigated in consultation with professionally designated experts. Potential mitigation measures are listed in the response to Terr 273. EnCana’s assessment of wetlands including the assessment of access routes has predicted negligible effects on wetlands. See Volume 3, Section 4.8 for details.

Reference: Volume 1, Section I.6.6, Page I-37, Point 244

Preamble: EnCana states that “remote sumps outside the NWA, on CFB Suffield, will be the primary destination for drilling waste. The sumps will be located when possible on pre- disturbed land. Sump areas will be appropriately reclaimed”.

Request: GOC recommends that EnCana provide the number of sumps required, and detail the projected footprint and impact upon vegetation, soil, and wildlife VECs, in addition to military training, defence research, and cattle grazing. GOC also suggests that EnCana define the “appropriately reclaimed” by detailing the methods and criteria used to assess sump reclamation.

Response: Approximately 25 sumps will be required for the project.

A detailed description of sump construction along with photos is attached below. Each sump will be approximately 1 hectare. The sumps will be sited, where possible, on previously disturbed (and not successfully reclaimed) sites, or on crested wheatgrass sites. The sites will then be reseeded and reclaimed to equivalent land capability, therefore, once reclaimed, the sites will be beneficial to native prairie integrity and will provide suitable wildlife habitat. Reseeding will be done with an approved seed mix.

Test holes are done to determine site suitability (i.e. water table depth, permeability of soil). The pre-site assessment is done to determine topsoil depth (a and b soil profiles) and to document vegetation cover. The site is then cleared of topsoil by a bulldozer and segregated into separate piles on site. Once the top soil is cleared, pits are excavated in the subsoil. Pits are dug with a bobcat or back hoe, at least 1 metre above the water table or permeable layer, and are typically 2 metres deep. The drilling waste is stored in the pits during drilling operations.

Once the project is completed, representative samples of the drilling waste are obtained by a third party environmental service company and the waste is analyzed according to EUB requirements. The waste is then disposed of by an on-site disposal method such as Mix - Bury - Cover (“MBC”). MBC is a disposal method where drilling waste is stabilized by mixing it with subsoil. The mixture is done at a minimum 3:1 ratio, and is typically done with a mixing machine and a back hoe. A typical MBC method is to spread the waste on the surface, allow it to dry, then put the waste back into the pit, mix and cover. Once the waste is mixed with subsoil it is then buried on site at least 1 metre above the water table or permeable layer and is covered with 1 metre of clean subsoil. The area is re-contoured and then the topsoil is replaced, 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-012 2 #Terr – 66 – B

and the site is then seeded. Please see the attached photos for an illustration of this process.

The goal of MBC as stated in the Directive 50 "is to incorporate waste into the subsoil below the major rooting zone and above the water table in a manner that preserves soil chemical properties and protects groundwater quality".

Cat clears lease of top soil

Cat digs pits into sub-soil

Empty pit at a remote sump location

Vac truck emptying drilling waste into pit

Drilling waste in pit

Drilling waste drying in pit

Dry drilling waste in pit

Dry drilling waste turned over with a back hoe in preparation for M-B-C

Mixing machine

Mixing machine can blend drilling waste into consistent mixture. Back hoe mixes drilling waste at 3 parts sub-soil to 1 part drilling waste. Cat re-contours lease and top soil is replaced. 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-012 1 #Terr – 74 – A

Reference: Volume 1, Section 2.2.1 Preconstruction Activities, Page 2-15

Preamble: EnCana states Team planning meetings will be held to discuss siting or routing issues and select preliminary sites and routs. These team planning-meetings will typically include personnel involved in the Project…

Request: AAFC-PFRA requests clarification regarding the personnel involved in these planning meetings. Sites and routs can disrupt cattle operations and AAFC-PFRA, through its resident pasture manager, wishes to be involved in the final siting decisions.

Response: Personnel who are involved in the preliminary site planning meetings typically include geologists, engineering, environmental specialists, surveyors and SIRC personnel. These preliminary site planning meetings involve desk top, document and database searches. The field portion of the PDA is executed by surveyors, environmental specialists, and construction personnel. Final site vetting as well as timing coordination is done via SIRC and involves the DND and other stakeholders such as the CWS and PFRA. During the PDA process, EnCana considers criteria for siting and routing which would decrease any potential conflict between gas development and other activity, such as cattle grazing, and would incorporate any additional criteria that the PFRA suggests.

Reference: Volume 1, Appendix I, Section I.5.6, page I-23, Point numbered 134.

Preamble: EnCana states that “appropriate setbacks… will be respected whenever possible”.

Request: The GOC recommends that EnCana discuss and clarify when setbacks will be respected, and what mitigative measures will be employed when setbacks are not respected. The proponent is also advised that the provincial setbacks mentioned (Fish and Wildlife Division 2001) are undergoing review and--in some cases, changes are being initiated, on a transitional (phase-in) basis.

Response: Each type of siting factor has a separate decision-making process with specific mitigation measures to address the particular issues related to that factor. EnCana is aware that both Provincial and Federal setbacks are under review. EnCana has committed to utilizing the Federal setbacks when they are available and Provincial guidance for any species not covered by the Federal document.

Reference: Volume 1, Section 1.1.3 Special Considerations in the Suffield NWA. Page 1-3

Preamble: The proponent states that it continually strives to minimize the environmental effects of its operations and makes reference to undertaking “extensive studies of all aspects of the local environment as part of its planning processes”.

Request: GOC recommends that EnCana discuss these extensive studies.

Response: For the survey methodology for rare plants please see the response to Terr 189a. For the survey methodology for wildlife please see the response to NC 36. Additionally, EnCana conducted field studies on vegetation and wildlife as part of its EIS. The results are located in Volume 3, Sections 3.6 and 5.6.5.

Reference: Volume 1 , Section 1.2.3 Project Management., Page 1-5

Preamble: The proponent states it will develop an (Post Construction) Environmental Effects Monitoring Plan (EEMP). Given the sensitive nature of the NWA a plan should be provided for review.

Request: GOC recommends that EnCana provide a detailed Environmental Effects Monitoring Plan.

Response: Please see the response to Terr 17.

Reference: Volume 1, Section 2. Project Description, Page 2-1 Figures 2.1 and 2.2.

Preamble: The proponent states that no new roads with built-up road beds will be constructed but access routes to each well site will be established, and refers the reader to Figures 2.1 and 2.2. Access routes are not shown in the legend of either figure.

Request: GOC recommends that EnCana provide a map of all transportation and access routes showing all transportation and access routes to facilitate understanding of any statements made with regard to access.

Response: Given that the well location and planning process cannot occur until the spring / summer before the construction season, the map requested is not available. After the project has been approved (in the event approval is obtained) it will not be available until shortly before the commencement of the construction season. EnCana embarks on a lengthy planning process in advance of determining final locations. See section 2.2.1 of Volume 1 for a description of the preconstruction activities.

Reference: Volume 1, Section 2.1.1.3 Production, Page 2-8

Preamble: The proponent states that in the surrounding areas to the NWA, EnCana has drilled 124 sections including the D6/D8 area of the NWA, Koomati adjacent to the NWA, and in the Military Training Area. It further states that the results of the drilling programs indicate significantly increased reserves can be recovered with minimal environmental effects.

Request: The GOC recommends that EnCana discuss the assertion that the results of the drilling programs indicate that significantly increased reserves can be recovered with minimal environmental effects. Clarify whether comparative studies were conducted in Koomati before and after in-fill drilling took place.

Response: EnCana’s decision to proceed with shallow gas development at 16 wps was based on the performance of several 16 wps pilot areas across the southern portion of the Suffield Military Block. Each of these pilots has clearly demonstrated incremental reserves recovery with increased well density. Most pertinent to the proposed Project in the NWA is the performance of the wells drilled in the D6/D8 pilot area in 2001. Decline analysis of this pilot show incremental reserves recovery in excess of 100 MMCF/well. Decline analysis was also used to develop type curves and forms the basis of the projected production forecasts and reserves recovery discussed in Section 2.1.1.3 in Volume 1 of the Environmental Impact Statement and presented in EnCana’s Open House material an extract of which is attached. This incremental reserve recovery effect is further supported by independent analysis by our reserve auditors, other assessments by other auditors in other areas and by a similar decline analysis which can be done on other infill projects.

Specific comparative environmental studies were not completed for either the D6/D8 pilot or Koomati, however Post Construction evaluations have been conducted for both areas. The D6/D8 pilot was assessed by AXYS Environmental Ltd in 2004. Results showed on right-of-way vegetation communities were trending upward towards control conditions and 92% of right-of-ways had statistically similar vegetation communities to off right-of-way sites. Results did show significant amounts of bare soil on right-of- way versus off right-of-way, but AXYS clarified the comment by adding that based on their experience from other projects, what was observed for vegetation establishment is not uncommon given that all of the sites were less than 3 years old.

As part of EnCana’s ongoing post construction monitoring, 44 % of the 2005 shallow gas drilling program was assessed in 2006 using a modified Range Health assessment. 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-012 1 #Terr – 88 – A

Koomati was included as it was drilled in 2005. Highlights of the report include: • vegetative recovery is progressing as expected given the vintage of the program, especially on work areas, • no occurrences of restricted weeds and minor occurrences of noxious weeds, • good adherence to shut down criteria.

Outstanding work in Koomati will be completed in 2007 which will aid in further trend analysis.

In addition, rare plant monitoring by TERA Environmental Ltd. in Koomati along Rifleman Rd in 2005 indicated a robust population of sand verbena plants despite the drilling activity in the area. A follow up inventory in 2006 was suspended due to circumstances beyond EnCana’s control. The rare plant monitoring was re-initiated in 2007, the results of which are not yet available.

Reference: Volume 1, Section 2.1.4 Wells. Page2-10

Preamble: Very little detail is provided on the above ground wells. Cattle guards, production shacks, etc. are not disclosed.

Request: GOC recommends that EnCana clarify all well infrastructure that will be used, including but not limited to cattle guards. Provide figures, numbers, locations and details showing all above ground well infrastructure.

Response: Above ground infrastructure will include the following: • Pig launchers/receivers • Group meters • Wellheads • Scada antennas and solar panels

Cattle guards will be used in PFRA grazing areas but not in other parts of the NWA. Please see attached pictures for further examples.

Potential designs for an above ground meter site in the NWA. Design elements include meter run, pig sender/receiver, SCADA system including antenna and cattle guard.

These photographs were taken in our Alderson field just south of CFB Suffield. Approximate dimensions of this design is 3 by 4 metres with a SCADA antenna height of 12 feet. Antenna height in CFB Suffield would be reduced to 3 – 5 feet. 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-012 1 #Terr – 89 – A

Some of the existing production measurement facilities in the NWA are underground within a caisson. This photograph is of a SCADA system mounted on the grid section of a caisson. The grid section is about 2 by 2 metres with an antenna height of about 5 feet.

Production measurement and pig launching facility, typical for the Middle Sandhills area of the NWA. Photograph was taken about 40 metres from the production measurement building.

Older style above ground wellhead surrounded by a cattle guard. Photograph was taken about 100 metres from the wellhead.

Existing pig launcher/receiver facility in the Middle Sandhills area of the NWA. Approximate dimensions of this facility are 1 metre high by 1 metre deep by 2 metres long.

Cattle resting/grazing beside one our well site caissons in the southern portion of the NWA. 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-012 1 #Terr – 89 – A

Older style well head used in the Middle Sandhills area of the NWA. Approximate dimensions are 1 metre high by 2.5 metres long.

Newer style well head used in the Middle Sandhills of the NWA. Approximate dimensions are 1 metre high by 1 metre long. View is from about 100 metres away.

Most recent above ground wellhead design. Photograph is taken from about 7 metres away. Wellhead dimensions are approximately 1.2 metres high by 1 metre long. Cattle guard dimensions are approximately 3 by 3 metres.

Reference: Volume 1, Section 2.1.5 Gathering System. Page 2-10

Preamble: The proponent states that approximately 180km of 2 inch pipeline and 40km of 4, 6, or 8 inch steel pipe will be required for the loop lines. Figure 2-2 shows pipelines but is lacking in detail.

Request: GOC recommends that EnCana clarify whether Figure 2-2 shows all of the pipelines and flowlines that will be required. If not, provide a figure that shows all. Provide a figure clarifying which pipelines will be 4 inch, 6 inch and 8 inch or greater.

Response: Figure 2-1 and 2-2 show all of the proposed pipelines and flowlines based on desktop exercises. The routing will be finalized after the sites are reviewed in the field as per the PDA process and EPP requirements. The existing figures differentiate between HDPE and Loop lines; HDPE is shown as a ‘bright’ thin red line while the loop lines are shown in a darker shade of red and as a slightly thicker line.

Information indicating which lines will be 4, 6, and 8 is not available and will not be available until shortly before the commencement of the construction season. EnCana embarks on a lengthy planning process in advance of determining final locations. The final selection of line size is dependent on the production rates of the existing wells at the time of the project, expected well performance of new wells and the number of wells tied-in to a particular loop line.

EnCana wishes to note that the estimated total pipeline lengths listed in the EIS are incorrect and that there will be approximately 250km of HDPE and 100 km of loop lines required. The incorrect values (180 km and 40 km) were not used in effects analysis and thereby do not change any of the conclusions stated elsewhere in the document.

Reference: Volume 1, Section 2.2.2 Construction, p 2-16 to 2-19 Volume 1 Section 2.2.3 Operations , Page 2-11, Page 2-19

Preamble: The proponent states that existing access roads will be utilized whenever possible and where appropriate. The terms of reference call for daily work schedules to be provided for every phase of the project. The proponent states “On average, two industry (EnCana) vehicles enter the NWA each day…”. In sections 2.2.2 Construction and Section 2.2.3 Operations, the proponent provides estimates of vehicle site visits for various activities but no overall assessment. During operations new wells (page 2-19) will be visited a minimum of once per month and annually thereafter. The existing 1145 wells will also receive annual visits. They indicate each truck will visit 15-20 wells per day. Information on the number of wells visited daily and the timing of these visits seasonally is needed to determine direct and indirect project effects, residual and cumulative effects.

Request: GOC recommends that EnCana provide details of the daily work force and schedules for every phase of the project.

Reference: Volume 1. Section 2.1.7, Other Infrastructure Page 2-14

Preamble: The proponent states that batteries with solar panels will be used to supply permanent power to group meter site transmitters and radio. A detailed description, location and numbers are not provided.

Request: GOC recommends that EnCana discuss the meter site transmitters with the solar panels. Provide the number of and figures showing the locations of group meter sites with solar panels.

Response: Below is a list of existing metering station in Suffield, a description of a SCADA group meter and a photograph of a typical belowground site.

Given that the well location and planning process cannot occur until the spring / summer before the construction season, the final locations requested are not available. After the project has been approved (in the event approval is obtained), it will not be available until shortly before the commencement of the construction season. EnCana embarks on a lengthy planning process in advance of determining final locations. See section 2.2.1 of Volume 1 for a description of the preconstruction activities.

Meter/Location Number Meter/Location Name SUF_B2_01-04MR1 SUFFIELD B2 01-04-20-03 W4M GROUP 15 SUF_B2_01-04MR2 SUFFIELD B2 01-04-20-03 W4M GROUP 16 SUF_B2_04-03MR1 SUFFIELD B2 04-03-20-03 W4M GROUP 17 SUF_B2_04-03MR2 SUFFIELD B2 04-03-20-03 W4M GROUP 18 SUF_B2_16-16MR1 SUFFIELD B2 16-16-18-04 W4M GROUP 9 SUF_B2_16-16MR2 SUFFIELD B2 16-16-18-04 W4M GROUP 10 SUF_B2_16-31MR1 SUFFIELD B2 16-31-19-03 W4M GROUP 14 SUF_B2_16-32MR1 SUFFIELD B2 16-32-19-03 W4M GROUP 13 SUF_B2_16-33MR1 SUFFIELD B2 16-33-17-04 W4M GROUP 11 SUF_B2_16-33MR2 SUFFIELD B2 16-33-17-04 W4M GROUP 12 SUF_D_16-10MR1 SUFFIELD D 16-10-17-05 W4M GROUP 14C SUF_D_08-28MR1 SUFFIELD D 08-28-15-06 W4M GROUP 5 SUF_D_08-28MR2 SUFFIELD D 08-28-15-06 W4M GROUP 6 SUF_D_08-04MR1 SUFFIELD D 08-04-16-06 W4M GROUP 7 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-012 2 #Terr – 95 – A

SUF_D_08-04MR2 SUFFIELD D 08-04-16-06 W4M GROUP 8 SUF_D_08-04MR3 SUFFIELD D 08-04-16-06 W4M GROUP 6B SUF_D_08-16MR1 SUFFIELD D 08-16-16-06 W4M GROUP 9 SUF_D_08-16MR2 SUFFIELD D 08-16-16-06 W4M GROUP 10 SUF_D_08-16MR3 SUFFIELD D 08-16-16-06 W4M GROUP 8B

1.0 SCADA SYSTEM

1.1 SCADA Hosts – Hardware

Supervisory Control and Data Acquisition (SCADA) Hosts are located at each compressor station. These hosts, via telemetry, communicate with and collect production information from the Remote Terminal Units (RTUs) located at existing group meter sites. As an example the SCADA host located at E Compressor Station will communicate with and gather production measurement data from E area group meter sites. The SCADA Hosts have recently been upgraded to new desktop Personal Computers (PC’s).

1.2 SCADA Host – Software

1.2.1 Operating System All new desktop PC’s acting as SCADA Hosts are currently running Windows XP with appropriate Service Packs and Patches.

1.2.2 SCADA Host software All new SCADA Hosts have been equipped with iFix version 4.0, which is the latest version from GE Fanuc. In order for the group meters to be compliant with the EUB requirements, the proper validation, archiving and reporting functionality is required. EnCana is supporting Flow-Cal for this purpose. In order to communicate properly with Flow-Cal, data needs to be presented in a .cfx file format. AutoSol is a proven I/O server that would replace the native GE Fanuc I/O Server, capable of providing such .cfx file.

1.3 Gas Flow Measurement Hardware

1.3.1 Transmitter 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-012 3 #Terr – 95 – A

A transmitter, installed within existing group meter caissons and inches from the existing meter run, is used to convert production measurements (static pressure, differential pressure and temperature) into electronic signals. The transmitter communicates modbus with the RTU via RS-485. One transmitter complete with 5-valve manifold and RTD is required for every meter run. Due to the design of the gathering system, most group meter sites have 2 meter runs. One visit per year to each group meter site will be required to confirm calibration of the transmitters. EnCana’s standard for 3 in 1 transmitters in Suffield is Rosemount model 3095.

1.3.2 Remote Terminal Unit (RTU) RTUs receive electronic production measurements from the transmitter, perform flow calculations and communicate production information to the SCADA Host via telemetry. The SCADAPack LP is the Remote Terminal Unit (RTU) used at the group meter sites. These RTU’s are capable of performing 2 gas flow calculations. As a result, only one RTU is required at each group meter site.

1.3.3 Radio For fast communication and license free frequency use, “spread spectrum” radios will be utilized at each group meter site. EnCana’s standard of MDS Transnet, 900MHz radios will be utilized for communication to the SCADA host from the group meter site RTUs. The transmitter output power of these radios is 1 watt.

1.3.4 Power Supply

Where grid power is not available, direct current batteries with a solar panel (60 cm X 60 cm) will be used to supply power to the group meter site transmitters, RTU and radio. These solar panels will be mounted with a 22.5 degree angle to maximize solar cell exposure to the sun. Based on power requirement calculations at previously installed metering setups and polling frequency of sites north of CD Station, each metering site will require one 30 Watt solar panel and 2 batteries (100 Amp-hours). Based on past experience, the life cycle of these batteries is expected to be 3 years. As a result, we anticipate one visit to each group meter site every 3 years to replace batteries.

1.3.5 Antenna & Mast 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-012 4 #Terr – 95 – A

A Yagi directional antenna mounted on an aluminum 50.8 mm schedule 40 mast is required for each radio. The mast height, including antenna, ranges between 0.9 and 1.5 metres. The mast is also used to mount the solar panel.

50.8 mm schedule 40 aluminum pipe has a yield strength ranging between 138 – 482 MPa. Using the worst case scenario of 482 MPa, a force of 6.3 kN is required to break the mast when applied 0.5 metres above grade. This force is equivalent to a mass of 640 kilograms being acted upon by gravity.

With the exception of battery replacement, addressed in 1.3.4, equipment maintenance incremental to the current maintenance practices and schedules is not anticipated. Visitation to the group meter sites, however, will be significantly reduced because staff will not need to manually collect production data. Manually collecting production data currently requires one man day per week per area, times 9 areas.

Reference: Volume 1. Section 2.2.1 Pre-Construction Activities. Page 2-15,16. Volume 3 Section 5.8.2 Mitigation Page 5-45.

Preamble: Volume 1 page 2-15, the proponent states that well site selection has yet to be determined and states in very general terms the criteria that will be considered in site selection and route locations. In Volume 3 Page 5-45 the proponent states that “Pre-disturbance assessments (PDAs) will be undertaken to identify special habitat features (i.e. leks, hawk and eagle nest sites, kangaroo rat den sites; amphibian breeding ponds; snake hibernacula). Specific timing restrictions and especially setback distances to be observed are not listed in the proponents report. Because there is variability among the citations and various interpretations, timing restrictions and setbacks the company will utilize must be spelled out in detail to enable an assessment of the environmental effects.

Request: GOC recommends that EnCana provide detailed wellsite selection criteria.

Response: Preliminary locations are chosen on the basis of all existing and available information on siting factors (see list below). Reservoir information via the baseline mapping process is also considered. Locations are preliminarily located 100m, at most, from ideal reservoir drainage positions.

Subsequent to the preliminary siting (baseline mapping), EnCana will then take into consideration various other siting criteria. As this Project is in a National Wildlife Area, EnCana is carefully analyzing and considering the prioritization of wildlife and wildlife habitat in determining locations. The siting factors for wellsites, pipelines and access routes include: • Provincially and Federally designated wildlife species at risk, sensitive wildlife species and their critical or sensitive habitat; • rare plants and rare plant communities; • wetlands, waterbodies and riparian areas; • sensitive and unstable soils and terrain; • areas of importance to First Nations; • historical, archaeological, and palaeontological resources; • research locations (e.g., sampling or data collection sites); • minimization of ground disturbance; and

• shortest distance between facilities. Once the foregoing criteria are applied, EnCana will analyze the proposed site. If the proposed site is outside of a Federally determined setback (or Provincially for species without Federal setbacks), the site will be deemed to be acceptable and “approved”. If an alternative location that does not require reducing a setback distance is not possible then the decision-making process for the appropriate siting factor is utilized to determine whether mitigation measures are sufficient to reduce the setback distance or not. If there are multiple constraints at a location, then it is assessed to determine whether one or more of the setbacks can be reduced while maintaining environmental protection until there is a location where either the setback is maintained or reduced with standard mitigation measures.

If standard mitigation measures are insufficient, or if there is uncertainty as to whether they are sufficient, the location will be referred to a separate process. The PDA materials will be provided to an expert in that siting factor for advice on whether the location can be utilized with appropriate mitigation measures. If the location is suitable after consultation with the expert(s), EnCana will refer the site to SEAC. SEAC will recommend whether to approve or deny the location (as per the provisions of the 1975 Surface Access Agreement).

Reference: Volume 1, Section 2.8, Page 2-41, Volume 3, Section 3.1, Page 3-1, Section 3.9, page 3-30, Section 4.8.2.2, Page 4-16, 5.6.5.3, Page 5-17, Section 7.1, Page 7-1 as examples

Preamble: EnCana uses the terms technically and economically not feasible and feasible in multiple locations in volumes 1 and 3. These are used to describe (Volume 1) reasons for not pursuing examination of the Alternative Means or (Volume 3 and its appendices) methods, or situations where an exception is made to efforts to observe set back rules, apply mitigation, or avoid outright destruction of Valued Environmental Components.

Request: GOC recommends that EnCana provide: 1. Describe the terms technically and economically not feasible and feasible. 2. An estimate of the portion of the Project (number of wells, km of pipeline, km of trail) where exceptions were or may be invoked, with reference to set backs provided by discipline leads, other mitigation, or outright destruction.

Response: 1. The criteria are discussed in Section 1.4.2 of Volume 1.

2. Given that the well and pipeline location and planning process cannot occur until the spring/summer before the construction season, the final Project design is not available. After the Project has been approved (in the event approval is obtained), it will not be available until shortly before the commencement of the construction season. EnCana embarks on a lengthy planning process in advance of determining final locations. See section 2.2.1 of Volume 1 for a description of the preconstruction activities.

Reference: Volume 1. Pg. 2.50

Preamble: Remote sumps will result in large amounts of mixed bury cover at depths of 1 to 1.5 m.

Request: GOC recommends that EnCana provide details on where will this occur, as well as what will be the impact of this cumulatively and to the source populations required to re-establish the NWA.

Response: Remote sumps will be located outside the NWA, but on CFB Suffield. Remote sump locations will be chosen wherever possible on lands that have been previously disturbed and/or have evidence of crested wheat grass, thus reducing any disturbance of native prairie. The PDA process will determine appropriate sites for sumps.

However, given that the well location and planning process cannot occur until the spring / summer before the construction season, the information on siting requested is not available. After the project has been approved (in the event approval is obtained), it will not be available until shortly before the commencement of the construction season. EnCana embarks on a lengthy planning process in advance of determining final locations. See section 2.2.1 of Volume 1 for a description of the preconstruction activities.

As EnCana sites remote sumps on previously disturbed (and not sucessfully) sites including crested wheatgrass areas, remote sumps will be replacing existing disturbance areas with sites that will be reclaimed utilizing the methodology discussed in response to Gen 48. Thus, this method of waste disposal will result in the creation of wildlife habitat relative to the existing conditions.

Reference: Volume 3 Section 5.9 Cumulative Effects 5-125

Preamble: A base case of 8 wells per section is provided throughout the documents (e.g. Section 5.9 Cumulative Effects Page 5-125).

Request: GOC recommends that EnCana provide justification for using a base case of 8 wells per section as opposed to presenting a base case of no wells per section. Response: Eight wells per section is the existing well spacing in the NWA. There are no sections without wells. Eight wells per section were used as the base case. The effects of infill drilling are being considered for EIS purposes of the Project.

yes Reference: Volume 3. Pg. 7.8. Section 7.3.5.

Preamble: Future land actions in the local and regional study areas. “The spatial distribution of planned wells is not currently available”

Request: GOC recommends that EnCana discuss the spatial distribution of all proposed wells within NWA.

GOC recommends that EnCana provide similar information regarding pipelines as well as access routes.

Response: Given that the well and pipeline location and planning process cannot occur until the spring/summer before the construction season, the final Project design is not available. After the Project has been approved (in the event approval is obtained), it will not be available until shortly before the commencement of the construction season. EnCana embarks on a lengthy planning process in advance of determining final locations. See section 2.2.1 of Volume 1 for a description of the preconstruction activities.

Reference: Volume 3, Section 7.3.5 Cumulative Effects. Page 7-8

Preamble: Long range forecasts for in-fill drilling suggest that “no further in-fill drilling is anticipated to occur […] upon completion of the 16 wps infill drilling”.

Request: GOC recommends that EnCana provide the rationale and assumptions upon which this assertion is based.

Response: EnCana has confirmed in prior responses to Information Requests that it has no plan to undertake additional infill drilling (subsequent to the proposed Project). This is not an assumption.

Reference: Volume 1, Appendix H ‘Conceptual Reclamation Plan’, Section H.1, Page H-3

Preamble: EnCana states that ‘Soil disturbance is a natural and necessary process that confers functionality to the rangeland landscape. The level of disturbance, however, must remain within a range of variability that is sustainable….’

Request: GOC recommends that EnCana discuss how the proposed disturbance is analogous to natural soil disturbance with references to scientific literature.

Response: EnCana provides the following example of how the proposed disturbance could be analogous to natural soil disturbance. Below is a photo of a plant of sandhills bluestem (Andropogon hallii HACK.) that appeared in 1991 on the center-line one year after TransCanada PipeLine constructed a large-diameter pipeline in The Great Sand Hills of Saskatchewan (personal communication, D.Walker, August 2007). Sandhills bluestem is common to sandy regions of Montana, Wyoming, Nebraska, North Dakota, and particularly Kansas but had never been previously reported in the Saskatchewan sand hills (Townley-Smith 1980).

Plants of sandhills bluestem expanded in numbers down the disturbed area of the right- of-way, which was fenced for protection against disturbance from cattle and by 1994, when another pipeline was constructed, the plant population was approximately 50 individuals spread over about 3 km. In 2001, the population had expanded further in number and range down the right-of-way but not outside the area of disturbance created by pipeline construction.

The possibility that seed of the original plant had been introduced during construction was ruled out (all construction equipment was new and the all-native seed mix came from growers in Alberta and Saskatchewan). It was speculated that the seed was 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-012 2 #Terr – 120 – B

dormant in the seed bank and that the disturbance from construction stimulated germination. In time and without further disturbance, edaphic and plant community changes could possibly weaken the competitive advantage that sandhills bluestem has in this location and the population could decline.

Townley-Smith, L. 1980. Vegetation of the Great Sand Hills. IN: Epp, H.T. and Townley-Smith, L. (ed.). The Great Sand Hills of Saskatchewan. Planning and Research Branch, Saskatchewan Environmental Resource Management, Saskatoon. pp. 156.

Walker, D.G. and M. Mears. 1994. Fourth Year Monitoring Program, Great Sand Hills Portion of the Burstall-Liebenthal Loop. Prepared for TransCanada Pipelines Limited by Western Oilfield Environmental Services Ltd. and David Walker and Associates Limited. 25 pp.

Reference: Volume 1, Appendix H ‘Conceptual Reclamation Plan’, Section H.1, Page H-4

Preamble: The proponent states that restoration of plant communities “may not be desired or even possible at some sites because of the permanent loss of soil and/or genetic resources and the invasion and/or expansion of other species.” This is contrary to the “relevant sections” in the report that conclude that these impacts will have negligible, insignificant, or significant impacts.

Request: GOC recommends that EnCana explain the discrepancies in these statements.

Response: As these statements in the Conceptual Reclamation Plan refer to site-specific reclamation, they are not contradictory as this will still result in the assessment of the Project on specific VECS as negligible or insignificant. The Conceptual Reclamation Plan follows an approach to reclamation that is based on landscape functionality as the goal or target for reclamation success. This concept is explained in paragraphs that precede the one from which the quote in the question has been taken. Three attributes of a "functional" or "healthy" landscape are: (1) site stability, (2) watershed function, and (3) biotic integrity. Where there is functional redundancy among plant species, landscape functionality may be possible with multiple assemblages of plant species. Thus the impact of the Project may be negligible or insignificant but could also be positive depending on location. EnCana’s obligation is to reclaim to equivalent land capability.

The NWA has been modified by human activities for more than a century, including cattle grazing, farming, military activities and gas development As such, reclamation to a pre-disturbance plant community composition may not be desired if it has been degraded by past land use, or if the composition is a non-native remnant of a cultivated field. To reclaim a disturbed area back to a degraded landscape would be irresponsible if there is an opportunity to improve landscape functionality.

A specific example can be drawn from the research of Dormaar and others (1994) near Lethbridge. They report that after 14 years of protection from grazing, foliar cover of needle-and-thread grass was 79% vs. 18%, and blue grama was 1 vs. 51% on abandoned cropland vs. uncultivated. The researchers concluded that to facilitate a rapid transition from a less productive native plant community dominated by blue grama to a more productive native plant community dominated by needle-and-thread grass, an input of energy, such as brief cultivation, may be required.

J. Dormaar, B. W. Adams and W. D. Willms. 1994. Effect of grazing and abandoned cultivation on a Sipa-Bouteloua Community. Journal of Range Management 47(1): 28- 32.

Reference: Volume 1, Appendix H ‘Conceptual Reclamation Plan’, Section H.3.2, Page H-6 to H-7 Volume 1, Appendix I ‘Environmental Protection Plan’, Section I.5.9, Page I-26

Preamble: In points numbered 4. and 5. (Appendix H), the terms Desirable and Undesirable are used but not defined. This may imply native vs. exotic origin, known invasibility of exotics, species from noxious weed lists (which include some native annuals), or some other criterion.

The Proponent states (Appendix I) “Undesirable vegetation may include restricted, noxious weeds, and may include specific nuisance weeds and species that are not native and compatible with the objectives of reclamation and the NWA.” It is not clear that crested wheatgrass, yellow sweet clover, and smooth brome will be considered undesirable and will be controlled as any other weed.

Request: GOC recommends that EnCana describe the terms Desirable and Undesirable with reference to a species list that unequivocally categorizes each species and reference the list in both Appendices with consideration of the most problematic exotic species, which are listed in the information letter “Problem introduced forages on reclaimed sites in Alberta”.

Response: EnCana defines undesirable plant species as those that negatively impact the functionality of the rangeland landscape. Desirable plant species are those that positively impact landscape functionality (see definition, Volume 1, Appendix H, Section H.1).

EnCana is committed to abide by the regulations of the Alberta Weed Control Act which defines weeds under three designations: restricted (must be eliminated); noxious (must be controlled) and nuisance (must prevent the spread) (AENV 2003a and b).

Plant species, both native and exotic, are designated as agricultural weeds when they pose a threat to productivity on cropland. The same species may not pose a threat to functionality on rangeland at the landscape level. Agricultural weed species could be considered benign on rangeland if there is a very low potential for spread to cropland.

Recent research on the autecology of invasive species has cast doubt on using apparent "invasibility" as the only characteristic for defining a species as the target for control (Lockwood and others 2005, Pokorny and others 2005). MacDougall and Turkington (2005) found that mowing or complete removal of an exotic, invasive grass increased light availability and bare ground but 36 of the 79 native species monitored did not 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-012 2 #Terr – 124 – B

respond positively or had a neutral to negative response to the reduced competition.

Jacobs and others (1998) report that weed control on rangeland is short-lived if propagules of desirable species are not available to occupy the niches opened up by weed control procedures. Furthermore, functionality can decline if more bare ground results in higher erosion rates and/or other undesirable species establish.

According to Adams and others (1997), non-native species in the NWA total 57 species or 14% of the flora and generally occupy successional stages in the NWA and in local instances are aggressive invaders into native communities. Many species were introduced into the NWA when the area was still under cultivation. Some were introduced for industrial revegetation and some for pasture improvement. Most are widespread throughout North America.

EnCana takes the position that desired plant species in the NWA are local, native species in an assemblage that promotes rangeland functionality. Current policy in Alberta regarding the goal of revegetation for prairie disturbances is “to promote the re-establishment of sound ecological function and eventually restore the original range of variability in biological structure and diversity” (Sinton 2001, Sinton and Pitchford 2002). Desirable species are those that facilitate reaching this goal and undesirable species are those that would prevent the goal being reached. EnCana’s obligation is to reclaim to equivalent land capability.

EnCana takes the position that most exotic species in the NWA have a minor impact on landscape functionality under current land use conditions and therefore do not require control measures. EnCana accepts the advice that any widespread weed management must integrated with other land use managers ( Hiebert and Stubbendieck 1993, Jacobs and others 1998). .

EnCana regards any species that impedes the establishment of desired plant species on disturbances created by The Project as undesirable and are a trigger for taking control measures.

EnCana considers crested wheatgrass, yellow sweet clover, and smooth brome as undesirable in areas of the NWA where they do not presently occur. However, where a disturbance from The Project occurs in an abandoned field seeded to those species, EnCana will attempt to establish desirable species but will not attempt to prevent re- establishment of plants from seeds in the topsoil seedbank.

EnCana regards Russian thistle, kochia, and tumbling mustard (tumbling weeds) as undesirable in areas where they have accumulated to considerable depth in some of the 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-012 3 #Terr – 124 – B

ravines leading to the South Saskatchewan river. The accumulations could be considered a significant threat to the functionality of the ravines. To avoid any further negative impact from the dispersal of tumbling weeds that grow and disperse from construction sites, EnCana will ensure these species are controlled on disturbances created by the Project.

References Cited

Adams, G.D., Trottier, G.C., Strong, W.L., Macdonald, I.D., Barry, S.J., Gregoire, P.G., Babish, G.W. and Weiss, G. 1997. Vegetation Component Report Canadian Forces Base Suffield National Wildlife Area Wildlife Inventory. Canadian Wildlife Service, Environment Canada, Prairie and Northern Region, Edmonton, Alberta 101 p.

Alberta Environment. 2001. Problem introduced forages on prairie and parkland reclamation sites (non-cultivated land) C&R/IL/01-6 2pp. Sinton, H.M. 2001. Prairie Oil and Gas: A Lighter Footprint. Alberta Environment. ISBN 0-7785-1711-X. 67 pp.

Hiebert, R.D. and Stubbendieck, J. 1993. Handbook for Ranking Exotic Plants for Management and Control. US National Park Service NRMWRO/NRR93/08. 30 p. http://www2.nature.nps.gov/pubs/ranking/ranking.htm

Jacobs, J.S., Carpinelli, M.F. and Sheley, R.L. 1998. Revegetating weed-infested rangeland: What we've learned. Rangelands 20(6):10-15.

Lockwood, J.L., Cassey, P. and Blackburn, T. 2005. The Role of Propagule Pressure in Explaining Species Invasions. Trends in Ecological Evolution. 20(5):223-228.

MacDougall, A.S. and Turkington, R. 2005. Are invasive species the drivers or passengers of change in degraded ecosystems? Ecology. 86(2):42-56.

Pokorny, M.L., Sheley, R.L., Zabinski, C.A., Engel, R.E., Svejcar, T.J. and Borkowski, J.J. 2005. Plant Functional Group Diversity as a Mechanism for Invasion Resistance. Restoration Ecology. 13(3):448-459.

Sinton, H.M. and Pitchford, C. 2002. Minimizing the Effects of Oil and Gas Activity on Native Prairie in Alberta. Prairie Conservation Forum, Occasional Paper Number 4. 40 p.

Reference: Volume 1, Appendix H ‘Conceptual Reclamation Plan’, Section H.3.3, Page H-7

Preamble: Cover crops are recommended for use to suppress weed growth during reclamation. Unfortunately, there is no definition of what constitutes a weed.

Request: GOC recommends that EnCana explain the rationale for a cover crop in detail, and re- evaluate the use of cover crops in light of potential impacts on endangered and threatened plant species at risk.

Response: EnCana is committed to abide by the regulations of the Alberta Weed Control Act which defines weeds under three designations: restricted (must be eliminated); noxious (must be controlled) and nuisance (must prevent the spread) (AENV 2003a and b). EnCana may also consider a species undesirable if landscape functionality is negatively affected (landscape functionality is defined in Volume 1, Appendix H, Section H.1). For example, foxtail barley (Hordeum jubatum) is an aggressive native species that can, under some circumstances, be a concern to land managers because it can cause mechanical damage to grazing animals.

Section H.3.3 does NOT state that cover crops are recommended PRIMARILY for use to suppress weed growth. Cover crops are recommended as an efficient method of plant establishment if seeded alone in the first of two steps. In Step 1, the cover crop is seeded when construction is complete. In step 2, the desired perennial seed mix is seeded into the standing stubble of the dead cover crop. The method may also be useful as a means to suppress weed growth.

Termed the two-step cover crop or stubble mulch method, it has proved over time to be a very reliable means to establish forages in the arid region of the Northern Great Plains (Jones and others 1975, Schuman and others 1980, King and others 1989). The “two-step” approach of seeding annuals first to control wind erosion and suppress weeds, followed by seeding native species into the stubble (in the fall), is the method most likely in southern Alberta to have the best outcome (a functioning diverse native plant community) in a timely manner (AENV 2003c).

Cover crops are not recommended if planted at the same time as the perennial species because competition from the faster-growing cover crop could result in reduced growth or outright failure of the slower-growing perennial species (Walker 1983).

During Step 1, when the cover crop is growing and the in situ mulch cover is being produced, weeds growth may be suppressed through competition. For the same reason 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-012 2 #Terr – 125 – B

of competitive ability, the cover crop also has the potential to suppress the growth of desirable species in the topsoil seed bank. If species at risk are present in the seed bank, they could also be negatively affected.

The Environmental Protection Plan contains specific measures that will be taken to avoid plant species at risk (Volume 1, Appendix I, Section 1.5.5). Before construction begins, all sites will have rare plant pre-disturbance assessments (PDAs) and measures are described to avoid or minimize disturbing the ground surrounding the plants.

The stubble mulch method for plant establishment is generally used on difficult sites where the risk of a seeding failure is high or where there has already been a failure and the seed bank is depleted. Such conditions, however, may possibly benefit some species-at-risk in the NWA. Species such as sand verbena, Tripterocalyx [Abronia] micranthus and Western spiderwort (Tradescantia occidentalis) are adapted to active sand dunes and may depend on the open ground resulting from disturbance.

The use of a cover crop could benefit these species over the short term by suppression of other species and by creating an open but stable ground surface over the medium term— positive conditions for an annual or short-lived perennial species while minimizing soil loss.

References Cited

Alberta Environment. 2003a. Weed Awareness for Reclamation. http://environment.gov.ab.ca/info/library/6886.pdf

Alberta Environment. 2003b. Weeds on Industrial Development Sites. R&R/03-4. 5 pp.

Alberta Environment. 2003c. Revegetation Using Native Plant Materials. R&R/03-3. 7 pp. http://environment.gov.ab.ca/info/library/5927.pdf

Jones, J.N., Armiger, W.H. and Bennett, O.L. 1975. A Two-Step System for Revegetation of Surface Mine Spoils. Journal of Environmental Quality. 4(2):233-235.

Schuman, G.E., Taylor, E.M., Rauzi, F. and Howard, G.S. 1980. Standing stubble versus crimped straw mulch for establishing grass on mined lands. Journal of Soil and Water Conservation. 35:25-27.

King, M.A., Waller, S.S., Moser, L.E. and Stubbendieck, J.L. 1989. Seedbed effects on grass establishment on abandoned Nebraska Sandhills cropland. Journal of Range 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-012 3 #Terr – 125 – B

Management. 42(3):183-187.

Walker, D.G. 1983. Effect of revegetation treatments on soil erosion, plant establishment, and species composition in the Great Sand Hills of Saskatchewan. IN: Eighth Annual Meeting of the Canadian Land Reclamation Association. August 21-24, Waterloo, Ontario. Canadian Land Reclamation Association. pp. 213-226.

Reference: Volume 1, Appendix H ‘Conceptual Reclamation Plan’, Attachment H-6, Page H- 35

Preamble:

Request: GOC recommends that EnCana provide a clear justification for any organic amendment that is consistent with the goals of biodiversity conservation in the National Wildlife Area.

Response: EnCana recommends an organic matter amendment where appropriate for sites lacking sufficient topsoil to support a healthy plant cover capable of reducing erosion and improving ecosystem functionality.

EnCana regards soil quality as a critical component of ecosystem functionality expressed as water and wind erosion, salinization, and loss of soil fertility. When soil loses vegetation cover, soil becomes more susceptible to wind and water erosion. In a process called deflation, wind entrains the finer soil particles and organic material from the soil. A concentrated layer of coarse sand with little or no structure is left behind. The loss of organic material decreases soil aggregation and stability, so the soil is left even more susceptible to aeolian erosion. Existing plants and seedlings are more likely to be "sandblasted" and buried. The water-holding capacity and the nutrient content of the soil are reduced when organic material is lost, which is an additional strain on vegetation survival. A soil is most vulnerable to deflation and wind erosion in arid regions and hot, windy climates. The most important single factor in protecting soil fertility is vegetation.

The probability of topsoil loss caused by construction is very low because ground- disturbing activities are scheduled for the dormant season when the ground is normally frozen and also because EnCana uses low impact methods that create a very small disturbance footprint (well area is typically five by six meters, and tie-in lines are typically plowed-in (Volume 1, Section 1.1.2).

EnCana notes that an organic matter amendment is one of several options available for mitigating a site where, because of low soil fertility, active wind erosion poses a threat to or an impairment of ecosystem functionality such as air or water quality. An alternative option for improving soil fertility is less appealing— exotic forage legumes such as alfalfa and cicer milkvetch. The soil loss standard provides guidance assessing risk and guidance for taking action (Volume 1, Appendix H, Section H.2.2).

Information Sources 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-012 2 #Terr – 128 – B

Herrick, J.E., Weltz, M.A., Reeder, J.D., Schuman, G.E. and Simanton, J.R. 1999. Rangeland Soil Erosion and Soil Quality: Role of Soil Resistance, Resilience, and Disturbance Regime. IN: Rattan, L. (ed.). Soil Quality and Soil Erosion. CRC Press. pp. 209-233.

Pimentel, D. and 10 others. 1995. Environmental and Economic Costs of Soil Erosion and Conservation Benefits. Science. 267:1117-1123.

Whisenant, S.G. 1999. Repairing Damaged Wildlands: A Process-Oriented, Landscape-Scale Approach. Cambridge University Press, Cambridge, UK.

Reference: Volume 1, Appendix H ‘Conceptual Reclamation Plan’

Preamble: The Guidelines for the EIS state the proponent is to provide “…how reclamation will be implemented should the project, or portions thereof, change ownership, or the proponent becomes insolvent.”

Request: GOC recommends that EnCana provide this information and discuss provisions for the posting of a bond. Response: (i) Insolvency In EnCana’s view, a bond is not required because pursuant to the 1975 Gas Agreement (“the Agreement”) between the Province of Alberta and the Government of Canada, assigned to EnCana, both the Province of Alberta and EnCana are jointly and severally liable to the Government of Canada for any damage resulting from shallow gas operations. This provides security in the extremely unlikely event that EnCana becomes insolvent.

Oil and gas operators are also subject to a comprehensive liability management program under the Alberta Energy and Utilities Board (“EUB”) which, in addition to monitoring an operator's ongoing ability to address its abandonment and reclamation liabilities on a monthly basis, also monitors an assignee's ability to address its abandonment and reclamation liabilities upon submission of any license transfer application. Accordingly, in the event that the Project changes ownership, and the deemed liabilities of the proposed assignee exceeds the deemed assets, such proposed assignee would be required to place a bond or security deposit with the EUB equal to the difference between its deemed liabilities and deemed assets, before the license transfer application is approved.

In addition, the EUB indicated to DND in a letter of May 14, 2007 (attached )that it would discuss, in conjunction with the Alberta Oil and Gas Orphan Abandonment and Reclamation Association, the potential participation of DND in the Alberta “Orphan Wells Fund” in respect of wells located on CFB Suffield (including the NWA). In the extremely unlikely event that EnCana did not have sufficient funds on deposit with the EUB to meet its abandonment and reclamation obligations on the Suffield NWA, such obligations could be met through the Orphan Well Fund. The EUB assesses an annual levy against all oil and gas operators in Alberta. These funds are then contributed directly to the Orphan Well Association to cover expenditures in respect of such “orphan” abandonment and reclamation activities.

EnCana is the leading North American unconventional natural gas and integrated 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-012 2 #Terr – 129 – C

oilsands company with second quarter 2007 gas production of 3.51 bcf/d and 133,000 bbls/d of oil and NGL production. EnCana maintains a strong balance sheet, targeting a net debt-to capitalization of 30-40%. EnCana has a net debt-to-capitilization of 29:71 and a net debt-to-adjusted-EBITDA of 0.8 times.

(ii) Change of Ownership The Agreement also provides mechanisms to address those circumstances where the project changes ownership. EnCana cannot further assign the Agreement without the “prior approval in writing of Canada.” Accordingly, in the event that the Project changes ownership, Canada will have the opportunity to assess the ability of any proposed assignee of EnCana to meet future reclamation obligations relating to the Suffield NWA and impose such conditions (including the posting of an appropriate bond or letter of credit) as the circumstances warrant. Please see EnCana’s response to Gen 11 for a discussion of EnCana’s present statutory and contractual reclamation commitments.

Reference: Volume 1. Appendix H. Pg I-28 Sec 172

Preamble: EnCana states “Where access trails traverse slopes, the trail will be aligned to create rolling dips that will drain water off the trail. The dips in the access trail may be of a duration that allows vehicle passage and may be spaced at 30 m apart for up to 10% slopes, 20 m for 15 % sloped and 10 m for 25% slopes”.

Request: GOC recommends that EnCana provide documented support on why these parameters were selected and describe how they will minimize the impact to the ecosystem. Response: EnCana recommends integrating rolling dips into the route of new access trails that climb a side slope. The requirement for new access trails is expected to be low because existing access trails will be used where possible and if in stable and durable condition (not actively eroding). The requirement will be determined during the Pre-development Assessment (PDA).

The rolling dip is a best management practice (BMP) borrowed from the forest industry where it is has long been a standard design consideration for mitigating the environmental impact of erosion off un-surfaced roads (Keller and Sherar 2003). The BMP can also be seen on durable hiking trails, for example the trails constructed by Lawrence Grassi in the 1950's at Lake O'Hara and Skoki Lodge in Banff National Park and behind Canmore. More recently, rolling dips have been incorporated into sustainable trails designed for OHVs and mountain bikes (Poff 2006).

EnCana offers calculations of estimated soil loss from the three scenarios to demonstrate the value of rolling dips in reducing soil loss. The Revised Universal Soil Loss Equation for Application in Canada (RUSLEFAC) is a version of the Universal Soil Loss Equation that was modified specifically for Canadian conditions by a consortium of federal and provincial soil scientists (Wall and others 2002). Results are illustrated in table format below.

The calculations indicate that breaking up a 100 m long slope into short segments by incorporating rolling dips into the route design can significantly reduce soil loss. RUSLEFAC predicts an annual rate of soil loss for the three scenarios, 30 m segment at 10%, 20 m segment at 15%, and 10 m segment at 25%, in the range of 7.3 to 8.4 tonnes per hectare per year (t/ha/yr). By comparison, a 100 m trail at a gradient of 25% constructed without dips is predicted to erode at a rate of 25 t/ha/yr.

Total annual soil loss is calculated by combining the soil loss rate with area of 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-012 2 #Terr - 132 - A

disturbance. The segmented trails have a predicted annual soil loss that ranges from 4 to 13 kilograms per year (kg/yr). A 100 m trail at 25% is predicted to annually lose a total of 127 kg.

For long-term sustainable land use, soil loss from erosion should be no greater than the rate of formation under local conditions, which vary with climate, land use, and nature of the soil parent material. Wall and others (2002) suggest that a soil loss rate of 11 t/ha/yr is a sustainable level of soil loss on deep, well-structured agricultural topsoil with high organic matter content and a permeable subsoil. A soil loss value of less than 6 t/ha/yr is recommended for dark and light colored soils.

EnCana has proposed a target soil loss standard for reclamation success on well sites and pipelines at 4 t/ha/yr (Volume 1, Appendix H, Section H.2.2, page H-4) and a maximum of 2 t/ha/yr if there is connectivity to a water body. Predicted soil loss from the three scenarios is greater by an approximate factor of 2 (7.3 to 8.4 t/ha/yr) but is within the range of accuracy of the model. In addition, soil loss does not cause an off- site impact because sediment accumulates at the bottom of the rolling dips. While redistribution of soil material on the landscape is not desirable, the impact must be balanced against the extra disturbance created by the addition of more rolling dips and the usability of the trail which may not be able to accommodate large equipment that may be required intermittently during the production phase of the project.

References Cited

Keller, G. and Sherar, J. 2003. Low-Volume Roads Engineering. USDA Forest Service a US Agency for International Development and Virginia Polytechnic Institute and State University, 172 p.

Poff, R.J. 2006. Rolling Dips for Drainage of OHV Trails. USDA-Forest Service, Pacific Southwest Region 8 p.

Wall, G.J., Coote, D.R., Pringle, E.A. and Shelton, I.J.; [Editor] 2002. RUSLEFAC Revised Universal Soil Loss Equation for Application in Canada: A Handbook for Estimating Soil Loss from Water Erosion in Canada. ECORC Contribution No. 02-92; AAFC Publication Number: AAFC/AAC2244E Research Branch, Agriculture and Agri-Food Canada, 117 p.

Reference: Volume 1. Appendix H. I-32. Sec 209.

Preamble: EnCana states “Site-specific conditions for grading and other increased disturbance MAY require topsoil stripping (in excess of 5x6 m)”. Request: GOC recommends that EnCana discuss where this will likely occur as well as the predicted change in the project footprint, biodiversity and cumulative impacts. Response: The most likely occurrence of an increase in stripping would be in the sandy soils. Due to soil stability and OH&S guidelines which requires slope stability on open excavations. Human safety is the number one priority in construction activities.

EnCana has considered the effects of topsoil stripping in the assessment of biodiversity and vegetation.

Reference: Volume 1, Appendix I ‘Environmental Protection Plan’, Section I.5.5, Page I-22

Preamble: Point #123. The proponent states “EnCana will in most cases avoid rare plants and will avoid where possible rare plant communities. If re-alignment is not possible then mitigation specific to the species or community will be implemented.”

Request: GOC recommends that EnCana explain the proposed mitigation measures for plant species at risk, and provide a substantiated probability and measure of confidence relating to the success of those mitigation measures. Make reference to the associated legislation to justify how mitigation will be approached.

Response: See the response to Terr 189a.

Reference: Volume 3.

Preamble:

Request: GOC recommends that EnCana provide justification on the selection of the regional and local study areas with respect to large mammals and their lifetime habitat requirements.

Response: The only large mammal selected as a Valued Ecosystem Component (VEC) was pronghorn antelope – a species listed as Sensitive by the Alberta government. Pronghorn primarily occupy the CFB Suffield and the NWA during the spring, summer and fall seasons. During winter they move to winter ranges generally to the south and east, portions of which occur immediately adjacent and along the edges of the CFB Suffield (Dillon Consulting 1998). The construction phase of the project largely occurs during winter (Oct 15 – Apr 15). The regional and local study areas encompass the majority of the range of pronghorn in the CFB Suffield (Dillon Consulting 1998). Major rivers are a natural (permeable) barrier to antelope movement during non-frozen conditions and as such the South Saskatchewan River was considered to be a suitable/natural eastern boundary for assessing Project impacts to this species.

Reference: Volume 3, Appendix 3E, Existing Disturbance Footprint Inventory – Detailed Methods and Results, Section 3E.2.3 Page 3E-4, 3E.4.1, page 3E-19 Volume 3, Table 3-1, page 3-19

Preamble: EnCana, in its methods sections for existing footprint describes measuring the width of features using a measuring tool in GIS as follows : “After a feature was digitized, its‘ feature type and width in meters (to within 1 m using the measure tool) was entered into the fields” (page 3E-4).

Request: 1. Further methodological details on measuring linear features (Appendix 3E, Section 3E.2.3, page 3E-4). 2. Describe how polygon boundaries were recognized in the field. 3. Provide minimum, maximum, and variance for all means and relative values in Appendix 3E, Tables 3E-3 and 3E-4, pages 3E-30 and 3E-31. 4. Compare widths for the same feature/location as determined by the GIS measurement tool and ground measures. Provide mean, minimum, maximum, and variance for the difference.

Response: 1. The methods in Table 3E-1 represent the approach followed. EnCana cannot add further details. 2. Polygon boundaries were measured in the field based on visually notable differences in vegetation type and ground disturbance (i.e. bare ground) attributable to physical disturbance of soils. 3. Please see response to Terrestrial 225 for width and area measurement statistics for linear and polygonal footprint features digitized in the GIS. 4. Mean width values for roads, trails and pipeline features based on field measurements are provided in Volume 3, Appendix 3E, Tables 3E-4 and 3E-5. Please refer to ‘mean total feature width’ as the best comparison to digitized width.

Reference: Volume 3, Appendix 3E, Section 3E.3.1, page 3E-15 Volume 3, Section 2, Page 2-10, Section 3, Page 3-9, Section 4, page 4-9, Section 7, page 7-11 Volume 3, Section 7.3.2, page 7-4

Preamble: The methods sections of Sections 2, 3, 4, and 7 all refer to Appendix 3E for detailed methods on how the existing disturbance footprint was calculated. EnCana identifies (Appendix 3E, Section 3E.3.1, page 3E-15) the three dominant land uses in the EIA study areas are military training, shallow gas development and livestock grazing. They occur in various combinations depending on geographic location. Volume 3, Section 7.3.2, page 7-4) EnCana identifies the majority (90% +/-) of this footprint is associated with past shallow gas activities. Approximately 10% (+/-) of the total is attributable to livestock grazing (dugouts and single track trails).

Request: GOC recommends that EnCana describe how the source of the disturbance was assigned to each feature as its size was determined. Response: With the exception of the reference to an approximate 90%/10% split (see the response to Terrestrial 114) between shallow gas and cattle grazing in the NWA the footprint calculations did not contrast relative contribution of oil and gas, military and livestock grazing to disturbance in the RSA. This was not possible to do accurately using this method because of difficulties separating double track trails associated with military training from double track trails associated with oil and gas activities.

Reference: Volume 1, Concordance Table, Page 5-20

Preamble: EnCana states in EIS Volume 1 in the Concordance Table, Page 5-20 under 5.: “N/A - 100m setback from S. Sask. River slope break”.

Request: GOC recommends that EnCana expand consideration of slope instability beyond well sites, to include all other infrastructure and development-related activities (e.g., access roads). Include in this slope instability assessment not just location (above and below) with respect to canyons and coulee walls, but also locations near pre-existing landslides in the area, and any potential for reactivation of pre-existing landslides. GOC recommends that EnCana undertake slope- stability analyses in order to identify slope gradients and areas unsuitable for development and provide the location of any slumps/landslides within the study area. Assess slope stability near well sites, and all other infrastructure and development-related activities (e.g., access roads).

Response: As part of EnCana’s Pre Disturbance Assessments (PDA’s) for each location and its related infrastructure, slope breaks and any associated soil losses will be considered.

EnCana will always maintain a 100m setback from the South Saskatchewan River for construction activities aside from water extraction.

EnCana does not believe that additional work to study slope stability is required for the scope of the project due to the setback distance limiting potential issues with slumping and landslides.

Reference: Volume 1, Concordance Table, Page 5-19; and Volume 4 Section 2.7, Pages 2-6 to 2-24, Volume 4 Appendix 2B Description of the Glacial History pertaining to the RSA/LSA Preamble: EnCana’s reference in the EIS Concordance Table, Page 19, fourth bullet under 4. suggests that the characterization of the sediments infilling the pre-glacial valleys is addressed in EIS Volume 4 Section 2.7, pages 2-6 to 2-24. However, neither this section referred to, nor elsewhere in the EIS contains any practical information on the “nature of sediments” infilling the preglacial valleys. The information that has been distilled from the available literature is largely conjectural, such as in EIS Volume 4 Appendix 2B, page 2B-3, where EnCana states: “As the glaciers advanced, fluvial deposits of permeable sand and gravel were deposited in river valleys in front of the glaciers. These sand and gravel deposits form the lower sand and gravel aquifer within the preglacial valley, which is the highest yielding aquifer in the RSA.”.

Request: GOC recommends that EnCana supplement the description of the extent and character of both the Lethbridge and Medicine Hat preglacial valleys by additional analyses, including a determination of the character of sediments and the geographical bounds of the buried channels, in order to properly “determine the potential for contaminant dispersal through the aquifer.” Use analysis of drill core samples and logs, and ground resistivity logging.

Response: EnCana refers the GOC to Figure 2A-1 Bedrock Topography and Incised Channels and the Figures 2A-2 to 2A-5, Geological Cross Sections A-A’ to D-D’ which immediately precede Appendix 2B Page 2B-1. The cross sections provide a legend showing the nature of the sediments infilling the pre-glacial valleys. The map shows the geographical bounds of the buried channels. The references and source materials are listed on the map and cross sections.

A map published by Alberta Geological Survey and titled “Bedrock Topography of the Medicine Hat Map-Area NTS 72L, Alberta” is available through the EUB web site and will assist the GOC in its understanding of the area’s glacial history. A copy of this map is provided below. EnCana believes that the EIS adequately discusses the extent and character of the preglacial valleys in so much as they pertain to the Shallow Gas Infill Development Project in the NWA and that additional analyses are not required.

Reference: Volume 1 Section 2.1 Reservoir Characteristics, Section 2.2 Project Phases, Section 2.8.1 Drilling and Completion Techniques, Section 3.3 Surficial and Subsurface Geology, and Section 5 Concordance Table; Volume 1 Appendices - Appendix B Regional Shallow Gas Reservoir Map and Appendix C Stratigraphic Column; and, Volume 4 Appendices - Appendix 2A Description of the Geologic History.

Preamble:

Request: GOC recommends that EnCana provide an isopach, surface contour map, porosity variation map, permeability distribution map and net pay map for each of the three gas- reservoir units: Second White Speckled Shale; Medicine Hat Sandstone; and Milk River Formation, to help evaluate the regional reservoir variability and viability across the two gas development areas.

Response: Reservoir variability within each formation is demonstrated by the core logs and photos shown below for the Second White Speckled Shale, the Medicine Hat Sandstone and the Milk River formations. The formations all have overall low permeability with variation both vertically and horizontally and consist of interlaminated shales and siltstones with the occasional fine grained sandstone.

EnCana wishes to note that for these formations, the maps requested by are of limited value in determining the recoverable resource potential. The performance of the infill pilot programs are the primary basis for expected recoveries, rather than geological mapping. For this reason companies such as EnCana have been developing gas in these formations for more than 30 years relying on pilot projects and production analysis as the primary methodology for determining the recoverable resource potential.

Preamble: GOC recommends that EnCana provide an isopach, and permeability maps for the two shale barrier units, the Upper Colorado Shale Formation, and First White Speckled Shale Formation, and for the Pakowki/Lea Park Formation to help evaluate the regional seal integrity of these permeability barriers.

Request:

Response: All three shale formations, the Colorado Shales, the First White Specks and the Pakowki are regionally extensive and thick enough to provide for complete regional seal integrity as demonstrated by the approximately 9000 wells in Suffield and 1145 wells presently in the NWA. EnCana does not believe further mapping is required to demonstrate this.

Detailed maps, cross-sections and discussion of the First White Speckled Shale and the Pakowki/Lea Park formations can be found in Chapter 20 (Cretaceous Colorado / Alberta Group of the Western Canada Sedimentary Basin) of The Geological Atlas of Western Canada Sedimentary Basin published by Alberta Geological Survey (ISBN 0920230539). At this time, EnCana is not in a position to provide copies of these maps as copyright laws require EnCana to first obtain the approval of the Government of Alberta. EnCana will seek such approval and, if granted, will provide copies of these maps to the Panel.

Reference: Volume 3, Section 2.1, Page 2-1, Page 2-20, Section 2.8.2.1, Page 2-27, Section 2.8.2.2, Page 2-30 Preamble: EnCana has identified a number of erosion, salinization, and contamination sensitive soils as Valued Ecosystem Components (VECs). However, EnCana also states that “Pipeline and well site construction, and traffic on access routes during construction could cause exposure of bare ground and reduction of protective vegetative cover, resulting in loss of topsoil or underlying soil material due to wind erosion…[and] compaction caused by excess traffic can increase overland flow… [and] can promote water erosion in channels or gullies”.

Request: GOC recommends that EnCana explain the rationale for the selection of soil VECs, and explain the absence of soil organic content and soil bulk density as VECs. Response: The soil-related VECs are based on all of the Soil Landscape Models (SLMs) described in the 1:50,000 Soil Survey of CFB Suffield. The rationale is provided within the “Risk Rating for SLMs” component of Volume 3, Section 2.6 (Methods). A complete list of all risk ratings for each SLM is provided in Volume 3, Appendix 2A. Each Soil Landscape Model represents a unique assemblage of: • soil series (a category used to describe soil classification and parent material based on soil properties) and • soil landscape model (based on recognizable slope characteristics and landscape pattern).

The request infers that soil organic matter content and bulk density are absent. However, soil properties are described at the soil series level in the Alberta Soil Series Database and in published soil survey reports. Bulk density and soil organic matter content are two important soil properties but were considered by the study team to be inappropriate candidates to be considered as VEC’s for this Project.

Reference: Volume 3, Section 2.1, Page 2-1

Preamble: EnCana states that “12 soil landscape groupings represent unique landscape features with varying degrees of sensitivity to soil related effects from shallow gas activity. The Majority of Other Soil Landscapes (group 13) is also valuable and requires normal practices for mitigation….The soil-related valued ecological components (VECs) are those soils that are sensitive to wind erosion, water erosion, soil salinization and subsurface soil contamination”

However, group 13 is composed of a group of loamy soils with moderate and high slopes, which are also highly susceptible to soil erosion.

Request: GOC recommends that EnCana explain why fine-textured loamy soils with moderate and highly-sloped landscape features were not considered.

Response: Loamy soils with moderate and high slopes are not highly susceptible to soil erosion except in cases where there is negligible vegetative cover. The project description involves minimal soil disturbance, and therefore loamy soils were not rated as sensitive (high to extreme risk for wind or water erosion). Fine textured soils on moderate and high slopes are sensitive to water erosion, but loamy soils are not fine textured.

Reference: Volume 3, Section 2.1, Page 2-2

Preamble: EnCana states that “Landscapes very sensitive to wind erosion include Choppy Sandhills where slopes exceed 15 percent, wetlands, channel crossing, dune crossings and southwest and west facing slopes that are more prone to aridity. Landscapes very sensitive to water erosion include those with steep or long slopes and low soil permeability….A vehicle access plan will be implemented, including access management to avoid out-of-bounds areas”

Request: It is unclear whether disturbance to these features will be completely avoided or minimized for mitigation of soil resources. GOC recommends that EnCana clarify the definition of out-of-bounds areas, and further, produce a map indicating what areas will be identified as out-of-bounds. Secondly, GOC recommends that EnCana present the proposed vehicle access management plan. GOC requests a copy of the access plan in order to fully understand any potential impacts to the ecosystem, both individually and cumulatively.

Response: Out of bound areas and access routes will be determined on a site by site basis and therefore maps cannot be provided at this time. EnCana embarks on a lengthy planning process in advance of determining final locations. See section 2.2.1 of Volume 1 for a description of the preconstruction activities.

Reference: Volume 3, Section 2.1, Page 2-2

Preamble: EnCana states that “Setback distances around wetlands, watercourses and surface water will be adhered to in accordance with the Environmental Protection Plan (EPP). EnCana will cooperate with DND in improving existing wetland inventories and mapping products.”

Request: GOC recommends that EnCana identify how it will define, identify, and map wetlands, and how setback distances will be employed as mitigation. Response: To define wetlands, EnCana utilizes the definition of a water body provided by the Alberta Water Act: “any location where water flows or is present, whether or not the flow or presence of water is continuous, intermittent or occurs only during a flood…”. EnCana selects the appropriate classification system based on the region and project area, such as Stewart and Kantrud (1971) for glaciated prairie regions.

In the event that wetlands occur within or near 100 m from the proposed development, the wetland is photographed and its distance and direction from the proposed development recorded using a GPS unit. The wetland is then classified based on its species composition and further wetland characteristics such as soil texture, salinity, high water mark definition, topography and abundance of wetland indicator species. In addition, a comprehensive vegetation species list is produced for Stewart and Kantrud (1971) Class 2 or higher wetlands.

In accordance with recommendations from ASRD, EnCana endeavors to maintain a 100 m setback from all wetlands. However, where resource extraction would be severely compromised and/or effects on the environment would be more adverse if the buffer was maintained due to additional factors (e.g., topography, species of concern, existing disturbance, etc.), EnCana may increase or decrease the 100 m setback. The setback distance will never be reduced below 15 m. EnCana has assessed the effects of the Project on wetlands in Volume 3, Section 4.8.

Reference: Volume 3. Section 2.7.1 1) Choppy Sandhills

Preamble: EIS notes that there are problems with past installations “several soil degradation problems were identified”. Request: GOC recommends that EnCana provide details of the degradation problems and discuss mitigation measures. Response: Soil degradation problems in Choppy Sandhills may be associated with occasional trails or pipelines on slopes that are greater than 15% and cross dunes. Mitigative measures such as avoidance of slopes greater than 15% and the application of appropriate reclamation measures are provided in the Environmental Protection Plan, in Appendix 1 of Volume 1.

Reference: Volume 3. Section 2.7.2. Fig. 2.2

Preamble:

Request: GOC recommends that EnCana provide justification as to why soils with a medium rating are not shown within Figure 2.2, as this would provide a more accurate representation of the actual conditions.

Response: The low and medium ratings are not shown, as each of the four figures (Figures 2.2 to 2.5) show soil landscapes that are sensitive to the four identified VECs (wind erosion, water erosion, salinization, and subsurface contamination). Soil landscapes with high and extreme ratings are classified as sensitive (VECs). The risks for each Soil Landscape Model in the 1:50,000 soil survey of CFB Suffield are identified in Table 2A-1 of Appendix 2A.

Reference: Volume 3. Section 2.7

Preamble:

Request: GOC recommends that EnCana provide justification for the use of such a small sample size for use in modeling the predicted changes to surface disturbance.

Response: Please see Volume 3, Sections 2.6 and 2.7 for a discussion of methods and existing conditions for soils.

Although no modeling was completed in Volume 3, Section 2 (soils), modeling was completed to develop a spatial footprint (disturbance) map. The methodology for this is contained in Volume 3, Appendix 3F.

Reference: Volume 3, Section 2.7, Page 2-11, Section 2.7.1, Page 2-13

Preamble: EnCana states that “Soil capability and quality are generally good in the LSA at present, but soil degradation has occurred in site-specific locations within some SLMs mapped in the 2003 soil survey”. Secondly, EnCana states that “Several soil degradation problems were identified during the 2006 field investigation at locations with existing gas infrastructure in the Choppy Sandhills Soil Landscape Feature. Problems were most apparent along pipeline corridors or access routes where slopes exceed 15 percent, and included wind erosion focal points and trails with erosion scars or deflation hollows.”

Request: GOC recommends that EnCana describe the nature and extent of soil degradation as a result of existing shallow gas development by soil landscape feature, and explain how mitigation has been employed, and the success of such mitigation, in relation to proposed mitigation.

Response: This information request cannot be specifically addressed to the level of detail asked for. The nature of soil degradation has not been categorized by soil landscape feature in the detailed requested. Based on existing footprint disturbance of 0.9% to 4.7% (mean = 1.8%) of soil landscape features have been effected by past land use (shallow gas and cattle). In the Choppy Sandhills, existing surface footprint is <1%.

Within Volume 3, Section 2, regional and local soils issues are discussed including the impacts of past shallow infill gas activities on the soil landscape features within the NWA. The literature noted in Section 2.6, Volume 3, page 2-9 provides information on past soil degradation in the NWA and CFB Suffield.

Reference: Volume 3, Section 2.8.1, Page 2-26

Preamble: EnCana suggests that it complies with applicable legislation and standard, including EUB Information Letter (IL) 2002-01, which provides recommendations for minimizing environmental impacts in native prairie.

Request: GOC recommends that EnCana define what the specific applicable regulations and standards are, and further state how it will comply with guidelines which are not enforceable by regulators.

Response: Please see EnCana’s response to Terr 55 for a discussion of the applicable legislation and standards. Please also see EnCana’s response to Gen 11 and Terr 129 for a discussion of EnCana’s legal commitments in respect of reclamation. EnCana’s commitments made in the EIS, including the Environmental Protection Plan (“EPP,” a draft version of which is presented in Appendix I of the EIS) and IL 2002-01, will form conditions of the Project, if approved, and the permits issued by the Alberta Energy and Utilities Board and the Department of National Defence will be subject to any such conditions. Compliance with these standards will be continually assessed and adaptively managed in accordance with the Environmental Effects Monitoring Plan (“EEMP”).

Reference: Volume 3, Section 2.8.2.1, Page 2-28

Preamble: EnCana states that “key mitigation measures include the selection of access routes on the basis of access requirements and environmental sensitivity.”

Request: GOC recommends that EnCana specify how access requirements and environmental sensitivities are defined, as well as the associated weights assigned during decision making.

Response: Access requirements refers to the type of vehicles that will be utilizing the access route and how often the vehicles will utilize the route. For example, in some circumstances, it may be more appropriate to have a different route for operational vehicles which are smaller than construction vehicles. Access routes are carefully selected to minimize the disturbance to the native prairie including preventing soil erosion. Part of selecting a wellsite is determining the access route. The same criteria are utilized for determining the access routes as for determining wellsites (please see the response to Terr 96).

Reference: Volume 3, Section 2.10, Page 2-41

Preamble: EnCana states “It is recommended that periodic monitoring be conducted to: identify incidents of wind or water erosion in sensitive areas, assess the effectiveness of mitigation, and identify the need for additional or amended mitigation measures; assess pipeline and access route conditions, and to regularly assess changes in the extent or area of soil salinization; identify any other areas of concern with respect to soil degradation.”

Request: GOC recommends that EnCana describe the specific monitoring procedures, methods, and assessment protocols, and the frequency in which they will be employed, in support of the statement above.

Response: Please see the response to Terr 17.

Soil erosion is one of the candidate program components. The process described in Volume 1, Section 4.7.1 will guide the final selection of the specific components and elements of the program.

Reference: Volume 3, Section 2.7.4, Page 2-25 and Volume 3, Appendix 2-A, Page 2A-1 to 2A- 6 Preamble: EnCana states in EIS Volume 3, Section 2.7.4, Page 2-25 that “For each [Soil Landscape Model] SLM, the risk of wind and water erosion, soil salinization, and subsurface contamination was rated as Low, Moderate, High or Extreme. These ratings, grouped by Soil Landscape Feature, are provided in Appendix 2-A. Appendix 2-A also includes an overall risk rating for each SLM.”

Request: GOC recommends that EnCana clarify how the overall risk before mitigation rating in Volume 3 Appendix 2A was objectively determined. Response: The risk ratings for wind erosion, water erosion, soil salinization and subsurface contamination are based on a five-level rating of Negligible, Low, Moderate, High and Extreme. The overall risk before mitigation combines the four risk ratings into a simplified three-level rating using only Low, Moderate and High. This is because there are no Soil Landscape Models (SLM) or soil landscape features (SLF) that have a combined risk of negligible or a combined risk of extreme. It is impossible to have negligible or extreme risks for all four types of degradation within the same SLM. For example, a site with an extreme subsurface contamination risk can also have an extreme risk for wind erosion, but due to the extreme leaching potential, it will have negligible potential for water erosion and soil salinization.

The overall risk before mitigation is based on a combination of the risk rating that is applied for each of the four factors. For example, the SLM CVD6/U1H has a high potential for wind erosion and subsurface contamination. The same SLM has a low potential for water erosion, and a low potential for soil salinity. The overall risk for this SLM is rated as High.

Reference: Volume 3, Section 2.8.1, Page 2-26

Preamble: EnCana states in EIS Volume 3, Section 2.8.1, Page 2-26, that “the Project will be developed using minimal disturbance (above-ground) well sites, spider ploughing of tie-ins during dry, non-frozen ground conditions (October 1 to April 15), and for the trenching of loop pipelines.”

Request: GOC recommends that EnCana clarify the period during which spider ploughing is viable given that October 1 to April 15 includes a considerable time period during which ground conditions are typically frozen.

Response: EnCana is capable of plowing in all pipelines in non-frozen conditions. The project calls for approximately 400 wells per year for 3 years. 8-10 wells can be completed on a daily basis, so EnCana will require approximately 50 days in the appropriate “weather window” to complete the plowing. Provided that military templates and weather do not reduce the window below 50 days, EnCana will be able to plow in non-frozen conditions. Also see answer to AWA 93.

Reference: Volume 3, Section 2.8.2.1, Page 2-27 to 2-28

Preamble: EnCana states in EIS Volume 3, Section 2.8.2.1, Page 2-27 to 28, that “Project planning and construction …will include mitigation measures to reduce wind erosion of soils due to the Project.”

Request: GOC recommends that EnCana clarify the timing of use of access routes to reduce wind erosion of soils, in the context of weather conditions, including wet weather and soil conditions and dry conditions.

Response: The use of access routes will be subject to wet weather or extreme weather shut down. Details of this can be found in the EPP, Volume 1, Appendix I, Section 5.1.

Reference: Volume 3, Section 2.8.2.1, Page 2-29, Table 2-6

Preamble: EnCana provides in EIS Volume 3, Section 2.8.2.1, Page 2-29, Table 2-6 showing Residual Environmental Effects on Soils Sensitive to Wind Erosion. Request: GOC recommends that EnCana clarify how the significance varies for soils that have low, moderate, high, and extreme sensitivity to wind erosion and, in particular, clarify significance with respect to soils with extreme sensitivity to wind erosion.

Response: The EnCana Project Description (Volume 1) emphasizes minimal soil disturbance. Soil disturbance on well locations will only occur at the bellhole, and pipelines will be largely constructed through the use of soil-preserving equipment such as a spider plow. Therefore, vegetative cover is largely retained and the integrity and properties of the topsoil remain intact. Soil disturbances represent extremely small areas. Residual environmental impacts on soils sensitive to wind erosion are insignificant.

Reference: Volume 3, Section 3.1, Page 3-1

Preamble: EnCana states that “Rare plant species and rare ecological communities and uncommon vegetation cover types will be avoided whenever feasible.”

Request: GOC recommends that EnCana: 1. Explain in detail how these plant and plant communities will be detected prior to the commencement of the Project; 2. Define the concept of feasibility as it applies to the above statement; 3. Explain how it will avoid disturbing or destroying individuals or critical habitat for those species identified under Schedule 1 of the federal Species at Risk Act; 4. Specify how the proposed mitigation for each Species at Risk assessed is consistent with the Species at Risk Act (SARA) and National Wildlife Area Regulations; 5. Specify a schedule for the return of habitat capability to areas impacted by the Project; 6. Assess the impacts where avoidance is not possible; and 7. Specify the proposed mitigation where avoidance is not possible, and its assess its effectiveness.

Response: 1. Rare Plant Survey Methodology Rare plant surveys will utilize a methodology based on the rare plant survey guidelines developed by the Alberta Native Plant Council (ANPC)1. The area surveyed will be the deemed lease area for wellsites, the right-of-way (ROW) for pipelines and access routes. Additionally, if a rare plant community is observed, then the extent of community is determined either with a ground search or via Landsat or Spot5 imaging. Rare plant surveys will be conducted during the growing season from May 15 to September 15.

Each plant will be investigated for its preferred habitat using existing information sources (Hitchock and Cronquist 2001, Moss 1996 and Parker and Bradley 1984). Once habitat information is gathered, each ecosystem will be assessed for its potential to support each rare plant. The total number of rare plants that potentially occur in each ecosystem will then be determined.

The survey will use a combination of meander and patterned searches. The ecosystem types will be rated for rare plant habitat suitability or potential. The ranking system for

1 Available at: http://www.anpc.ab.ca/assets/rareplant.pdf 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-012 2 #Terr – 189a-B

rare plants adapted from the Alberta Native Plant Council will be used. Plants will be ranked based on morphology, lifecycle and habitat. Particular emphasis will be placed on locating tiny cryptanthe (Cryptantha minima). In CFB Suffield, tiny cryptanthe is typically found in native mixed grasslands with moderate relief and exposed soil (Alberta Sustainable Resource Development 2004). The presence of vegetation including Pursh’s plantain will also be used as another indicator for areas where tiny cryptanthe occurs (Alberta Sustainable Resource Development 2004).

Based on the rare plant habitat survey, ecosystem types will be ranked according to their ability to support rare plant species. Five categories of rare plant habitat suitability will be derived from a frequency histogram that correlated each ecosystem type with the number of rare plants that might potentially be found within them. The five categories are very low, low, moderate, high, and very high habitat potential.

A rare plant potential is assigned to each plant community type based on field observations and on a literature review. Native prairie and wetlands are given higher ratings than disturbed sites because prairie and wetlands characteristically provide rare plant habitat while disturbed areas do not typically provide habitat suitable for rare plants. Although this method is subjective, it does provide a basis to rank ecosystems for their potential to support rare plants.

Whereas an ecosystem type may be ranked very low for rare plant habitat, there is a possibility that rare plants could be found in microsites within individual stands the ecosystem type.

In the event that rare plant species are observed, a thorough search will be done to determine the extent and status of the population. Rare plant populations, if present, are estimated and mapped, a GPS location is recorded, photographs are taken and a detailed ANHIC rare plant report form will be completed and submitted to ANHIC.

Refer also to the draft EPP, Volume 1, Appendix I, Section I.5.5.

2. EnCana will avoid identified rare plants and rare plant communities except in exceptional circumstances where resource extraction would be severely compromised and/or effects on the environment would be more adverse if the rare plant was avoided.

3. Pursuant to the draft EPP (located in Appendix I of Volume 1), EnCana will identify and locate rare plant and plant communities. These locations will be provided on environmental alignment sheets. The locations will be clearly marked if it is appropriate in the circumstances. 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-012 3 #Terr – 189a-B

4. EnCana’s primary strategy is to comply with the SARA and the NWA regulations and avoid rare plants. All wellsites will avoid rare plants. In the event that avoidance during pipelining is not possible of a listed species, EnCana will apply for a permit under the SARA. EnCana’s primary mitigation measure will be to construct pipelines in dormant conditions so the disturbance is minimized. See the attached decision-making process.

5. No specific schedule for the return of habitat capability was assumed. This will differ depending on site conditions. The results of empirical assessments (e.g. breeding bird surveys, vegetation triangle surveys) reflect the past recovery timing. See Section 3.6 of Volume 3.

6. Avoidance will occur in the vast majority of cases. In the rare instances that avoidance is not possible, specific measures will be taken to minimize the effects. EnCana has assessed the environmental effects of the Project on rare plants in Volume 3, Section 3.7.

7. See answer to point #4.

GO No nups & Yes factor? Are spill Are incidents a Mitigation (EPP, s. I.4) (EPP, Spill Clea Spill SUCCESSFUL MITIGATION SUCCESSFUL No Yes Is soil soil Is factor? erosion a (EPP, s.I.5.3) Erosion Controls Yes No dry or Are the frozen? conditions Yes STOP No Is it a routes) pipeline? Yes (ie.wells, access access (ie.wells, Yes m No 10 RARE PLANTS (including species of value to First Nations) First to value of species (including PLANTS RARE Setback Setback (Fence Off) distance inside

Setback Distance 10 of 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-012 1 #Terr - 200 - A

Reference: Volume 3, Section 3.7.1, page 3-20

Preamble: EnCana states that “the planning of specific wellsites and access routes will include vegetation considerations with a focus on: avoiding uncommon communities with a higher density of existing disturbance whenever possible; and avoiding known occurrences of rare plant species and rare ecological communities whenever possible.”

Request: GOC recommends that Encana: 1. define the term “whenever possible”, and the factors assessed in its determination; 2. describe in detail how it will avoid occurrences of rare plant species in areas where rare, threatened or endangered species may exist, but have not been historically surveyed; 3. assess the impacts where avoidance is not possible; and 4. specify the proposed mitigation where avoidance is not possible, and its assess its effectiveness;

Response: 1. See the response to Terr 189a. 2. See the response to Terr 189a. 3. The effects of the Project on rare plants and ecological communities was assessed as negligible including the potential of not avoiding them in exceptional circumstances. See Volume 3, Section 3.7.2.3 for details. 4. See the response to Terr 189a.

Reference: Volume 3, Section 3.7.2.1, page 3-23

Preamble: EnCana states that “Key mitigation measures include: Constraints-based pre-planning of the proposed well and pipeline layout that largely avoid sites that are the most sensitive to effects on native plant integrity”.

Request: GOC recommends that EnCana: 1. define the term “largely avoid” and identify those sites most sensitive to effects on native plant integrity; 2. assess the impacts where buffer distances may be reduced; and 3. specify the proposed mitigation where buffer distances may be reduced, and its assess its effectiveness.

Response: 1. See the response to Terr 189a and 200. 2. EnCana has considered the potential effects of Project including the effects of not avoiding all sensitive environments (i.e. rare plant communities and uncommon vegetation types). EnCana has predicted negligible environmental effects on rare plant and ecological communities, and uncommon vegetation cover types. See Volume 3, Section 3.7. 3. See the response to Terr 189a.

Reference: Volume 3. Section 3.7.2. Pg. 3.22

Preamble:

Request: GOC recommends that EnCana explain and justify for the comparison of 8 to 16 well per section and not to the baseline of 4 or 0 wells per section. Response: Please see the response to Terr 111.

Reference: Volume 3, Section 3.7.2.1, Table 3-4, page 3-25

Preamble: EnCana considers the de-commissioning and reclamation phases as having a negative impact on native prairie grassland integrity. Request: GOC recommends that EnCana clarify and explain how reclamation activities have negative impacts on grassland integrity. GOC recommends that EnCana provide information on historical reclamation success, including measurement standards and criteria, and the degree of reclamation success with respect to grassland integrity and biodiversity

Response: EnCana considers the decommissioning and abandonment phases as having a temporary negative impact on native prairie grassland integrity because removing existing infrastructure will create a ground disturbance that will reduce ecological function for a time. Reclamation follows after the decommissioning and abandonment activities. EnCana regards reclamation as a progression of assisted natural processes toward a stated goal and ecological function may be somewhat reduced from that goal during the recovery period after decommissioning and abandonment phase.

Examples of historical reclamation success including measurement standards and criteria and degree of success are provided in Volume 3, Appendix 3. Appendix 3 provides a detailed methodology and the results of the status of 22 measures of native prairie grassland integrity on pipelines/wells (and adjacent control areas) at varying ages since construction. This data shows that pipelines constructed in the 1980s showed a much higher level of recovery toward a native condition than 1970s pipelines/wells that were seeded with crested wheatgrass and 1990s and 2000s pipelines/wells that were not seeded with crested wheatgrass. The comment regarding ‘near native condition’ is supported by the finding that there were no statistically significant differences (between treatments and controls) for 17 of the 22 measures of native integrity for the 1980s samples.

Reference: Volume 3, Section 3.7.2.1, Table 3-4 & 3-5 & 3-6, page 3-25/27/29

Preamble: EnCana considers construction, operation, decommissioning and reclamation in assessing environmental effects. Request: GOC recommends that EnCana consider all other phases of development, including maintenance activities such as snowblading/grading to allow for Winter access, re- swabbing, re-fracturing, and water disposal for wells producing water, in assessing effects on soils sensitive to erosion.

Response: ‘Maintenance activities’ such as swabbing (produced water disposal) and re-fracturing are considered to be part of the Operations phase and maintaining vehicular access to wells and facilities are inherently part of such activities. Volume 1, Section 2.2.3 of the Environmental Impact Statement details on the activities of the operations phase including swabbing and re-fracturing.

Reference: Volume 3, Section 3.9, page 3-30, Appendix H, Pages H-3/4

Preamble: EnCana states that “monitoring will occur before construction and then after construction until targets for successful vegetation recovery has been reached (see Conceptual Reclamation Plan Volume 1, Appendix H)…If monitoring does not result in successful recovery within 10 years then restoration procedures will be taken”. EnCana further states “The reclamation plan has also been designed with recognition of multiple societal values including soil, water and air quality, biodiversity and aesthetics…Implicit in this approach is the recognition that the restoration of specific plant communities may not be desired or even possible at some sites because of the permanent (on a human time scale) loss of soil and/or genetic resources and the invasion and/or expansion of other species….This perspective also frees reclamation based on the principles of ecological restoration from the deBASes or what represents the “pre-disturbance” or, in some cases, the “pre-settlement” plant community that are associated with the word “restoration.”

Request: GOC recommends that EnCana: 1. Specify the definition of reclamation success and how it will be measured, in relation to the conservation of native dry mixed grass prairie vegetation and pre-disturbance states, with particular focus on biological capability, diversity, and end land-use objectives appropriate for a National Wildlife Area; 2. Identify how rare plant species, communities, and species at risk will be reclaimed, in relation to pre-disturbance states and species/genetic-level conservation; 3. Specify what restoration actions will be carried out if monitoring does not result in successful recovery in 10 years; and 4. Explain the results of pre-development rangeland health assessment using Range/Pasture Health Assessment (Alberta Rangeland Health Task Group, 2000) in assessing pre-disturbance and post reclamation rangeland capability and the return of equivalent capability.

Response: 1. EnCana’s obligation is to reclaim to equivalent land capability pursuant to the 1975 Access Agreement. In Alberta, reclamation success is defined in the Environmental Protection and Enhancement Act as achieving “equivalent capability”. This is defined as: “The ability of the land to support various land uses after reclamation is similar to the ability that existed prior to any activity being conducted on the land, but the ability to support individual land uses will not necessarily be equal after reclamation.”

2. Rare plants and plant communities and species at risk will be avoided as much as 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-012 2 #Terr - 214 - A

possible. In cases where avoidance is impossible, specific mitigation strategies will be implemented, see the response to Terr 189a.

3. EnCana has not completed a final reclamation plan that will detail the actions necessary to obtain a reclamation certificate. Final details of the Environmental Effects Monitoring Plan (EEMP) have yet to be determined. EnCana will provide further details regarding its proposal for appropriate monitoring at the forthcoming hearing; further, the EEMP will be developed based on direction from the Joint Review Panel.

4. The Rangeland Health Assessment will determine whether the site is on a trajectory to meet the goal of equivalent land capability. This is assessed in three categories: site stability, watershed function and biotic integrity.

Reference: Volume 3, Appendix 3J, Page 3J-9

Preamble: EnCana states that “No additional focused rare plant searches were conducted during the baseline phase of this EIS…It was not feasible to define the precise routing of each well and associated pipeline in the planning stage. Rare plant searches need to be done in the areas that will be directed affects (i.e., surveyed pipeline routes)”.

Request: GOC recommends that EnCana: 1. discuss the accuracy, currentness, and completeness of the information it has obtained from government agencies including ANHIC, regarding rare plants and plant communities, and Species at Risk; 2. advise on the effectiveness and accuracy of the assessment of Project-related effects on rare plants and plant communities, and plant Species at Risk VECs, given that the locations of well sites and associated pipelines have not been precisely defined, in light of the precautionary principle; 3. discuss the effectiveness and accuracy of the assessment of Project-related effects on rare plants and plant communities, and plant Species at Risk VECs, given that the location, population and spatial extent information of these of these species may be incomplete and/or out-of-date, in light of the precautionary principle; 4. describe the proposed activities will affect the conservation of wildlife, pursuant to the National Wildlife Area Regulations and the Species at Risk Act and in the context of the mandate of the National Wildlife Area; and 5. describe the regional significance of those units and the anticipated effects, where rare plant communities may be removed by the project or fragmented by the disturbance footprint.

Response: 1. The locational data used for constraints mapping was, to the best of EnCana’s knowledge, accurate and current. The Alberta Natural Heritage Information Centre (ANHIC), one of over 80 centres in an international Natural Heritage Network, was established in 1996. The ANHIC provides accurate and accessible biodiversity information necessary for making informed decisions concerning conservation, natural resource management, and development planning. The ANHIC collects, continually updates, analyzes and disseminates information about the location, condition, status, and trends of selected elements, including species and plant communities. Locational data concerning rare elements was also obtained from the DND for constraints mapping purposes (see Volume 3, Appendix 3F, Section 3F.2.4.9). 2. The location of rare plants will be identified during surveys as part of the PDA 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-012 2 #Terr - 215 - A

process. Impacts will then be mitigated primarily through avoidance, therefore the level of confidence in the assessment is high. 3. The spirit of the Species at Risk Act (SARA), Migratory Birds Convention Act (MBCA) and the Canadian Biodiversity Strategy is the preservation of wildlife and biodiversity in Canada (the “Legislation”). The avoidance of rare species is an objective that is consistent with the spirit of the Legislation. EnCana’s process for siting wellsites, pipelines and access routes focuses on avoiding rare species. In the event that a rare species is located, the PDA process will determine appropriate mitigation measures and site locations. 4. It is unclear which units are referred to in this question. 5. The locations of rare plants do not need to be known as the mitigation is known. EnCana will be avoiding rare plant locations in the siting of access routes and wells. Pipelines will avoid rare plants, aside from exceptional circumstances. Based on well established mitigation and avoidance, EnCana has a high level of confidence in the EIS assessment.

Reference: Volume 3, Section 3, Vegetation

Preamble: The proponent makes multiple references to the current distribution of crested wheat grass and other exotic and invasive species. Crested wheat grass is distributed along roads and pipelines as well as at pipeline junctions, and other facilities in the NWA.

Request: GOC recommends that EnCana provide justification for not measuring the magnitude of invasion by sampling perpendicular to existing roads, trails, and pipelines to measure how crested wheatgrass and other non-native species spread.

The GOC recommends that EnCana describe how the proponent proposes to address the current distribution of weeds and exotic species in terms of containment, removal, and restoration of native prairie areas that are impacted by these species.

Response: EnCana takes the position that a study measuring the magnitude of invasion of crested wheatgrass and other non-native species in order to measure how they spread is a question better suited to academic research. A considerable body of relevant research has been published; some examples are listed below.

The current distribution of weeds and exotic species in the NWA is the result of over a century of human impact beginning in the 1900's with cattle grazing (Anderson [1941] reports herds sizes of 10,000 animals in the Medicine Hat area), agricultural cultivation in the 1930's (Adams and others [1997] report 129 ha of remnant stands of crested wheatgrass inside the NWA), heavy cattle stocking rates in the 1970's (Adams and others 1997), intensive horse grazing during the 1980's (Weerstra 1996), and oil and gas activities from 1970 to present.

EnCana acknowledges the advice that a well-planned and well-executed Integrated Weed Management Program is required for removal and restoration of native prairie areas impacted by weeds and exotic species (US National Park Service 1998, Sheley and Marks 2002, Masters and Sheley 2004, Jacobs and others 1998, Bakker and Wilson 2004). To be effective, all land users must cooperate in the program. An integral part of such a program is a comprehensive cost-benefit analysis study (US National Park Service 1998).

EnCana has described specific measures in the Conceptual Reclamation Plan (Volume 1, Appendix H) and the Draft Environmental Protection Plan (Volume 1, Appendix I) to minimize the introduction and seed dispersal of undesirable species on disturbances created by the project. Some of the measures include (1) dormant season construction, 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-012 2 #Terr - 221 - A

(2) cleaned construction equipment, (3) use of revegetation seed that is free of undesirable species, (4) Pre-construction Assessments (PDAs) (5) prompt revegetation, where re-seeding is occurring, (6) monitoring and prompt action to suppress the growth and reproduction of undesirable species, and (7) Environmental Monitoring.

References Cited

Ambrose, L.G. and Wilson, S.D. 2003. Emergence of the Introduced Grass Agropyron cristatum and the Native Grass Bouteloua gracilis in a Mixed-Grass Prairie Restoration. Restoration Ecology. 11(1):440-116.

Anderson, C.G. 1941. Grazing Rate Report: Short Grass Area of Alberta. Compiled with the co-operation of the Short Grass Stock Growers' Association of Medicine Hat. Department of Lands and Mines, Province of Alberta 237 p.

Bakker, J.D. and Wilson, S.D. 2004. Using ecological restoration to constrain biological invasion. Journal of Applied Ecology. 41:1058-1064.

Henderson, D.C. and Naeth, M.A. 2005. Multi-scale impacts of crested wheatgrass invasion in mixed-grass prairie. Biological Invasions. 7(4):639-650.

Jacobs, J.S., Carpinelli, M.F. and Sheley, R.L. 1998. Revegetating weed-infested rangeland: What we've learned. Rangelands. 20(6):10-15.

Keane, R.M. and Crawley, M.J. 2002. Exotic Plant Invasions and the Enemy Release Hypothesis. Trends in Ecological Evolution. 17(4):164-169.

Masters, R.A. and Sheley, R.L. 2004. Principles and practices for managing rangeland invasive plants. Journal of Range Management. 54(5):502-517.

McClay, A.S., Fry, K.M., Korpela, E.J., Lange, R.M. and Roy, L.D. 2004. Costs and Threats of Invasive Species to Alberta's Natural Resources. Alberta Research Council 0-7785-2957-6.

Sheley, R., Manoukian, M. and Marks, G. 1996. Preventing noxious weed invasion. Rangelands. 18(3):100-101.

US National Park Service. 1998. Exotic Species. US National Park Service. Accessed Jan 22, 2001. http://www1.nature.nps.gov/wv/texotics.htm

USDA-NRCS. 2000. Plant Guide Crested Wheatgrass. The PLANTS Database, United States Department of Agriculture, Natural Resource Conservation Service, National Plant Data Center, Baton Rouge LA accessed on 06May 24 at http://plant- materials.nrcs.usda.gov/

Weerstra, B.G. 1996. Range condition evaluation following feral horse removal, Canadian Forces Base Suffield. Prepared for Department of National Defense by Biota Consultants, Cochrane, AB. 75pp + appendices and maps.

Wilson, S.D. and Partel, M. 2003. Extirpation or Coexistence? Management of a Persistent Introduced Grass in a Prairie Restoration. Restoration Ecology. 11(4):410- 416.

Reference: Volume 1, Section 2.2.2, Construction, page 2-16 Volume 3, Section 3.7.2.1, Native Prairie Grassland Integrity, pages 3-23, 3-24, and Section 3.7.2.2, page 3-26

Preamble: EnCana states (Vol. 1, page 2-16) with regard to the construction phase: “EnCana will contractually require that all equipment will arrive in a clean condition (i.e., free of weeds) to minimize the risk of weed introduction, and will be in good working condition to minimize emissions and noise.” Clean condition is also cited without definition of equipment or specificity of location in Volume 3, Section 3.7.2.1 and 3.7.2.2.

Request: GOC recommends that EnCana provide: 1. A description of cleaning as mitigation for weeds, non-native plants and invasive species in pre-construction, operations, maintenance, decommissioning and clean-up phases. 2. Specifically address whether it includes or excludes vehicles of all types and sizes. 3. Clarify what facilities will be established to clean equipment. 4. Clarification of where the equipment will be required contractually to arrive in clean condition.

Response: 1. Cleaning as mitigation for weeds, non-native plants and invasive species, and the reference in the preamble to a “clean condition” means that vehicles will be cleaned of all mud, soils and debris for all project phases. Please see the response to Terr 108. 2. It includes vehicles of all types without exception. 3. Equipment will be cleaned at existing facilities outside of the Base (contractors’ shops or a public wash facility). In addition, the equipment coming from Medicine Hat or Brooks will travel via highway or gravel road, thus the probability of weed contamination is remote. 4. The equipment will be required to arrive at the Bingville gate in clean condition.

Reference: Volume 1, Section 2.2.2, Construction, page 2-16 Volume 3, Section 3.7.2.1, Native Prairie Grassland Integrity, pages 3-23, 3-24, and Section 3.7.2.2, page 3-26

Request: GOC recommends that EnCana provide: 5. References and justifications that demonstrate that cleaning will minimize the risk of introductions of weeds and non-native and invasive plants. 6. Specifically address the mechanical movement of weed (crested wheat grass) seed in the NWA from introduced sources in the NWA.

Response: Vehicle cleanliness is first the responsibility of the operator of the vehicle and will be part of the bid package for all contracts. Cleaning equipment (all vehicles) of mud and vegetation prior to entering the Suffield block and NWA and prior to moving from contaminated sources to uncontaminated areas within the NWA will minimize the spread of seed and rhizomes of undesirable plants (e.g., weeds designated under the Weed Control Act and problem forage plants like crested wheatgrass) to areas where they are not already present (AENV a and b).

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.

Further detail is outlined in the Undesirable Vegetation Control During Construction section of the EPP (Vol. 1, Section I.5.9, pg I-26) and the Operations and Maintenance section of the EPP (Vol. 1, Section I.6.11, pg I-42).

References Cited and Supporting

Native Plant Working Group. 2001. Native Plant Revegetation Guidelines for Alberta. H. Sinton-Gerling (ed.), Alberta Agriculture, Food and Rural Development and Alberta Environment. Edmonton, Alberta. 58 pp.

Alberta Environment. 2003a. Weed Awareness for Reclamation. http://environment.gov.ab.ca/info/library/6886.pdf

Alberta Environment. 2003b. Weeds on Industrial Development Sites. R&R/03-4. 5 pp.

Reference: Volume 3, Section 3.7.2.1 Native Prairie Grassland Integrity: Preliminary Project Footprint, Page 3-23 Volume 3, Section 2.6, Soils, Methods: Effects Analysis, page 2-11 Volume 3, Appendix 3D, Paired Pipeline Sampling - Detailed Methods and Results, Tables 3D-2 (page 3D-11), 3D-3 (page 3D-19), Table 3D-4 (page 3D-27) Volume 3, Appendix 3E, Existing Disturbance Footprint Inventory - Methods and Results, Tables 3E-3 and 3E-4, page 3E-30

Preamble: EnCana states (page 3-23) “Based on the 4.5 and 12-m widths the incremental footprint of pipelines for the three-year drilling period would amount to 0.4% of the total land area of the NWA respectively.

EnCana will utilize aboveground well sites which will result in a disturbance footprint of approximately 30 m2 per well. Well-related footprint will affect <0.01% of the NWA, based on land area. Total footprint associated with combined wells and pipelines constructed over the three-year time period will amount to <0.5% of the land area of each of the NWA.”

EnCana states (page 2-11) “The maximum extent of surface disturbance was assumed to be a 4.5m width for spider ploughing laterals and a 12 m width for trenching loop lines. These disturbance areas encompass equipment working space and include the physical effects on soils and traffic during construction (and operations).” The parameters used for estimating size is not provided for all features.

Elsewhere (Appendix E) EnCana provides a limited description of project footprint calculation. A reference is made to well pads being 10 m sq. Elsewhere in the EIS EnCana makes reference to 30 m sq well pad.

Request: GOC recommends that EnCana provide: 1. The means, variance, minimum and maximum extent in the above noted Tables; 2. A description of how Project habitat loss (footprint) was calculated. 3. Clarify whether indirect losses and loss of habitat effectiveness were included in the footprint.

Response: 1. The widths of linear features (4.5m-tie-ins and 12-m loop lines) and the area of wells (30 m2) used to estimate project footprint were based on expert opinion from construction specialists within EnCana. For the linear features the widths were based on working space and equipment sizes and include more than the 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-012 2 #Terr - 225 - A

trench width or ‘roach’ resulting from plowing. Subsequent measurements of linear features in the field during the fall of 2006 (see Appendix 3E-3, 3E-4 and 3E-5) indicated that these estimates were accurate. Standard deviations for measurements are provided below. 2. Please refer to Volume 3, Section 3.7.2.1, pages 3-22 and 3-23 and Volume 3, Appendix 3L for detailed discussion of the methods and results of project footprint assessment. Appendix 3L (page 3L-6) provides assumptions associated with assigned Project feature widths. 3. The footprint only takes into account direct effects within the working space. Habitat effectiveness was not taken into account for this assessment.

Mea Mean Mean Mean Mean n Mean Mean Mean Pipeli Mean Inter- Inter- Sam Mean Total RG ROW ROW Feature Total ne Trail Trail Pipe- Feature Type ple Slop SD SD Feature SD SD SD SD SD R SD 1 SD 2 SD Type Code Area Widt Width Widt Trail Size e (%) Width Widt Widt Widt (m2) h (m) h Widt (m) h h (m) h (m) (m) (m) h (m) (m) 368. LS lease 38 2.2 1.9 860.1 ------9 PL pipeline 16 4.4 1.5 - - 2.9 1.4 2.9 1.4 ------PLJ pipeline junction 3 2.1 1.7 404.5 25.3 ------PL+DT pipeline + double track trail 36 4 2.2 - - 5.8 2.2 1.3 0.7 0.7 0.2 1.2 0.7 1.9 1.6 ------PL+ST pipeline + single track trail 1 4 0 - - 3.9 0.3 1 0.1 0.5 0.2 - - 2.5 0.4 ------RGR raised gravel road 6 2.5 2.7 - - 20.5 2.1 ------8.3 1 6 1 6.2 1.3 TDT-TR trail double track - truck 27 3.7 2.1 - - 2.5 0.4 - - 0.6 0.2 1.3 0.2 ------TDT-TA trail double track - tank 14 4.3 1.9 - - 3.6 0.5 - - 1.1 0.3 1.4 0.4 ------TST trail single track 7 5.6 3.2 - - 0.42 0.2 - - 0.42 0.2 ------

Mea n Mean Mean Mean Mean Bar Mean Mean % Bare Mean Inter- Sam Mean Bare Bare e Bare Feature Bare Soil - Bare Trail Feature Type ple Slop SD SD Soil on SD SD SD SD Soil - SD Soil SD Soil - SD Type Code Soil - Pipeli Soil - Bare Size e (%) Feature RGR - ROW Control ne Trail (%) Soil (%) (%) RO 2 (%) (%) (%) W1 (%) LS lease 38 2.2 1.9 11 14.9 26.2 27 ------PL pipeline 16 4.4 1.5 16.1 21.6 31.4 28.5 PLJ pipeline junction 3 2.1 1.7 41.5 36.8 44.9 37.6 ------PL+DT pipeline + double track trail 36 4 2.2 7.1 9.5 - - 22.2 24.5 46.2 30.9 17.7 20.7 ------PL+ST pipeline + single track trail 1 4 0 1.7 1.9 - - 5.8 7.8 3.3 3.5 ------33. RGR raised gravel road 6 2.5 2.7 12.3 16.1 ------99.8 0.4 25.2 23.4 25.2 1 TDT-TR trail double track - truck 27 3.7 2.1 9.1 14.4 44.1 33.1 - - 44.1 33.1 14.6 21.3 ------TDT-TA trail double track - tank 14 4.3 1.9 20.4 23.5 45.1 32.7 - - 45.1 32.7 19.2 19.4 ------TST trail single track 7 5.6 3.2 7.8 6.7 34.1 32.1 - - 34.1 32.1 ------

Table A. Mean area and percent cover for bare soil on leases and pipeline junctions.

Mean Relative Amount of Feature Mean Mean % Mean % Relative Increase in % Feature Sample Total Bare Soil as Type Slope SD SD Bare Soil SD Bare Soil SD Cover Bare Soil Relative to Type Size Area Compared to Code (%) 2 Control Feature Control (m ) Control 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-012 4 #Terr - 225 - A

LS lease 38 2.2 1.9 860.1 368.9 11 14.9 26.2 27 2.4 15.2 pipeline PLJ 3 2.1 1.7 404.5 25.3 41.5 36.8 44.9 37.6 1.1 3.4 junction

Table B. Mean width and percent cover for bare soil on pipelines and pipelines with trails. Feature Type Code PL PL+DT PL+ST Feature Type pipeline pipeline + double track trail pipeline + single track trail Sample Size 16 36 1 Mean Slope (%) 4.4 4 4 SD 1.5 2.2 0 Mean Total Feature Width (m) - 5.8 3.9 SD - 2.2 0.3 Mean Pipeline Width (m) 2.9 1.3 1 SD 1.4 0.7 0.1 Mean Trail Width (m) - 0.7 0.5 SD - 0.2 0.2 Mean Inter-Trail Width (m) - 1.2 - SD - 0.7 - Mean Inter-Pipe-Trail Width (m) - 1.9 2.5 SD - 1.6 1.4 Mean % Bare Soil - Control 16.1 7.1 1.7 SD 21.6 9.5 1.9 Mean Bare Soil on Feature (%) 31.4 - - SD 28.5 - - Mean Bare Soil - Pipeline (%) - 22.2 5.8 SD - 24.5 7.8 Mean Bare Soil - Trail (%) - 46.2 3.3 SD - 30.9 3.5 Mean Inter-Trail Bare Soil (%) - 17.7 - SD - 20.7 - Weighted Average of % Bare Soil on Feature 31.40 25.59 3.00 Relative Amount of Bare Soil as Compared to Control 1.95 3.60 1.76 Relative Increase in % Cover Bare Soil Relative to Control 15.30 18.49 1.30

Table C. Mean width and percent cover of bare soil for roads and trails. Feature Type Code RGR TDT-TR TDT-TA TDT-All TST raised gravel trail double track - trail double track trail double trail single Feature Type road truck - tank track - all track Sample Size 6 27 14 41 7 Mean Slope (%) 2.5 3.7 4.3 3.7 5.6 SD 2.7 2.1 1.9 3.2 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-012 5 #Terr - 225 - A

Mean Total Feature Width (m) 20.5 2.5 3.6 2.48 0.42 SD 2.1 0.4 0.5 0.2 Mean Trail Width (m) - 0.6 1.1 0.68 0.42 SD - 0.2 0.3 0.2 Mean Inter-Trail Width (m) - 1.3 1.4 1.18 - SD - 0.2 0.4 - Mean RGR Width (m) 8.3 - - - SD 1 - - - Mean ROW1 Width (m) 6 - - - SD 1 - - - Mean ROW2 Width (m) 6.2 - - - SD 1.3 - - - Mean % Bare Soil - Control 12.3 9.1 20.4 11.24 7.8 SD 16.1 14.4 23.5 6.7 Mean % Bare Soil - Trail - 44.1 45.1 38.18 34.1 SD - 33.1 32.7 32.1 Mean Inter-Trail Bare Soil (%) - 14.6 19.2 13.87 - SD - 21.3 19.4 - Mean Bare Soil - RGR (%) 99.8 - - - SD 0.4 - - - Mean Bare Soil - ROW1 (%) 33.1 - - - SD 25.2 - - - Mean Bare Soil - ROW2 (%) 23.4 - - - SD 25.2 - - -

Weighted Average of % Bare Soil on Feature 57.17 28.76 35.03 27.54 34.1

Relative Amount of Bare Soil as Compared to 4.65 3.16 1.72 2.45 4.37 Control Relative Increase in % Cover Bare Soil Relative to 44.87 19.66 14.63 16.30 26.3 Control

Table D. Comparitive Analysis of Ursus Field Investigation and Air Photo Investigations. PL PL+DT RGR TDT-TR TST L Feature pipeline + double track pipeline raised gravel road trail double track trail single track Lease Variable trail Ursus Air Photo Ursus Air Photo Ursus Air Photo Ursus Air Photo Ursus Air Photo Ursus Air Photo Sample Size 16 6046 36 6140 6 1468 41 30200 7 9098 38 3629 Mean Total Feature 2.90 3.08 5.80 3.64 8.30 7.15 2.48 3.41 0.42 2.05 860.1 469.50 Width/Area (m) Standard 1.40 1.68 2.20 1.43 1.00 2.02 0.40 1.21 0.20 1.54 368.9 0.09 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-012 6 #Terr - 225 - A

Deviation

Mean Total Mean Total Mean Mean % Bare Soil - Mean % Bare Soil - ID Easting Northing NAD Feature Type Width (m) Area (m2) Slope Feature Control R1 535742 5593057 83 pipeline junction 13.1 - 2 92.6 48.6 R1 535647 5593119 83 pipeline 3.6 - 2 86.4 58.6 R3 536340 5597152 83 lease - 1734.1 3 31 9 R4 536039 5596950 83 pipeline 5.3 - 4 12.4 17.1

Reference: Volume 3, Section 7.3.2. Past Land Actions in the NWA. Page 7-4

Preamble: The past land action of using exotic invasive species such as crested wheatgrass in reclamation was not discussed in this section. The invasion of these species off-site also represents an increased “footprint” that is not discussed in this EIS.

Request: 1. Measure or model the expanded existing and project footprint of disturbance created by exotic species invasions. Response: The extent to which crested wheatgrass (CWG) occurs currently in the NWA was measured as part of the vegetation triangle program (see Volume 3, Appendix 3C, page 3C-1). Homogeneous strips of CWG were also picked up during digitizing of older trunk and loop lines.

Reference: Volume 3, Section 7.5, Vegetation Cumulative Effects, Pages 7-14 to 7-23

Preamble:

Request: The GOC recommends that EnCana conduct a cumulative effects assessment using a multivariate model that can incorporate the interactions identified. Specifically assess the impact of crested wheatgrass invasion, and how this will interact with the proposed new developments, continued livestock grazing, soil or any other factors identified.

Response: The purpose of assessing cumulative effects is to provide information that allows the EIA practitioner to assess whether the incremental effects of the Project when added to past, present and planned/reasonably foreseeable land actions are likely to result in significant impacts on Valued Ecosystem Components. This can be done using modeling, empirical studies, or reference to analog studies. In Section 7.0 of Volume 3 EnCana assessed the magnitude and significance of the incremental and cumulative effects of the Project. A multi-variate modeling procedure would be less effective than the direct empirical approaches used in the EIS to assess additive and cumulative effects of in-fill drilling. Please refer to responses to Terrestrial 3 and Terrestrial 124 for a discussion of impacts of Crested Wheatgrass.

Reference: Volume 3, Appendix 3C, Vegetation Triangle Sampling Program, Section 3C.2.1, page 3C-3 , and Table 3C-1, page 3C-4, Volume 3, Section 5.6.3, Habitat Mapping, Page 5-10 Volume 3, Section 7.3.3, page 7-4 Volume 3, Section 6.8.2 Species Diversity (Biodiversity) relies on results from vegetation sampling.

Preamble: EnCana states in the methods of Vegetation Triangle Sampling that “Grazing intensity was described using data obtained from PFRA. This data provided the number of Animal Unit Months (AUM) of grazing for each of the pastures delineated in the NWA and Koomati for the period 1990 to 2005. Taking into account the land area of each pasture, grazing intensity was expressed as the number of acres per animal unit month. These values were rank-ordered bracketed and assigned values of low, moderate and high. Areas that were not grazed were also classified and mapped”. No assumptions or ecological justification or references to support them are provided.

EnCana also states “For the purposes of rating habitat suitability for wildlife VECs (Section 5.8) in the RSA, fire frequency and livestock grazing modifiers were attached to potential vegetation cover types to form habitat units…”. The modifiers provided are discontinuous and the range of values contained in classes range vary (2.9, 2.1, 14.4)

Elsewhere (Section 7.3.3, page 7-4) EnCana states “The Suffield Grazing Advisory Committee (SGAC) maintains annual cattle stocking rates at a level that sustains pasture quality.”

Request: GOC recommends that EnCana: 1. Provide clarification on what year(s) of stocking rates or non-grazing were used to assign the modifier. 2. Describe the method (rank order) of determining unequal break points used for grazing intensity. 3. Provide clarity for the two grazing categories “None” and “No Grazing” (Table 3C-1). 4. Provide a map showing grazing intensities.

Response: 1. Each of the potential vegetation cover types (e.g. Gu) was overlain onto maps of livestock stocking rates. Please see the chart and map below for stocking rate groupings and classes. 2. The stocking rate (AUM/acre) for 12 pastures were rank-ordered. There were natural breaks in the data as shown in the chart below. These were bracketed 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-012 2 #Terr - 229 - A

into three classes as per the chart below. 3. Grazing intensity = None for areas with no current grazing (i.e. large portions of MTA and LSA). Please see the map below. 4. Please see the map below.

Stocking All Data All Grazing Pasture Strata Years Years (AUM/Acre) (AUM/Acre) A1 Moderate 0.18 0.2 A1a Light 0.06 0.11 A1b Light 0.08 0.14 A1c High 0.21 0.23 A2 Moderate 0.17 0.21 A2a High 0.74 2.23 A2b High 0.26 0.59 B1 Light 0.08 0.13 B1a Light 0.04 0.1 B1b Moderate 0.16 0.18 C1 Moderate 0.15 0.16 C2 Moderate 0.16 0.17

** All other areas in and around NWA were assigned Stocking Strata of NONE

Reference: Volume 3, Appendix 3D Paired Pipeline Sampling, all Sections Volume 3, Section 6.8.2 Effects on Species Diversity relies on results from this and other methods to draw conclusions.

Preamble: EnCana states on page 3D-45 “Since approximately 1980 there appears to be a gradient in the level of recovery toward a more native condition with decreasing similarity in measured attributes between control and treatment plots with decreasing time since construction.”

Request: GOC recommends that EnCana substantiate the assertion that there is demonstrated recovery of native integrity on pipelines over time, taking into account: 1. Paired Pipeline surveys were attempted for only 3 of 8 Topographic Habitat Units that occur in the LSA/ RSA (limited stratification). 2. Results were not presented for the middle time period (1990 to 1999) in one or more of the Topographic Habitat Units in Appendix 3D Tables 3D-5, 3D-6 and 3D-7. 3. A number of indicators of native integrity remain different after almost 30 years (1980 to 1989). 4. Results presented in Tables throughout Appendix 3D do not include measures of variability (variance or maximum and minimum) or measures of statistical power.

Response: 1. Even though three of eight THUs were sampled, these three THUs are dominant and representative of the North-NWA (SD-1) and the South-NWA (UF3 and SD2). The three sampled THUs comprise 61 % of the NWA. SD-1 is the most abundant with 35 %, followed by UF-3 with 13.8% and SD-2 with 13.4% of the total NWA area.

2. Within the 1990-1999 period of time the oil and gas industry reduced its activities in the NWA, hence wells and pipelines from this period were very scarce.

3. Although a number of indicators remain different, well/pipelines constructed during the 1980–89 period showed the least difference in native integrity measures between well-pipeline and control samples. The majority (34 of 59) of best native integrity rankings (green cells) occur for this age-class especially in the UF-3 and SD-1 habitat types (Volume 3, Table 3D–6). The 1980–89 age-class also had the lowest number of poorest (red cells) native integrity rankings (3 of 59). The above mentioned clearly indicate higher levels of recovery toward native condition than other age classes.

4. Please see the table below (max and min values for paired pipeline sampling). The 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-012 2 #Terr - 237 - A

lack of need for power analysis is addressed in the response to Terrestrial 235.

Minimum and maximum values for pair ipeline sampling on THU UF-3 Attributes 73-79 (well- 73-79 (control) 80-89 (well- 80-89 (control) 90-99 (well- 90-99 (control) 00-05 (well- 00-05 (control) pipeline) pipeline) pipeline) pipeline) Min Max Min Max Min Max Min Max Min Max Min Max Min Max Min Max Bare soil (%) 4 80 0.5 10 0.5 34 0.5 15 2 90 0.5 19 0.5 70 0.5 26 Litter cover (%) 20 90 60 90 50 90 70 90 10 90 70 90 30 90 65 90 Litter depth (cm) 0.5 0.5 0.5 1 0.5 2 0.5 1 0.5 1 0.5 2 0.5 3 0.5 4 Native species cover (%) 2 17 37 97 18.5 49 18.5 55 11.5 52.5 32 74.5 9.5 72 29 94 Introduced species cover (%) 11 63 0 0 0 26 0 0 0 34.5 0 1 0 31 0 0

Minimum and maximum values for pair ipeline sampling on THU SD-1 Attributes 73-79 (well- 73-79 (control) 80-89 (well- 80-89 (control) 00-05 (well- 00-05 (control) pipeline) pipeline) pipeline) Min Max Min Max Min Max Min Max Min Max Min Max Bare soil (%) 0.5 80 0.5 30 0.5 35 0.5 30 0.5 80 0.5 35 Litter cover (%) 15 95 60 90 50 90 60 95 15 95 55 95 Litter depth (cm) 0.5 5 0.5 4 0.5 3 0.5 4 0.5 9 0.5 10 Native species cover (%) 5 99 30.5 91 13 100 21.5 99 9.5 100 22.5 100 Introduced species cover (%) 0 45 0 4.5 0 19 0 6.5 0 20 0 2

Minimum and maximum values for pair ipeline sampling on THU SD-2 Attributes 73-79 (well- 73-79 (control) 80-89 (well- 80-89 (control) 90-99 (well- 90-99 (control) 00-05 (well- 00-05 (control) pipeline) pipeline) pipeline) pipeline) Min Max Min Max Min Max Min Max Min Max Min Max Min Max Min Max Bare soil (%) 4 75 0.5 6 0.5 30 0.5 20 0.5 60 0.5 3 0.5 40 0.5 8 Litter cover (%) 20 90 85 90 60 95 70 95 40 90 85 90 60 90 20 90 Litter depth (cm) 0.5 1 0.5 2 0.5 4 0.5 6 0.5 3 0.5 4 0.5 1 0.5 1 Native species cover (%) 4.5 23.5 26.5 54.5 7 61 28.5 61 25 72 24 79.5 11.5 84.5 28 100 Introduced species cover (%) 8 25 0 0.5 0 21 0 3.5 0 55 0 0 0 50.5 0 0.5

Reference: Volume 3, Appendix 3J, Rare Plants Section 3J.1.3, Page 3J-9

Preamble: The proponent states that “detailed and seasonally appropriate rare plant searches will be conducted prior to the siting of each well location and associated pipeline. If rare plants are found then the well or pipeline location will be moved to avoid rare plants”.

The absence of any rare plant surveys does not allow conclusions to be drawn about impacts on rare plant species.

Request: GOC recommends that EnCana describe the impacts of the project on rare plants, including species at risk. Describe methodology for rare plant surveys. Response: Please see Section 3.7.2.3 of Volume 3 for the effects of the Project on rare plant species at risk. See the response to Terr 189a for the rare plant survey methodology.

Reference: Volume 3, Section 5.1

Preamble: EnCana assesses the effects of the Project on Species at Risk, including but not limited to Loggerhead Shrike, Sprague’s Pipit, Ferruginous Hawk, Burrowing Owl and Ord’s Kangaroo Rat.

Request: GOC recommends that EnCana: 1. Specify how the Project will affect the conservation of wildlife pursuant to the National Wildlife Area Regulations and National Wildlife Area Regulations. 2. Specify how the proposed mitigation for each Species at Risk assessed is consistent with the Species at Risk Act, Migratory Birds Convention Act, and National Wildlife Area Regulations. .

Response: See response to Terrestrial 189a.

Reference: Volume 3, Section 5.1

Preamble: EnCana assesses the effects of the Project on Species at Risk, including but not limited to Loggerhead Shrike, Sprague’s Pipit, Ferruginous Hawk, Burrowing Owl and Ord’s Kangaroo Rat.

Request: 1. Specify a schedule for the return of habitat capability to areas impacted by the Project Response: At this time, EnCana has not proposed a schedule for the reclamation process for the return of habitat capability to areas impacted by the Project. The final reclamation plan will be developed based on best available practices at the time and will address the issue of timing to a return to equivalent land capability status. Field studies have been conducted that are informative on the timing of recovery (See Volume 3, Section 3.6).

Reference: Volume 3, Section 5.8.1, Page 5-44

Preamble: EnCana states that “Potential for mortality due to collisions with vehicles exists. EnCana will minimize this potential by restricting speeds in the NWA to 70 kph from 15 October-15 April, 50 kph from 15 April to 15 October.”

Request: GOC recommends that EnCana specify the potential for wildlife mortality on access trails within the NWA, with reference to any existing scientific studies. GOC recommends that EnCana assess the probability of mortality on access trails, and how vehicle-related mortality on access trails will be mitigated.

Response: Vehicle speeds in the 50 to 70 kph range minimize animal-vehicle collisions. A comprehensive literature search was conducted for each wildlife VEC. Key findings with respect to mitigation and potential impacts including collisions with vehicles have been provided in Sections 5.8.2. and 5.8.3. Vehicle speed will be restricted to 70 kph from October 15 to April 15 and 50 kph from April 15 to October 15 in the high risk snake area.

As is discussed in section 5.8.3 of Volume 3, the Project is predicted to have negligible to insignificant effects on wildlife. The assessment of the effects of the Project on wildlife and wildlife habitat was made in the context of five major areas of conservation biology: direct habitat loss and alteration; sensory disturbance and effective habitat loss; habitat fragmentation; direction mortality; and, barriers to movement (see section 5.8.2). Therefore, wildlife mortality due to Project effects was evaluated for all phases of the Project.

EnCana has taken special precautions at Suffield to reduce snake mortality. For example, EnCana closed a road where snake mortality was known to occur. Further, in 2006, EnCana hired a snake researcher to monitor snake migration with the intention of attempting to reduce the effects of gas activities on snakes. Section 5.8.2 (pg 5-46) discusses the extensive mitigation measures to prevent snake mortality, particularly during the snake migration period.

Additionally, EnCana has committed to consulting with other stakeholders regarding snake mortality on Box Spring Road and consulting with the DND regarding snake mortality on CFB Suffield.

Reference: Volume 3, Section 5.8.2, Page 5-46

Preamble: EnCana states that “Pre-disturbance assessments will be undertaken to identify special habitat features (i.e., leks; hawk and appropriate buffer will be established as per the applicable criteria. Buffers may be reduced in exceptional circumstances where resource extraction would be severely compromised and/or effects on the environment would be more adverse if the buffer was adhered to.”

Request: GOC recommends that EnCana: 1. specify how it has documented baseline locations of lek, nest, den, breeding ponds, and hibernacula sites, including an assessment of the sampling intensity and coverage; 2. specify what other relevant policies, programs, and mandates apply to setbacks within the NWA and how they will be observed; 3. specify how it will obtain appropriate permits for disturbances to Species at Risk; 4. specify the conditions and criteria used to determine exceptional circumstances as they relate to the reduction in buffer sizes; 5. specify how the Project will affect the conservation of wildlife pursuant to the National Wildlife Area Regulations and National Wildlife Area Regulations;

Response: 1. See the response to NC 36.

2. See the responses to Gen 78 and Terr 78. The EUB has a 100m setback guideline for gas activities from water bodies (including wetlands) unless natural drainage is maintained and acceptable measures are implemented.

3. See the response to Terr 189a.

4. See the response to Gen 32 and AWA 34.

5. See the response to Terr 189a.

Reference: Volume 3, Section 5.8.2, Page 5-46

Request: GOC recommends that EnCana: 1. identify potential effects of the Project, and subsequent mitigation on all wildlife VECs where buffers may be reduced; 2. specify the proposed mitigation where buffer distances may be reduced, and assess its effectiveness; 3. specify whether it has received advice or input from provincial recovery teams with respect to mitigation measures and significance of residual environmental effects for Species at Risk. 4. specify how the proposed mitigation for each Species at Risk assessed is consistent with the Species at Risk Act, Migratory Birds Convention Act, and National Wildlife Area Regulations; and 5. specify a schedule for the return of habitat capability to areas impacted by the Project.

Response: 1.&2. Potential effects of the project are provided in Volume 3, Section 5.8. The proposed mitigation of the project on wildlife VECs has been provided in Section 5.8 and in the draft EPP (Volume 1, Appendix I).

3. EnCana has reviewed all relevant Provincial and Federal recovery strategies. EnCana has worked in the past and will be working with the members of recovery teams to determine appropriate mitigation measures.

4. The spirit of the Species at Risk Act (SARA), Migratory Birds Convention Act (MBCA), the Federal Policy on Wetland Conservation, and the Canadian Biodiversity Strategy, is the preservation of wildlife and biodiversity in Canada (the “Legislation”).

The avoidance of rare species is an objective that is consistent with the spirit of the Legislation. EnCana’s process for siting wellsites, pipelines and access routes focuses on avoiding rare species. In the event that a rare species is located, the PDA process will determine appropriate mitigation measures and site locations. 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-012 2 #Terr – 254b – A

5. At this time, EnCana has not proposed a schedule for the reclamation process. The final reclamation plan must consider timing as one factor in return of land to equivalent land capability status. Evidence of past reclamation timing is provided in Volume 3, Section 3.6.

Reference: Volume 3, Section 5.8.3.2, Page 5-48

Preamble: EnCana states that “Disturbance within 2 km of a lek during the breeding season (March through June) may be harmful [for Sharp-tailed Grouse]…A 500 m buffer from leks (Fish and Wildlife Division 2001) will be respected year-round whenever possible. This buffer may be reduced in exceptional circumstances where resource extraction would be severely compromised and effects on the environment would me more adverse if the buffer was adhered to.”

Request: GOC recommends that EnCana: 1. specify the criteria and thresholds which will be used in determining the possibility of respecting lek buffers; 2. assess the impacts to Sharp-tailed grouse conservation and reproduction where buffer distances may be reduced; 3. specify the proposed mitigation for Sharp-tailed grouse where buffer distances may be reduced, and its assess its effectiveness; 4. specify how the assessment of habitat loss includes individual lek locations; 5. specify how existing habitat fragmentation resulting from pipelines and access trails has affected Sharp-tailed grouse leks; and 6. specify how projected habitat fragmentation resulting from the Project will affect Sharp-tailed grouse conservation and reproduction.

Response: 1. Lek buffers will be respected except in exceptional circumstances where effects on the environment would me more adverse if the buffer was adhered to and resource recovery would be severely compromised. See the attached decision making process for Sharp-tailed Grouse.

2. Potential reduction of buffer distances has been considered in the project effects assessment for the Sharp-tailed Grouse. The project effects on Sharp-tailed Grouse are predicted to be insignificant. See Volume 3, Section 5.8.3.2.

3. See the attached decision making process for Sharp-tailed Grouse.

4. Habitat suitability rating and assessment is not intended to assess site specific habitat requirements of VECs. Site specific habitat requirements including leks will be identified during pre-disturbance assessments (PDAs) and appropriate mitigation and setbacks implemented.

5. EnCana has no information on how existing linear features (roads and major pipelines) have 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-012 2 #Terr – 255-B

impacted Sharp-tailed Grouse leks. A baseline assessment of Sharp-tailed Grouse habitat patch distribution is contained in Volume 3, Appendix 5I.

6. The Project is not predicted to result in fragmentation effects and therefore Sharp-tailed Grouse are not predicted to be effected by fragmentation as a result of the Project.

PROCEED criteria Successful Successful implementation of Yes Required Mitigation Site Specific SEAC Approval Consult specialist Consult No Develop siting Develop criteriaPDA's for March March access routes access (>100m setback) Construct pipelines Wells,loop lines and between 01 Nov to 15 betweenNov 01 Yes No Wait sensitive time Construct during non- Yes Yes STOP SHARP TAIL GROUSE (An example for the protection of a leking/breeding area) leking/breeding a of protection the for example (An GROUSE SHARP TAIL No Setback Setback Reduced Unable to SetbackDistance m 500 of reduce setback

Reference: Volume 3, Section 5.8.3.34, Page 5-99, Volume 3, Section 5.8.3.34, Table 5-39 Page 5-101

Preamble: EnCana states that “Anthropogenic habitats such as road sides and pipelines may act as population sinks…Kangaroo rats that use anthropogenic features have been shown to: (1) have lower survival rates and are prone to local (patch) extinctions, (2) experience higher rates of botfly parasitism and (3) have a significantly lower body mass index than kangaroo rats in more natural habitats…Additional factors include predators and vehicle traffic…Appropriate setback (Scobie and Faminow 2000 or its successor) from wildlife and habitat features will be respected year-round whenever possible. A buffer distance may be reduced in exceptional circumstances where resource extraction would be severely compromised and effects on the environment would be more adverse if the buffer was adhered to.” EnCana also suggests that the magnitude of environmental effects is low, level of confidence is high, and significance of effect is insignificant.

Request: GOC recommends that EnCana: 1. specify the types of wildlife and habitat features that will be buffered, and the buffer distance; 2. specify the criteria and thresholds which will be used in determining the possibility of respecting wildlife and habitat buffers, including the definition of exceptional circumstances; 3. assess the impacts wildlife and habitat features where buffer distances may be reduced; 4. specify the effect of fragmentation and changes to plant communities, and subsequent effects on Ord’s Kangaroo Rat habitat use, habitat quality, and population viability; 5. specify the proposed mitigation for wildlife and habitat features where buffer distances may be reduced, and its assess its effectiveness; 6. specify the assumptions and rationale to support the conclusions that the magnitude of environmental effects is low, level of confidence is high, and significance of effect is insignificant, given that Kangaroo rats that use anthropogenic features have been shown to: have lower survival rates and are prone to local (patch) extinctions, experience higher rates of botfly parasitism and have a significantly lower body mass index than kangaroo rats in more natural habitats, and are affected by predation and vehicle traffic; 7. specify how the Project will affect the conservation of wildlife pursuant to the National Wildlife Area Regulations and National Wildlife Area Regulations; 8. specify how the proposed mitigation for Ord’s Kangaroo Rat is consistent with the Species at Risk Act and National Wildlife Area Regulations; and 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-012 1 #Terr – 256-B

9. specify a schedule for the return of habitat capability to areas impacted by the Project.

Response: 1. As described in the draft Environmental Protection Plan (EPP) in Volume 1, Appendix I, Heading #133 and #137, a pre-disturbance assessment (PDA) will identify wildlife and wildlife habitat features, listed species, sensitive environments, wetlands, rare plants and communities, soils and historic/aboriginal resources requiring setbacks. PDAs will identify wildlife and habitat features such as residences, breeding areas, foraging areas such as burrows, dens, nests, wetlands, amphibian breeding ponds, grouse leks. Also, as discussed in the EPP under Heading # 134, appropriate setbacks (Scobie and Faminow 2001; Fish and Wildlife Division 2001) will be respected except under exceptional circumstances where resource extraction would be severely compromised and/or effects on the environment would be more adverse if the buffer was adhered to. 2. Whenever a species of wildlife or its habitat is encountered within the setback distance and there is no alternative location available, the appropriate decision-making process is utilized to determine whether the setback can be reduced. See the attached decision- making process for the Ord’s kangaroo rats. 3. The project effects on Ord’s kangaroo rats have been discussed in Volume 3, Section 5.8.3.34. 4. The potential project effects on wildlife and habitat were assessed within the context of five major conservation biology issues: direct habitat loss and alteration, sensory disturbance and effective habitat loss, habitat fragmentation, direct mortality, and barriers to movement. See Volume 3, Section 5.8.1 for details on the effects of fragmentation and habitat alteration. 5. See the attached decision-making process for the Ord’s kangaroo rats. EnCana is confident of the effectiveness of these mitigation measures as they have been utilized previously at CFB Suffield. 6. As discussed in Volume 3, Section 5.8.3.34, the conclusion of a low magnitude of effects and insignificant residual environmental effects assumes successful implementation of the mitigation measures outlined. EnCana’s previous experience with mitigation measures related to kangaroo rats suggests that the mitigation measures implemented for this Project will be successful in resulting in insignificant effects on kangaroo rats. 7. The conservation of Ord’s kangaroo rats will not be affected. Project impacts will not be significant given the negligible magnitude of Project footprint and mitigation measures proposed. 8. The spirit of the Species at Risk Act (SARA), Migratory Birds Convention Act 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-012 1 #Terr – 256-B

(MBCA) and the Canadian Biodiversity Strategy is the preservation of wildlife and biodiversity in Canada (the “Legislation”). The avoidance of rare species is an objective that is consistent with the spirit of the Legislation. EnCana’s process for siting wellsites, pipelines and access routes focuses on avoiding rare species. In the event that a rare species is located, the PDA process will determine appropriate mitigation measures and site locations. 9. See the response to Terr 254b, point #5.

PROCEED Yes No Monitor on site on Monitor SPECIALIST Daylight constructiononly CANCEL OR CONSULT OR CONSULT CANCEL loop line? loop Is it a Well or or Well it a Is Access Route? Access Is it a pipeline or Not Active Yes KANGAROO RAT RAT KANGAROO avoid Yes - - Yes active survey) WAIT (confirm by night - mark- burrows and instruct personnel to Are KRATS active (16 (16 active KRATS Are November to 31 March) 31 to November No 250 m less than Setback Distance Distance Setback

Setback Distance m 250 of 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-012 1 #Terr - 260 - A

Reference: Volume 3, Section 5.1, Project Effects Assessment, Page 5-3, Volume 3, Section 5.7.1.2, Fragmentation, Page 5-24, Volume 3, Appendix 5D Antelope RSF, Page 16

Preamble: In the Project Effects Assessment EnCana states “Fragmentation was not assessed for project effects” (Page 5-3). EnCana also states “Linear features used for fragmentation assessment were major pipelines (trunk lines) and raised gravel roads. Minor pipelines (individual well tie-in lines, loop lines) and access trails were deemed not to contribute to fragmentation”(Page 5-24). With regard to pronghorn (Appendix 5D) EnCana states “Roads and trails contribute directly and indirectly to habitat loss through habitat fragmentation, traffic, and introduction of exotic species (Berger et al., 2006).

Request: GOC recommends that EnCana: 1. Provide justification, for the assumptions that access trails, traffic, minor pipelines and other infrastructure and activities do not have a behavioural or reproductive effect on wildlife species. 2. Provide justification, for the assumptions that minor pipelines, access trails and other infrastructure and activities do not contribute to fragmentation on wildlife. 3. Provide justification for the exclusion of assessment of fragmentation effects on birds. 4. Include all roads, access trails, pipelines, loop junctions in the measure of fragmentation. 5. Conduct an assessment of project fragmentation effects for all Wildlife VECs.

Response: 1. An Access Management Plan for the Project will be developed once the locations are finalized and the distribution and volumes of traffic are further understood. Appropriate protection measures and any additional reclamation activities that may be required on existing trails will be assessed. General environmental protection measures for trails are outlined in Volume 1, Appendix I, Section I.5.2 – Traffic Control. 2. Please see the response to Terr 193. 3. Please see the response to Terr 193. 4. EnCana included major pipelines and roads in assessing baseline. Access trails and minor pipelines were deemed not to contribute to fragmentation. 5. Please see Volume 5, Section 5.7.1.2. Baseline habitat fragmentation analysis was done for those species listed on pages 5-25, however, project effects were not analyzed as the Project is not predicted to increase habitat fragmentation.

Reference: Volume 3, Section 5.8 Project Environmental Effects Assessment , Page 5-41

Preamble: The environmental effects of cattle guards and production shacks are not discussed.

Request: GOC recommends that EnCana discuss the potential environmental effects of cattle guards, production shacks and any other infrastructure not discussed in the application. Include the potential for the structures to provide perches for predators, and potential habitat sterilization/avoidance by wildlife.

Response: The number of “cattle guards, production shacks and other infrastructure” suitable as a hunting perch for a raptor resulting from the Project will be limited – EnCana currently does not generally use features such as “cattle guards” and “production shacks” in production operations on CFB Suffield and has no intention of changing this practice with the Project (See the response to Terr 89). A small number of shacks (less than 10 are expected) may be required for meters. Although such features are useful to sit-and-wait predators, the raptor species present in the NWA are either not primarily sit-and-wait predators or require a much higher perch than would be afforded by the infrastructure in question. During extensive field time in the MTA and NWA very few incidences of raptors using infrastructure were noted. The potential impact of raptors using infrastructure as hunting perches was considered implicitly in the impact assessment as a direct mortality consideration. EnCana knows of no compelling evidence in the literature that this potential impact could be significant for this Project.

Reference: Volume 3, Section 7.6.6, Page 7.28

Preamble: EnCana states “Vehicle collisions with wildlife, particularly snakes, were identified as a primary potential source of mortality (Section 5.6.1). A number of vehicle traffic mitigation measures were recommended to reduce this form of mortality. Project effects after mitigation were considered to be minor and insignificant. Increased formation level training and additional infill drilling in the MTA have potential to add to traffic volumes and increase cumulative snake mortality.”

Request: GOC recommends that EnCana justify and rationalize how project effects after mitigation were considered to be minor and insignificant on snake populations on the NWA and adjacent areas.

Response: Using appropriate mitigation (as described in 5.8.2), potential project effects on the regional snake population would be minor and insignificant. The majority of construction activity will be confined to the period October 15 to April 15 when the potential for snake mortality due to vehicles will be very small as snakes hibernate. Although pipeline construction is proposed during October 1-15, it will be confined to the western portion of the NWA where there is reduced potential for snake encounters. In addition, vehicle speed will be restricted to 70kph from October 15 to April 15, and 50kph from April 15 to October 15. Traffic volumes are not predicted to increase significantly, and both oil and gas and military activity to the west of the NWA have a lower potential to interact with snakes and are subject to all existing snake and other wildlife mitigation measures.

EnCana is confident that the mitigation will be effective as the mitigation measures are based on the mitigation measures undertaken by EnCana in the Spring/Summer of 2006 to reduce the effects of shallow gas development on snakes. Additionally, EnCana has committed to entering into discussions with other stakeholders to reduce the effects of traffic on snakes along Box Spring Road. EnCana is committed, as it has been since 1975, to working with all stakeholders in the area to ensure that the environment continues to be protected.

Reference: Volume 3, Section 4.8.2, Page 4-18

Preamble: EnCana assesses environmental effects during construction, operation, and decommissioning.

Request: GOC recommends that EnCana: 1. describe how reclamation activities, and any other project phase not considered, will affect wetlands; describe the environmental effects that have occurred as a result of disturbances to wetlands, and the measures that have been taken to mitigate or manage those effects, including an assessment of the degree to which those mitigation measures have been successful; 2. compare biodiversity at sites with existing oil and gas activities with undisturbed sites; 3. how reclamation will be carried out for those wetlands which are affected by the Project, including specific seed mixes, and define reclamation success for wetlands; 4. provide measures of biodiversity on baseline sites that are representative of the proposed reclamation; 5. indicate past reclamation experience for wetlands, including a comparison of the similarity in wetland function, health, and species composition to undisturbed wetlands; 6. provide species lists and summaries of observed and estimated species richness and evenness for wetland communities; and 7. rank each wetland type for biodiversity potential by combining measures of species richness, overlap in species lists, importance of individual species or association, uniqueness and other appropriate measures and describe the techniques used in the ranking process;

Response: 1. The findings of the supplemental wetland field study supports the EIS conclusion that the project will have negligible effects on wetlands. All Project phases were assessed in the assessment of wetlands. EnCana has predicted negligible effects due to the avoidance of wetlands and maintaining a 100m setback aside from in exceptional circumstances. Past disturbance footprint resulting from shallow gas activities in the NWA is minimal (<1.0% of available supply). Description of existing footprint on wetlands is provided in Volume 3, Section 4.7.2, page 4-1 and Appendix 4B. As is indicated by the minimal footprint, EnCana has been successful in avoiding wetlands, which is the primary mitigation measure. The 2007 wetland study by EnCana indicates that there is a high degree of similarity in terms of both species richness and 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-012 2 #Terr - 269 - B

percent cover as between on and off pipeline sampling.

2. The 2007 wetland study by EnCana measured floristic diversity (Simpson’s index) on and off of pipelines previously constructed in ephemeral, temporary and seasonal wetlands. For Class 1 and 2 wetlands (ephemeral and temporary on the Stewart and Kantrud 1971 classification system) floristic diversity was higher on than off pipelines for age classes 1970-79 and 2000-06. For age classes 1980-89 and 1990-99 floristic diversity was higher off pipelines than on. Floristic diversity index was higher on than off of pipelines for Class 3 wetlands (independent of age).

3. EnCana does not intend to construct pipelines within wetlands; however, may in exceptional circumstances work within the 100 meter setback around wetlands. In such instances, reclamation will utilize seed mix specifically designed for wetland margins such as the example provided in Appendix H, page H-39. EnCana will monitor the sites in the spring, summer and fall in the year following construction. EnCana follows the “no net loss” of wetlands policy of the Federal Government and will monitor to ensure that there is no loss of wetland function following reclamation.

4. Biodiversity measurements at past examples of active wetland reclamation are not available. Based on natural recovery expected Simpson’s accumulated index values of 11.5 to 13.3 are expected in Class 1 and 2 wetlands (see EnCana’s 2007 wetland study report).

5. No past examples of active reclamation in wetlands in the NWA are available as EnCana has previously utilized natural recovery.

6. Please see the wetland report for species richness measures and similarity indices for Class 1, 2 and 3 wetlands with and without pipeline construction in the MTA. Simpson’s diversity index in the wetland report indicates that invasive species have not caused native plant species loss in wetlands.

7. As described above, please see the wetland report for information on biodiversity found in wetlands with pipelines in the MTA. EnCana has not studied the effects of pipelining in class 4 or higher wetlands so has no information on those wetlands.

Supplemental Wetland Field Study - 2007

Environmental Impact Statement

EnCana Shallow Gas Infill Development in the Suffield National Wildlife Area

September 5, 2007

TABLE OF CONTENTS

Executive Summary

1.0 INTRODUCTION 1.1 Background 1.2 Objectives

2.0 METHODS

3.0 RESULTS 3.1 Bare Ground Cover 3.2 Vegetative Litter Cover and Depth 3.3 Native Plant Species Richness and Cover 3.4 Introduced Plant Species Richness and Cover 3.5 Weedy/Invasive Plant Species Richness and Cover 3.6 Vegetation Height 3.7 Plant Species Composition and Similarity 3.7.1 Plant Species Composition 3.7.2 Plant Species Similarity 3.8 Plant Biodiversity

4.0 SUMMARY AND CONCLUSIONS 4.1 Baseline Introduced Plant Species Abundance in Wetlands 4.2 Effects of Pipelines on Native Wetland Vegetation Integrity

5.0 LITERATURE CITED

FIGURES

Figure 1. Locations of wetland samples Figure 2. Sample layout schematic Figure 3. Mean bare ground % cover by age class- Cl. 1&2 wetlands Figure 4. Mean vegetative litter cover by age class – Cl. 1&2 wetlands Figure 5. Mean # of native plant species by age class- Cl. 1&2 wetlands Figure 6. Mean % cover of native plant species by age class – Cl. 1&2 wetlands Figure 7. Mean # of introduced plant species by age class – Cl. 1&2 wetlands Figure 8. Mean % cover of introduced plant species – Cl. 1&2 wetlands Figure 9. Mean # of weedy/invasive plant species – Cl. 1&2 wetlands Figure 10. Mean % cover of weedy/invasive plant species – Cl. 1&2 wetlands

TABLES

Table 1. Mean values for sampled attributes in Class 1&2 wetlands. Table 2. Mean values for sampled attributes in Class 3 wetlands. Table 3. Plant Species recorded on transects – 2006 Table 4. Importance values for dominant plant species in Cl. 1&2 wetlands Table 5. Plant species in Class 3 wetlands. Table 6. Sorenson's indices of similarity for plant species on and off pipelines Table 7. Simpson Diversity Index values

APPENDICES

Appendix 1. Statistical results for Class 1&2 Wetlands Appendix 2. Statistical Results for Class 3 Wetlands

EXECUTIVE SUMMARY

EnCana’s Environmental Impact Statement (EIS) for shallow gas infill development in the Suffield NWA addressed impacts of the Project on wetland supply and function. EnCana committed in the EIS to a supplemental wetland field study in the summer of 2007. The overall goal of this study was to quantify the effects of past and existing pipeline construction on wetland vegetation composition and structure.

Field sampling was conducted between July 3 and August 3, 2007. A total of 130 wetlands were sampled including Class 1&2 wetlands (Steward and Kantrud 1971 classifications) with existing pipelines; Class1&2 wetlands without pipeline; Class 3 wetlands with pipeline; and, Class 3 wetlands without pipeline. A paired pipeline transect method (parallel transects located on and off pipelines) was employed at the majority of sampling sites. An additional subset of transects was sampled in Class 1&2 and Class 3 wetlands that did not support any pipeline activity. For these ‘reference’ wetlands only one 25m transect (with 5 subplots) was sampled. All sampling was conducted in the Military Training Area (MTA) adjacent to the NWA. Originally EnCana was going to sample in the NWA; however, access in the form of a NWA permit was denied by the Department of National Defence (“DND”). This has unavoidably resulted in reduced sample sizes.

Data collected at samples included 18 measures of native vegetation integrity including: bare ground percent cover; litter percent cover and depth; native plant species richness and cover; introduced and weedy/invasive plant species richness and cover; vegetation height by layer (graminoid, forb, shrub); plant species composition/similarity; and, plant species biodiversity.

It was concluded that introduced species cover in Class 1&2 wetlands is generally higher than in uplands. It also was concluded that ambient weedy/invasive plant species cover in ephemeral and temporary wetlands is generally higher than in uplands, i.e., that weeds are less common in Class 1&2 wetlands than non-wetland areas.

Class 3 wetlands supported considerably less introduced and invasive/weedy species than Class 1& 2 wetlands, possibly because of more moist conditions.

The structure of vegetation in Class 1&2 and Class 3 wetlands, as measured by mean height of various layers, was not altered significantly by pipeline construction. The ground surface (as measured by bare ground cover, litter cover and depth) along pipelines in Class 1&2 wetlands was altered significantly for newer (2000-06) pipelines but less so for older pipelines. It was concluded that recovery (over time) was taking place for these measures in ephemeral and temporary ponds. The ground surface of Class 3 wetlands was not significantly altered by pipeline construction.

For Class 1&2 wetlands, introduced and weedy/invasive plant species richness and percent cover were higher on than off of pipelines. These differences were significant for introduced graminoid species (not for introduced forbs). Weedy/invasive species percent cover differences were statistically significant for two age classes (1970-79 and 1990-99). Pipelines constructed in Class 3 wetlands exhibited mixed results in terms of introduced and weedy/invasive plant species richness and mean percent cover. Generally these wetlands are less prone to weedy plant invasion, especially for graminoid weed species. Class 3 wetlands are less prone to weedy/invasive plants on pipelines than are Class 1&2 wetlands, likely because of higher soil moisture.

In spite of increased introduced and weedy/invasive plant species occurrence, native plant species richness and cover were not significantly affected by pipeline construction in Class 1&2 wetlands. The only statistically significant differences in native plant richness and cover between on and off paired transects was noted for the oldest pipelines, and only for graminoids. This likely reflects the past use of Crested Wheatgrass (Agropyron pectiniforme) as a reclamation species.

Sorenson’s index values (70% to 83%) indicate a high degree of similarity in plant species composition between transects located on and off pipelines for all age classes. Class 3 wetlands showed the greatest degree of similarity (species abundance and composition) between on and off pipeline samples as described by the Sorenson Quantitative Diversity Index.

Based on Simpson’s diversity index calculations, floristic diversity was both reduced and increased after pipeline construction depending on age class. Results for Class 3 wetlands indicated that pipeline construction increased floristic diversity but this increase was attributed to additional introduced plants. Native plant species loss in wetlands due to pipeline construction was considered to be unlikely.

During field studies it was noted that stands of Crested Wheatgrass (Agropyron pectiniforme) were most evident along pipelines when the micro-topography in wetlands had been modified during construction. This modification was in the form of a raised berm (‘roach’) that generated a drier environment that facilitated the establishment of this species. This occurred primarily along pipelines constructed in the 1970s and 1980s, and modern techniques may be designed to not leave a roach.

1.0 INTRODUCTION

1.1 Background

EnCana’s Environmental Impact Statement (EIS) for shallow gas infill development in the Suffield NWA addressed impacts of the Project on wetland supply and function (Volume 3, Section 4.0). EnCana committed in the EIS to a supplemental wetland field study in the summer of 2007. The overall goal of this study was to quantify the effects of past and existing pipeline construction on wetland vegetation composition and structure.

1.2 Objectives

Specific objectives of this study were:

• to quantify ambient (baseline) levels of introduced, weedy and invasive plant species in wetlands;

• to quantify the effects of past pipeline construction in wetlands on native vegetation composition/structure and substrate in wetlands;

• to measure differences in the effects of pipeline construction within different classes (Stewart and Kantrud 1971) of wetlands that reflect varying moisture levels; and,

• to understand the degree to which native wetland vegetation may recover from pipeline construction over time.

2.0 METHODS

All sampling was conducted in the Military Training Area (MTA) adjacent to the NWA. Originally EnCana was going to sample in the NWA; however, access in the form of a NWA permit was denied by the Department of National Defence (“DND”). This has unavoidably resulted in reduced sample sizes. Five broad sampling regions were located in areas of similar topography and soils that supported concentrations of wetlands (Figure 1). Sections (one square mile) of land within these regions were pre-selected and all pipeline access trails in each section were driven by truck. Sampling sites were then selected where pipelines were observed to cross wetlands. Transects were placed in wetlands that were classified as either Class1&2 or Class 3 (Stewart and Kantrud 1971). Class 1&2 samples represented the outer rings of wetlands characterized by wetland-low prairie and wet meadow vegetation. Class 3 samples were characterized by moister shallow marsh wetland conditions (Stewart and Kantrud 1971).

A paired pipeline transect method was employed at sampling sites. This method was similar to that reported for sampling pipeline/lease construction effects on upland native vegetation in the EIS (Volume 3, Appendix 3D). The approach sampled two parallel 25m transects, one located on the pipeline and the other off the pipeline. The ‘off-pipeline transect’ was 10 meters from the on-pipeline transect and was located in the same meso-topography and vegetation community. Each transect had five 1m2 plots and five 5m2 plots (Figure 2). The smaller plots were used to quantify bare ground cover, litter cover, litter depth, vegetation height (graminoids, forbs, and shrubs), and percent cover of individual plant species. The larger plots were used to quantify weedy/invasive species percent cover using Daubenmire cover classes.

Sampling of Class 1&2 wetlands was stratified by pipeline age. Samples were grouped into four main age classes including pipelines constructed between 1970- 1979, 1980-1989, 1990-1999, and 2000-20006. There were not a sufficient number of pipeline crossings in Class 3 wetlands to allow stratification by pipeline age because Class 3 wetlands were likely more deliberately avoided than were ephemeral wetlands during construction over the past three decades. An additional subset of transects was sampled in Class 1&2 and Class 3 wetlands that did not support any pipeline activity. For these ‘reference’ wetlands only one 25m transect (with 5 subplots) was sampled. Reference samples were collected from wetlands that were in as close proximity to affected wetlands as possible.

The Wilcoxon signed rank statistic was used to test differences between the ranked means of measured variables on and off pipelines. Statistical comparisons between reference areas and wetlands with pipelines were not conducted because of ad-hoc selection of reference samples and potential for highly variable environmental effects in reference areas versus wetlands with pipelines (e.g. fire history, military activity).

Figure 1. Locations of wetland samples in the CFB Military Training Area.

Figure 2. Wetland sampling methods

Floristic inventory plot 2 m • Percent cover of all

species present m

5 • Percent cover of bare .

0 ground and litter. •Litter depth •Graminoids, forbs, and shrubs height 5 m Invasive and weedy plants species plot •Daubenmire cover class for invasive and weedy species

5 m • Local landform •Landform element •Slope and aspect •GPS location (starting and ending point

2 m

1m 1m

Pipeline midline Note: Another 25 m transect “Off pipeline” was done parallel to the pipeline and trying to maintain a minimum 10 m distance for the paired sampling.

3.0 RESULTS

Field sampling was conducted between July 3 and August 3, 2007. A total of 130 wetlands were sampled including:

• Class1&2 wetlands with pipeline (N=92) o 35 constructed between 1970 and 1979 o 22 constructed between 1980 and 1989\ o 10 constructed between 1990 and 1999 o 25 constructed between 2000 and 2006

• Class1&2 wetlands without pipeline (N=22)

• Class 3 wetlands with pipeline (N=12)

• Class 3 wetlands without pipeline (N=4)

The generalized locations of these samples are shown in Figure 1.

Table 1 provides data (mean values) for all sampled measures for Class 1&2 wetlands with pipelines (on and off) and for reference wetlands without pipelines. Table 2 provides this same data for Class 3 wetlands, independent of the age of pipeline and including reference wetlands.

The following sections of the report present results organized by several aspects and measures of wetland native vegetation integrity, including:

• Bare ground percent cover • Litter percent cover and depth • Native plant species richness and cover • Introduced and weedy/invasive plant species richness and cover • Vegetation height by layer (graminoid, forb, shrub) • Plant species composition/similarity • Plant species biodiversity

Table 1. Mean values for sampled attributes in Class 1&2 wetlands.

Age class 1970-1979 1980-1989 1990-1999 2000-2006 NO On Off On Off On Off On Off Attribute pipeline pipeline pipeline pipeline pipeline pipeline pipeline pipeline PIPELINE Bare ground cover 16.2 10.3 16.5 12.3 5.1 3.1 17.9 5.5 5.0 Litter cover 73.5 79.7 73.7 80.3 88.4 89.8 71.3 86.2 87.5 Litter depth 2.0 2.0 3.2 3.6 4.8 4.5 2.7 3.8 3.8 Graminoid height 35.4 30.1 36.1 33.8 39.8 33.0 35.2 31.8 34.8 Forb height 27.0 22.3 25.7 26.5 35.9 26.6 25.9 26.0 28.7 Shrub height 39.3 29.4 24.5 21.7 32.7 29.7 28.8 34.0 20.5 # native graminoid species 3.8 4.6 4.0 4.2 6.0 5.2 5.4 5.6 4.5 Native graminoid sp cover 32.2 38.9 31.7 36.5 23.7 27.0 32.5 38.1 40.2 # native forb species 5.0 5.2 4.9 4.4 5.7 6.2 5.8 5.5 4.4 Native forb species cover 11.6 12.1 8.4 7.5 5.2 7.0 11.7 8.6 8.1 # native shrub species 0.3 0.2 0.1 0.1 0.2 0.2 0.2 0.2 0.1 Native shrub species cover 0.3 0.3 0.3 0.3 0.1 0.2 0.1 0.2 0.1 # introduced graminoid species 0.7 0.1 0.5 0.1 0.5 0.0 0.3 0.0 0.0 Introduced graminoid cover 6.9 0.1 4.7 0.2 1.6 0.0 2.5 0.0 0.0 # introduced forb species 2.9 2.4 3.4 3.1 5.1 3.9 4.2 3.4 2.7 Introduced forb cover 8.3 6.6 5.8 5.9 14.5 9.9 6.9 4.2 10.2 # weed/invasive sp 4.9 4.1 6.0 5.2 7.0 5.9 6.6 5.4 4.2 Weed/invasive sp cover 30.0 14.8 24.4 16.2 33.3 21.8 21.1 13.8 20.9 Number of sites 35 22 10 25 22

Table 2. Mean values for sampled attributes in Class 3 wetlands.

On Off NO Attribute pipeline pipeline PIPELINE Bare ground cover 1.0 1.0 0.5 Litter cover 93.4 92.0 95.0 Litter depth 6.2 6.7 6.7 Graminoid height 53.4 52.7 43.6 Forb height 41.5 36.2 29.7 Shrub height n/a 41.0 n/a # native graminoid species 4.0 4.3 4.3

Native graminoid sp cover 50.1 56.4 45.0

# native forb species 4.5 3.8 3.5

Native forb sp cover 20.6 15.7 5.4 # native shrub species 0.0 0.1 n/a Native shrub species cover 0.0 0.1 n/a # introduced graminoid species 0.1 0.0 0.0 Introduced graminoid cover 0.03 0.0 0.0 # introduced forb species 2.8 2.4 1.5 Introduced forb cover 3.5 1.5 1.1 # weed/invasive species 4.7 3.8 2.0 Weed/invasive sp cover 2.4 2.0 6.0 Number of sites 12 4

3.1 Bare Ground Cover

For Class 1&2 wetlands with pipelines the average percent cover of bare ground ranged from 3.1% to 12.3% (mean = 15.6%) on pipelines and from 5.1% to 17.9% (mean = 8.7%) off pipelines. Mean bare ground cover was higher on than off pipelines for all age classes (Figure 3) and significantly so for age classes 1990-99 and 2000-06 (Appendix 1). Class 1&2 wetlands without pipelines had mean bare ground cover of 5.0%.

18 16 14 12 10 % 8 6 4 1970-1979 2 1980-1989 0 1990-1999 2000-2006

Figure 3. Mean bare ground % cover by age class- Class 1&2 wetlands

Class 3 wetlands supported the same bare ground cover (1%) on and off pipelines. Bare ground was generally low in Class 3 wetlands, measuring 0.5% in those Class 3 wetlands without pipelines.

3.2 Vegetative Litter Cover and Depth

For Class 1&2 wetlands with pipelines the mean percent cover of litter ranged from 79.7% to 89.8% (mean = 82.7%) off pipelines and from 71.3% to 88.4% (mean = 74.6%) on pipelines. Mean litter cover was lower on pipelines for all age classes (Figure 4) and significantly so for age classes 1980-89 and 2000-06 (Appendix 1). Class 1&2 wetlands without pipelines had mean litter cover of 87.5%.

90 80

60 50 % 40

30 20 2000-2006 10 1990-1999 0 1980-1989 1970-1979

Figure 4. Mean vegetative litter cover by age class – Class 1&2 wetlands

Class 3 wetlands supported slightly higher litter cover (93.4%) on pipelines than off pipelines (92.0%). This difference was not statistically significant (Appendix 2). Litter cover in Class 3 wetlands without pipelines (95.0%) was very similar to that in Class 3 wetlands with pipelines.

Mean litter depth varied minimally between transects located on (mean = 2.8 cm) and off (mean = 3.2 cm) of pipelines. The exception was for pipelines constructed during 2000 to 2006 in which case litter depth on pipelines (3.8 cm) was significantly higher than off (2.7 cm). No significant differences in litter depth were detected on (6.2 cm) and off (6.7 cm) of pipelines for Class 3 wetlands.

3.3 Native Plant Species Richness and Cover

The mean number of native plant species did not differ significantly between transects located on and off of pipelines in Class 1&2 wetlands (Figure 5). The exception was the 1970-79 age class for graminoids (Appendix 1). Mean percent cover of native plant cover was generally higher off (46.6%) than on (41.5%) pipelines (Figure 6) but this difference was statistically significant only for graminoids in the 1970-79 age class (Appendix 1). The mean number and percent cover of native plant species recorded in Class 1&2 wetlands without pipelines were 9.0 (species) and 48.4% (cover) respectively.

12.0

10.0

8.0 1970-1979 6.0 1980-1989 1990-1999 4.0 2000-2006 2.0

0.0

Figure 5. Mean number of native plant species by age class- Class 1&2 wetlands

60.0

50.0

40.0 1970-1979 30.0 1980-1989 1990-1999 20.0 2000-2006

10.0

0.0

Figure 6. Mean % cover of native plant species by age class – Class 1&2 wetlands

For pipelines crossing Class 3 wetlands the mean number of native plant species did not differ significantly on (8.4 species) versus off (8.3 species) of the pipeline (Table 2). Mean percent cover of overall native plants also did not differ markedly between samples located on (69.6%) and off (70.6%) of pipelines crossing Class 3 wetlands (Table 2). From a statistical perspective the mean percent cover of native graminoids was significantly higher off (56.4%) pipelines than on (50.1%). However, the mean percent cover of native forbs was significantly greater on (20.6%) than off (15.7%) of pipeline (Appendix 2).

The mean number and percent cover of native plant species recorded in Class 3 wetlands without pipelines were 7.8 (species) and 50.4% (cover) respectively.

3.4 Introduced Plant Species Richness and Cover

This section of the report discusses results pertaining to the number and percent cover of introduced (non-native) plant species recorded in the smaller (1 m2) plots replicated along paired transects on and off pipelines and in reference wetlands. Section 3.5 summarizes the results of invasive and weedy plant sampling of larger 10 m2 plots sampled at the same transects.

Both the number and mean percent cover of introduced plant species were higher on versus off pipelines crossing through Class 1&2 wetlands (Figures 7 and 8). The mean number of introduced plant species on pipelines was 4.1 and off of pipelines was 3.1. In Class 1&2 wetlands without pipelines the mean number of introduced plant species recorded in 1m2 plots was 2.7. The mean percent cover of introduced plant species on pipelines was 12.6% and off of pipelines was 6.2%. In Class 1&2 wetlands without pipelines the mean percent cover of introduced plant species recorded in 1m2 plots was 10.2%.

6.0

5.0

4.0 1970-1979 3.0 1980-1989 1990-1999 2.0 2000-2006

1.0

0.0

Figure 7. Mean # of introduced plant species by age class – Class 1&2 wetlands

18.0 16.0 14.0 12.0 1970-1979 10.0 1980-1989 8.0 1990-1999 6.0 2000-2006 4.0 2.0 0.0

Figure 8. Mean % cover of introduced plant species – Class 1&2 wetlands

The differences between native plant richness and cover on and off paired pipeline transects in Class 1&2 wetlands was significant for graminoids but not for forbs (Appendix 1).

The mean number of introduced plant species did not differ significantly between paired transects on (2.9) and off (2.4) of pipelines crossing Class 3 wetlands (Appendix 2). The mean number of introduced plant species observed in wetlands without pipelines was 1.5. The mean percent cover of introduced plant (forb) species was significantly higher on (3.5%) than off (1.5%) of pipelines crossing Class 3 wetlands. The mean percent cover of introduced plant species observed in wetlands without pipelines was 1.1%.

3.5 Weedy/Invasive Plant Species Richness and Cover

Weedy and invasive plant species were recorded in 10 m2 plots (Figure 2). These larger plots were designed specifically to detect weedy plants. Both the number and mean percent cover of total weedy/invasive plant species were higher on versus off of pipelines crossing through Class 1&2 wetlands (Figures 9 and 10). Differences in number of weedy species were statistically significant only for the 2000-06 age class. Differences in the mean percent cover of weedy species were statistically significant for the 1970-79 and 1990-99 age classes (Appendix 1).

The mean number of total weedy/invasive plant species on pipelines was 5.9 and off of pipelines was 4.9. In Class 1&2 wetlands without pipelines the mean number of total weedy/invasive plant species recorded in 10m2 plots was 4.2. The mean percent cover of weedy/invasive plant species on pipelines was 26.6% and off of pipelines was 15.5%. In Class 1&2 wetlands without pipelines the mean percent cover of weedy/invasive plant species recorded in 10m2 plots was 20.9%.

7.0

6.0

5.0

4.0

3.0

2.0

1970-1979 1.0 1980-1989 0.0 1990-1999 2000-2006

Figure 9. Mean # of weedy/invasive plant species – Class 1&2 wetlands

Mean cover of w eed/invasive species w etlands class1-2 35.0

30.0

25.0

20.0 % 15 . 0

10 . 0

5.0 1970-1979 1980-1989 0.0 1990-1999 2000-2006

Figure 10. Mean % cover of weedy/invasive plant species – Class 1&2 wetlands

The mean number of weedy/invasive plant species recorded in 10 m2 plots did not differ significantly between paired transects on (4.7) and off (3.8) of pipelines crossing Class 3 wetlands. The mean number of introduced plant species observed in wetlands without pipelines was 2.0. The mean percent cover of weedy/invasive plant species did not differ significantly on (2.4%) versus off (2.0%) pipelines crossing Class 3 wetlands. The mean percent cover of invasive/weedy plant species observed in wetlands without pipelines was 6.0%.

3.6 Vegetation Height

For paired transects in Class 1&2 wetlands the mean height of graminoids on pipelines (35.2 to 39.8 cm) was higher than off (30.1 cm to 33.8 cm) for all age classes. Forb heights were higher on than off pipelines for the 1970-79 (27.0 cm vs. 22.3 cm) and 1990-99 (35.9 cm vs. 26.6 cm) age classes. Forb heights were higher off than on pipelines for the 1980-89 (25.7 cm vs. 26.5 cm) and 2000-06 (25.9 cm vs. 26.0 cm) age classes. Shrub heights were higher on pipelines in Class 1&2 wetlands for all but the 2000-06 age class. None of the height differences for any vegetation layer were statistically significant (Appendix 1).

3.7 Plant Species Composition and Similarity

This section of the report compares the composition and degree of similarity of plant species recorded in wetlands with and without pipelines and between transects located on and adjacent (10 m parallel) pipelines. The total list of plant species recorded on transects in wetlands during the summer of 2007 is provided in Table 3.

Table 3. Plant Species recorded on transects during wetland sampling in the MTA- August 2006

Forb species Origin Graminoid species Origin Achillea millefolium L. N Agropyron intermedium (Host) Beauv. I Agoseris glauca (Pursh) Raf. N Agropyron pectiniforme R & S I Ambrosia artemisiifolia var elatior (L) Desc. N Agropyron repens (L.) Beauv. I Androsace septentrionalis L. N Agrostis scabra Willd. N Antennaria dimorpha N Agrostis stolonifera L. I Antennaria sp N Agropyron smithii Rydb. N Arabis sp N Agropyron trachycaulum (Link) Malte N Arabis hirsute (L.) Scop N Agropyron sp Arnica sp N Alopecurus aequalis Sobol. N Artemisia frigida Willd. N Beckmannia syzigachne (Steud.) Fern. N Artemisia ludoviciana Nutt N Bouteloua gracilis (HBK) Lag. N Asclepias spoeciosa Torr N Bromus inermis Leyss. ssp inermis I Aster ericoides L. N Calamagrostis inexpansa A. Gray N Aster sp Calamagrostis stricta (Timm) Koeler Astragalus bisulcatus (Hook.) N Calamagrostis sp N Astragalus dasyglottis Fisch. ex DC. N Carex atherodes Spreng. N Atriplex nuttallii S. Wats. N Carex brevior (Dewey) Mack. N Atriplex prostrata Bouch. Carex lanuginosa Michx. N Campanula rotundifolia L. N Carex praegracilis W. Boott. N Cerastium arvense L. N Carex scirpoidea Michx. N Chenopodium album L. I Carex simulata Mack. N Chenopodium pratericola Rydb. N Carex stenophylla Wahl N Chenopodium sp Carex sp 1 Cirsium arvense (L.) Scop. I Carex sp 2 Cirsium undulatum (Nutt.) Spreng N Deschampsia cespitosa (L.) Beauv. N Cleome serrulata Pursh. N Distichlis stricta (Torr.) Rydb. N Marsilea vestita Hook & Grev. N Eleocharis acicularis (L.) R. & S. N Collomia linearis Nutt. N Eleocharis palustris (L.) R. & S. N Crepis runcinata (James) T. & G. N Elymus junceus Fisch. I Crepis tectorum L. I Hordeum jubatum L. ssp jubatum N Descurainia richardsonii (Sweet) O.E. Schulz N Juncus balticus Willd. N Descurainia sophia (L.) Webb I Koeleria macrantha (Ledeb.) J.A. Schultes f. N Draba nemorosa L. N Muhlenbergia asperifolia (Nees & Mey) N Epilobium ciliatum Raf. ssp. ciliatum N Muhlenbergia cuspidata (Torr.) Rydb. N Epilobium palustre L. N Muhlenbergia richardsonis (trin.) Rydb. N Equisetum laevigatum A. Br. N Muhlenbergia sp. N Erigeron canadensis L. N Phalaris arundinacea L. N Erigeron lonchophyllus Hook. N Poa canbyi (Scribn.) Piper N Erigeron philadelphicus L. N Poa juncifolia Scribn. N Erigeron sp N Poa palustris L. N Erysimum cheiranthoides L. ssp cheiranthoides I Poa pratensis L. N-I Erucastrum gallicum (Willd.) Schultz I Poa sp L. Galium boreale L. N Puccinellia nuttalliana (Schult.) A.S. Hitchc N Galium sp. Scirpus paludosus A. Nels. N Gaillardia aristata Pursh N Spartina gracilis Trin. N Gaura coccinea Pursh N Sphenopholis obtusata (Michx.) Scribn. N Glaux maritima L. N Stipa viridula Trin N Glycyrrhiza lepidota (Nutt.) Pursh N

Gnaphalium palustre Nutt. N Grindelia squarrosa Willd. N Hedeoma hispidum Pursh N Shrub species Origen Heterotheca villosa (Pursh) Shinners N Artemisia cana Pursh N Iva axillaris Pursh. N Rosa woodsii N Kochia scoparia (L.) Schrad. I Sarcobatus vermiculatus (Hook.) Torr. N Lactuca pulchella (Pursh) DC N Lactuca serriola L. I Lappula occidentalis (S. Wats.) Greene N Lappula squarrosa (Retz.) Dumort. I Lepidium densiflorum Schrad. N Lygodesmia juncea (Pursh) D. Don N Medicago lupulina L. I Melilotus alba Desr. I Melilotus officinalis (L.) Lam. I Melilotus sp. I Mentha arvensis L. N Myosurus minimus L. N Navarretia minima Nutt. N Oenothera caespitosa Nutt. N Oenothera nuttallii Sweet N Oenothera sp N Orthocarpus luteus Nutt. N Penstemon procerus Dougl. ex Grah. N Penstemon sp. N Plantago elongata Pursh N Plantago patagonica Jacq. N Plantago eriopoda N Polygonum arenastrum Jord. ex Bor I Polygonum amphibium L N Polygonum coccineum Muhl. N Polygonum lapathifolium L. I Polygonum ramosissimum Michx. N Polygonum sp. Potentilla anserina L. N Potentilla bipinnatifida Dougl. Ex. Hook. N Potentilla norvegica L. N Potentilla sp L. Ranunculus macounii Britt. N Ranunculus sp. Ratibida columnifera (Nutt) Wooton & Standl. N Rorippa sp. Rumex maritimus L. N Rumex stenophyllus Ledeb. I Rumex triangulivalvis (Dans.) Rech. F. N Rumex sp. Salicornia europea ssp rubra (A. Nels.) N Salsola kali L. I Silene sp. Sisymbrium altissimum L. I Sisyrinchium montanum Greene N Sisyrinchium septentrionale Bicknell N

Solidago multiradiata Ait. N Solidago sp. N Sonchus arvensis L. I Sphaeralcea coccinea (Pursh) Rydb. N Suaeda calceoliformis (Hook.) Moq. N Taraxacum officinale Weber I Thermopsis rhombifolia (Nutt.) Richards. N Thlaspi arvense L. I Tragopogon dubius Scop. I Tragopogon pratensis L. I Tragopogon sp L. I Trifolium sp. I Triglochin maritima L. N Unknown forb (sapling) Veronica peregrina ssp. Xalapensis (HBK) Pennell N Verbena bracteata Lag. & Rodr. N Vicia americana Muhl. N Viola sp.

3.7.1 Plant Species Composition

Class 1&2 Wetlands

Table 4 lists the dominant plant species observed in Class 1&2 wetlands on and off of pipelines for each of the four age classes. Dominance was based on rank-ordered species with the 25 highest importance values (mean cover x constancy). Table 4 also shows the dominant species observed in Class 1&2 wetlands that did not have pipelines.

Common native graminoids recorded in Class 1&2 wetlands were: Agropyron smithii, Poa palustris, Distichlis stricta, Hordeum jubatum, Poa pratensis, Eleocharis acicularis, Agropyron trachycaulum, Carex spp., Juncus balticus and, Puccinellia nuttalliana. Dominant native forbs in Class 1&2 wetlands were: Artemisia ludoviciana, Achillea millefolium, Glycyrrhiza lepidota, Grindelia squarrose, Astragalus dasyglottis, Triglochin maritima, Vicia americana, Aster ericoides, Lactuca pulchella, and, Rumex triangulivalvis.

The most commonly recorded introduced graminoid plant species in Class 1&2 wetlands were: Agropyron pectiniforme, Bromus inermis, Agropyron repens, Elymus junceus, and Agropyron intermedium. The dominant introduced forbs recorded in Class 1&2 wetlands were: Sonchus arvensis, Crepis tectorum, Cirsium arvense, Taraxacum officinale, Descurainia sophia, Lactuca serriola, and Chenopodium album.

Class 3 Wetlands

Table 5 lists the dominant plant species observed in Class 3 wetlands on and off of pipelines and in wetlands without pipelines. Dominance was based on rank-ordered species with the 25 highest importance values (mean cover x constancy).

Common native graminoids recorded in Class 3 wetlands were: Carex atherodes, Eleocharis palustris, Beckmannia syzigachne, Hordeum jubatum, Poa palustris, Agropyron smithii, Alopecurus aequalis, Agrostis scabra, Phalaris arundinacea, and, Juncus balticus. Dominant native forbs in Class 3 wetlands were: Polygonum coccineum, Artemisia ludoviciana, Rumex triangulivalvis, Potentilla anserina, Mentha arvensis, Lactuca pulchella, Grindelia squarrose, Rumex maritimus, and Epilobium palustre.

Class 3 wetlands did not support noteworthy concentrations of introduced graminoid plant species. The most commonly recorded introduced forb species recorded in Class 3 wetlands were: Chenopodium album, Sonchus arvensis, Cirsium arvense, Lactuca serriola, Taraxacum officinale, Crepis tectorum, Sisymbrium altissimum, and Tragopogon dubius.

Table 4. Rank-ordered importance values for dominant plant species in Class 1&2 wetlands - on and off pipelines. 1970-79 OFF 1970-79 ON 1980-89 OFF 1980-89 ON 1990-99 OFF 1990-99 ON 2000-06 OFF 2000-06 ON NO PIPELINE

Agrosmi 94.2 Agrosmi 103.8 Agrosmi 79.9 Agrosmi 106.7 Soncarv 39.7 Soncarv 58.6 Agrosmi 131.0 Agrosmi 110.4 Agrosmi 108.6 Poa pal 25.4 Artelud 30.6 Poa pal 37.7 Poa pal 17.9 Agrosmi 36.0 Agrosmi 30.9 Care sp1. 19.6 Hordjub 27.6 Poa pra 38.4 Artelud 21.7 Diststr 21.3 Hordjub 9.7 Agropec 14.3 Diststr 12.2 Agrotra 19.8 Poa pra 16.9 Artelud 21.5 Care sp1. 26.4 Hordjub 16.9 Agropec 17.0 Diststr 9.0 Diststr 14.2 Muhlric 8.0 Poa pra 14.9 Eleoaci 13.6 Poa pra 17.3 Poa pal 15.6 Diststr 15.2 Soncarv 8.3 Eleoaci 6.9 Artelud 8.9 Poa pra 6.0 Diststr 14.6 Hordjub 13.2 Agrotra 14.2 Soncarv 15.1 Soncarv 13.5 Grinsqu 8.0 Artelud 6.2 Hordjub 8.4 Careste 5.1 Cirsarv 10.7 Poa pal 11.5 Creptec 9.3 Cirsarv 11.2 Care sp1. 10.9 Poa pal 7.4 Soncarv 6.1 Stipvir 7.9 Juncbal 4.9 Hordjub 7.4 Creptec 8.4 Taraoff 8.8 Artelud 10.8 Eleoaci 4.4 Hordjub 6.2 Care sp1. 5.7 Creptec 4.3 Cirsarv 4.1 Glyclep 4.2 Artelud 7.5 Stipvir 7.5 Juncbal 10.4 Poa pra 3.4 Puccnut 5.8 Poa pra 5.5 Taraoff 4.2 Calaine 4.0 Juncbal 3.3 Taraoff 7.0 Poa pal 6.5 Carepra 7.5 Grinsqu 2.8 Cirsarv 3.1 Agrotra 4.6 Poa pra 3.7 Poa pal 3.6 Descsop 3.2 Diststr 6.4 Diststr 5.8 Eleoaci 6.6 Creptec 2.5 Descsop 2.6 Taraoff 4.3 Cirsarv 3.3 Carepra 3.2 Poa pal 2.9 Grinsqu 3.5 Grinsqu 5.2 Puccnut 5.8 Cirsarv 2.2 Poa pra 2.5 Achimil 3.2 Achimil 3.1 Artelud 2.7 Asteeri 2.3 Agrotra 2.6 Eleoaci 2.9 Taraoff 5.6 Agrotra 2.2 Eleoaci 1.9 Puccnut 2.9 Puccnut 2.2 Astrdas 2.0 Calaine 2.1 Achimil 2.2 Cirsarv 2.8 Hordjub 3.9 Taraoff 1.9 Taraoff 1.6 Stipvir 2.5 Care sp1. 2.0 Glyclep 1.8 Carepra 2.1 Juncbal 1.3 Care sp1. 1.8 Creptec 2.9 Trigmar 1.6 Creptec 1.6 Carepra 2.4 Soncarv 1.9 Agrotra 1.7 Taraoff 2.0 Astrdas 1.1 Soncarv 1.6 Diststr 2.8 Astrdas 1.4 Care sp1. 1.5 Creptec 2.1 Eleoaci 1.7 Caresci 1.6 Muhlric 1.6 Glyclep 1.0 Astrdas 1.6 Achimil 2.7 Poa jun 1.4 Agrotra 1.5 Juncbal 1.8 Descsop 1.5 Ambrart 1.4 Astrdas 1.4 Muhlric 1.0 Achimil 1.0 Glyclep 1.7 Juncbal 1.1 Poa jun 1.4 Trigmar 1.6 Viciame 1.4 Taraoff 1.4 Stipvir 1.2 Viciame 0.9 Poa jun 0.9 Careath 1.6 Glyclep 1.0 Stipvir 1.3 Rumetri 1.5 Juncbal 1.3 Asteeri 1.3 Agroint 1.1 Alopaeq 0.8 Glyclep 0.8 Stipvir 1.1 Iva axi 0.9 Astrdas 1.3 Cirsarv 0.8 Suaecal 1.2 Epilpal 1.2 Equilae 0.6 Agrosca 0.8 Descsop 0.7 Poa jun 1.1 Ambrart 0.8 Glyclep 1.0 Poa sp. 0.7 Rumetri 1.2 Creptec 1.0 Care sp1. 0.6 Eleopal 0.7 Bromine 0.6 Poa sp. 1 Stipvir 0.8 Bromine 0.9 Epilpal 0.6 Trigmar 0.7 Artefri 0.9 Ambrart 0.5 Stipvir 0.6 Agrosca 0.6 Carelan 0.9 Puccnut 0.8 Juncbal 0.7 Lactpul 0.5 Chenalb 0.6 Eleopal 0.8 Chenpra 0.5 Cirsarv 0.4 Agrorep 0.6 Lactpul 0.9 Muhlric 0.8 Viciame 0.6 Viciame 0.4 Grinsqu 0.5 Lactser 0.6 Artelud 0.4 Careste 0.3 Agropec 0.5 Agrosca 0.9 Achimil 0.6 Elymjun 0.4 Lactser 0.4 Glyclep 0.5 Care sp1. 0.4 Lactser 0.4 Asteeri 0.3 Viciame 0.3 Trigmar 0.7

Native Graminoid Native Forb Introduced Graminoid Introduced Forb

Table 5. Plant species in Class 3 wetlands.

OFF-PIPELINE ON-PIPELINE NO PIPELINE

Careath 72.6* Careath 135.1 Careath 43.5 Poa pal 64.3 Becksiz 69.0 Eleopal 23.1 Eleopal 59.5 Eleopal 63.9 Becksiz 12.9 Polycoc 49.5 Polycoc 53.5 Poa pra 4.6 Hordjub 41.4 Hordjub 36.7 Polycoc 3.8 Artelud 20.9 Eleoaci 31.1 Alopaeq 1.6 Becksiz 20.3 Poa pal 20.0 Pote sp. 1.1 Eleoaci 17.6 Artelud 9.2 Chenalb 1.0 Rumetri 14.1 Poteans 3.5 Rumetri 0.9 Agrosmi 5.8 Chenalb 2.8 Eleoaci 0.7 Mentarv 3.7 Rumetri 2.6 Lactpul 0.5 Grinsqu 3.3 Agrosmi 2.1 Cirsarv 0.3 Chenalb 3.1 Alopaeq 1.5 Solimul 0.2 Phlaaru 2.3 Carelan 0.9 Hordjub 0.1 Poteans 1.7 Soncarv 0.8 Agrotra 0.1 Ambrart 1.5 Grinsqu 0.7 Mentarv 0.1 Soncarv 1.5 Agrosca 0.5 Astrbis 0.1 Taraoff 0.4 Mentarv 0.3 Poa pal 0.1 Cirsarv 0.3 Rumemar 0.3 Agrosca 0.1 Atripro 0.2 Ambrart 0.3 Epilpal 0.1 Lactser 0.2 Lactser 0.2 Artelud 0.1 Rumemar 0.2 Chenpra 0.2 Sisyalt 0.1 Lactpul 0.1 Creptec 0.1 Asteeri 0.1 Achimil 0.1 Veroper 0.1 Juncbal 0.1 Poa pra 0.1 Epilpal 0.1 Tragdub 0.1

* Importance value - Mean % Cover x constancy

Native graminoid Native forb Introduced graminoid Introduced forb

3.7.2 Plant Species Similarity

The Sorenson’s index was used to measure and express the degree of similarity of the full range of plant species recorded on and off of pipelines for Class 1&2 and Class 3 wetlands. The equations for two versions of this index follow:

Sorenson Similarity Diversity Index (Cs)

Cs = 2j/(a+b) where,

a = species richness in site a b = species richness in site b j = number of shared species

Sorenson Quantitative Diversity Index (Cn)

Cn = 2(jN)/(aN+bN) where,

aN = Total abundance in site a (in this case the sum of % cover) bN = Total abundance in site a (in this case the sum of % cover) jN = The sum of the lower of the two abundances recorded for shared species

Both Sorenson Indices (Cs and Cn) range from 0 to 1. A value of 1 indicates complete similarity, while a value of 0 indicates complete dissimilarity.

Table 6 shows the Sorenson’s indices results for Class 1&2 and Class 3 wetlands.

Table 6. Sorenson's indices of similarity for plant species on and off pipelines

Class 1&2 Wetlands Class 3 Wetlands

1970-79 1980-89 1990-99 2000-06 All Ages Sorenson's Cs 0.81 0.76 0.81 0.83 0.78

Sorenson's Cn 0.73 0.71 0.7 0.71 0.78

All pipeline ages and classes show that over 70% similarity between species types and abundance recorded on and off of pipelines. The highest index of similarity based solely on species richness was 83% for the most recently constructed pipelines (2000- 06). The degree of similarity was very similar (70% to 73%) for all age classes when taking into account both species richness and percent cover (Sorenson’s Cn). Class 3 wetlands showed the highest index of similarity (78%) for Sorenson’s Cn.

3.8 Plant Biodiversity

The Simpson’s Diversity Index was employed in order to compare floristic diversity between paired transects located on and off of pipelines. This index was calculated as follows:

1/D= {sum[n(n-1)]}/[N(N-1)] where, n= % cover per species N= Total % cover

Table 7 shows the Simpson’s diversity index results for Class 1&2 and Class 3 wetlands, on and off of pipelines and in wetlands with no pipelines. Higher index values mean greater diversity.

Table 7. Simpson Diversity Index values

Accumulated Simpson Index for wetlands class 1-2 Age class Location Index value 1970-1979 On pipeline 13.3 Off pipeline 12.6 1980-1989 On pipeline 11.5 Off pipeline 13.2 1990-1999 On pipeline 13.0 Off pipeline 15.0 2000-2006 On pipeline 13.2 Off pipeline 11.3 NO PIPE NO PIPELINE 14.7

Accumulated Simpson Index for wetlands class 3 Location Index value On pipeline 10.0 Off pipeline 7.0 NO PIPELINE 4.5

For Class 1&2 wetlands floristic diversity was higher on than off pipelines for age classes 1970-79 and 2000-06. For age classes 1980-89 and 1990-99 floristic diversity was higher off pipelines than on. Floristic diversity index was higher on than off of pipelines for Class 3 wetlands (independent of age). The accumulated Simpson’s index is sensitive to sample size therefore comparisons of this index must be done with caution.

4.0 SUMMARY AND CONCLUSIONS

4.1 Baseline Introduced Plant Species Abundance in Wetlands

• For Class 1&2 wetlands the mean percent cover of introduced plant species in wetlands with pipelines ranged from 6.2% off of (adjacent) pipelines to 12.6% on pipelines. Wetlands without pipelines had a mean percent cover of introduced plants of 10.2%.

• By comparison, the mean percent cover of introduced plant species recorded within 1 m2 plots during vegetation triangle sampling in the MTA (in 2006) was 6.4%. We therefore conclude that introduced species cover in wetlands is generally higher than in uplands.

• For Class 3 wetlands the mean percent cover of introduced plant species in wetlands with pipelines ranged from 1.5% off of (adjacent) pipelines to 3.6% on pipelines. Wetlands without pipelines had a mean percent cover of introduced plants of 1.1%.

• Based on 10 m2 plots, mean percent cover of weedy/invasive species ranged from 15.5% off of (adjacent) pipelines to 26.6% on pipelines. Wetlands without pipelines had a mean percent cover of weedy/invasive plant species of 20.9%.

• By comparison, the mean percent cover of weedy/invasive plant species recorded within 100 m2 plots during vegetation triangle sampling in the MTA (in 2006) was 13.8%. We therefore conclude that weedy/invasive plant species cover in wetlands is generally higher than in uplands; i.e., that weeds are more common in wetlands than in non-wetland areas.

4.2 Effects of Pipelines On Wetland Vegetation Integrity

• The structure of vegetation in Class 1&2 and Class 3 wetlands, as measured by mean height of various layers, is not altered significantly by pipeline construction.

• The ground surface (as measured by bare ground cover, litter cover and depth) along pipelines in Class 1&2 wetlands is altered significantly for newer (2000- 06) pipelines but less so for older pipelines. We therefore conclude that recovery is taking place for these measures.

• The ground surface of Class 3 wetlands is not significantly altered by pipeline construction because the productive wetland environment and wetter soil conditions likely results in greater vegetation resilience and repair.

• For Class 1&2 wetlands, introduced and weedy/invasive plant species richness and percent cover are higher on than off of pipelines. These differences are significant for introduced graminoid species (not for introduced forbs).

Weedy/invasive species percent cover differences are statistically significant for two age classes (1970-79 and 1990-99).

• Pipelines constructed in Class 3 wetlands exhibited mixed results in terms of introduced and weedy/invasive plant species richness and mean percent cover. Generally these wetlands are less prone to weedy plant invasion, especially for graminoid weed species.

• In spite of increased introduced and weedy/invasive plant species occurrence, native plant species richness and cover is not significantly affected by pipeline construction in Class 1&2 wetlands. The only statistically significant differences in native plant richness and cover between on and off paired transects was noted for the oldest pipelines, and only for graminoids. This likely reflects the past use of Crested Wheatgrass (Agropyron pectiniforme) as a reclamation species.

• Class 3 wetlands are less prone to weedy/invasive plants on pipelines than are Class 1&2 wetlands, likely because of higher soil moisture.

• Sorenson’s index values (70% to 83%) indicate a high degree of similarity in plant species composition between transects located on and off pipelines for all age classes. Class 3 wetlands showed the greatest degree of similarity.

• Based on Simpson’s diversity index calculations, floristic diversity is both reduced and increased after pipeline construction depending on age class. Results for Class 3 wetlands indicate that pipeline construction increases floristic diversity but because this increase is based on introduced plants future native plant species loss in wetlands due to pipeline construction is unlikely.

• During field studies it was noted that stands of Crested Wheatgrass (Agropyron pectiniforme) were most evident along pipelines when the micro- topography in wetlands had been modified during construction. This modification was in the form of a raised berm (‘roach’) that generated a drier environment that facilitated the establishment of this species. This occurred primarily along pipelines constructed in the 1970s and 1980s.

5.0 LITERATURE CITED

Stewart R. and H. Kantrud. 1971. Classification of natural ponds and lakes in the glaciated prairie region. Resource publication 92. Bureau of Sport Fisheries and Wildlife. Washington. 57pp.

APPENDIX 1. Statistical results for On and Off pipeline transects -Class 1&2 Wetlands

Total Mean Value number of Wilcoxon test AGE VARIABLE paired On pipeline Off pipeline transect p-value 70- 79 Bare soil cover 16.2 10.3 35 0.12 80- 89 Bare soil cover 16.5 12.3 22 0.08 90- 99 Bare soil cover 5.1 3.1 10 *0.01 00- 06 Bare soil cover 17.9 5.5 25 *0.001 70- 79 Litter cover 73.5 79.7 35 0.16 80- 89 Litter cover 73.7 80.3 22 *0.02 90- 99 Litter cover 88.4 89.8 10 0.24 00- 06 Litter cover 71.3 86.2 25 *0.002 70- 79 Litter depth 1.96 2.0 35 0.88 80- 89 Litter depth 3.2 3.6 22 0.14 90- 99 Litter depth 4.8 4.5 10 0.34 00- 06 Litter depth 2.7 3.8 25 *0.02 70- 79 Grass height 35.4 30.1 35 0.07 80- 89 Grass height 36.1 33.8 22 0.29 90- 99 Grass height 39.8 33.0 10 0.10 00- 06 Grass height 35.2 31.8 25 0.13 70- 79 Forb height 27.0 22.3 35 0.08 80- 89 Forb height 25.7 26.5 22 0.73 90- 99 Forb height 35.9 26.6 10 0.08 00- 06 Forb height 25.9 26.0 25 0.91 70- 79 Shrub height 39.3 29.4 35 0.06 80- 89 Shrub height 24.5 21.7 22 n/a 90- 99 Shrub height 32.7 29.7 10 n/a 00- 06 Shrub height 28.8 34.0 25 0.24 70- 79 # Native graminoid species 3.8 4.6 35 *0.02 80- 89 # Native graminoid species 4.0 4.2 22 0.86 90- 99 # Native graminoid species 6.0 5.2 10 0.12 00- 06 # Native graminoid species 5.4 5.6 25 0.79 70- 79 Cover of native graminoid species 32.2 38.9 35 *0.02

80- 89 Cover of native graminoid species 31.7 36.5 22 0.09 90- 99 Cover of native graminoid species 23.7 27.0 10 0.80 00- 06 Cover of native graminoid species 32.5 38.1 25 0.12 70- 79 # Native forb species 5.0 5.2 35 0.69 80- 89 # Native forb species 4.9 4.4 22 0.48 90- 99 # Native forb species 5.7 6.2 10 0.90 00- 06 # Native forb species 5.8 5.5 25 0.87 70- 79 Cover of native forb species 11.6 12.1 35 0.94 80- 89 Cover of native forb species 8.4 7.5 22 0.72 90- 99 Cover of native forb species 5.2 7.0 10 0.38 00- 06 Cover of native forb species 11.7 8.6 25 0.33 70- 79 # Native shrub species 0.3 0.2 35 0.54 80- 89 # Native shrub species 0.1 0.1 22 n/a 90- 99 # Native shrub species 0.2 0.2 10 n/a 00- 06 # Native shrub species 0.2 0.2 25 0.74 70- 79 Cover of native shrub species 0.3 0.3 35 0.62 80- 89 Cover of native shrub species 0.3 0.3 22 n/a 90- 99 Cover of native shrub species 0.1 0.2 10 n/a 00- 06 Cover of native shrub species 0.1 0.2 25 0.12 70- 79 # Introduced graminoid species 0.7 0.1 35 *0.0002 80- 89 # Introduced graminoid species 0.5 0.1 22 *0.04 90- 99 # Introduced graminoid species 0.5 0.0 10 0.06 00- 06 # Introduced graminoid species 0.3 0.0 25 *0.03 70- 79 Cover of introduced graminoid species 6.9 0.1 35 *0.00 80- 89 Cover of introduced graminoid species 4.7 0.2 22 *0.03 90- 99 Cover of introduced graminoid species 1.6 0.0 10 0.06 00- 06 Cover of introduced graminoid species 2.5 0.0 25 *0.03 70- 79 # Introduced forb species 2.9 2.4 35 0.17 80- 89 # Introduced forb species 3.4 3.1 22 0.35 90- 99 # Introduced forb species 5.1 3.9 10 0.18 00- 06 # Introduced forb species 4.2 3.4 25 0.16

70- 79 Cover of introduced forb species 8.3 6.6 35 0.28 80- 89 Cover of introduced forb species 5.8 5.9 22 0.90 90- 99 Cover of introduced forb species 14.5 9.9 10 0.16 00- 06 Cover of introduced forb species 6.9 4.2 25 0.06 70- 79 # Weed/invasive species 4.9 4.1 35 0.09 80- 89 # Weed/invasive species 6.0 5.2 22 0.28 90- 99 # Weed/invasive species 7.0 5.9 10 0.10 00- 06 # Weed/invasive species 6.6 5.4 25 *0.03 70- 79 Cover of weed/invasive species 30.0 14.8 35 *0.0004 80- 89 Cover of weed/invasive species 24.4 16.2 22 0.06 90- 99 Cover of weed/invasive species 33.3 21.8 10 *0.005 00- 06 Cover of weed/invasive species 21.1 13.8 25 0.09

Appendix 2. Statistical Results for On and Off pipeline transects - Class 3 Wetlands Total Wilcoxon Mean Value number test VARIABLE of On Off paired p-value pipeline pipeline transect Bare soil cover 1.0 1.0 12 0.74 Litter cover 93.4 92.0 12 n/a Litter depth 6.2 6.7 12 0.90 Grass height 53.4 52.7 12 0.68 Forb height 41.5 36.2 12 0.06 Shrub height n/a 41.0 12 n/a # Native graminoid species 4.0 4.3 12 0.74 Cover of native graminoid species 50.1 56.4 12 *0.05 # Native forb species 4.5 3.8 12 0.64 Cover of native forb species 20.6 15.7 12 *0.03 # Native shrub species 0.0 0.1 12 n/a Cover of native shrub species 0.0 0.1 12 n/a # Introduced graminoid species 0.1 0.0 12 n/a Cover of introduced graminoid species 0.03 0.0 12 n/a # Introduced forb species 2.8 2.4 12 0.80 Cover of introduced forb species 3.5 1.5 12 *0.01 # Weed/invasive species 4.7 3.8 12 0.10 Cover of weed/invasive species 2.4 2.0 12 0.22 n/a: too few united samples to perform signed rank test *: significant difference detected between on and off pipeline transect values

Reference: Volume 3, Section 4.4.3, Page 4-5, Volume 3, Section 4.7.1, Page 4-11

Preamble: EnCana states that “Deviations in precipitation levels and varying extent of surface runoff (Adams et al. 1998) can lower wetland area calculations from those derived from aerial photographs taken during modal climatic periods. However, planned pre- disturbance assessments will confirm wetland presence and extent and identify any wetlands not currently mapped including Class 1 and 2 wetlands.” EnCana further states that “Adams et al. (1997) noted that not all ephemeral or temporary wetland (e.g., Classes 1 and 2 in Stewart and Kantrud [1971]) were mapped by CWS. Differences between these “lesser” wetlands and surrounding upland grassland can be very subtle and difficult to detect.”

Request: GOC recommends that EnCana: 1. explain how it has considered those wetlands which have not been currently mapped in assessing Project-related impacts on wetlands; 2. specify how it will inventory additional wetlands, given that Class 1 and 2 wetlands are difficult to detect; 3. specify how it has considered the variability of wetland area calculations due to changes in precipitation; 4. explain how this variability affects the assessment of Project-related impacts on wetlands; and 5. specify how baseline information collected for wetland communities, including Class 1 and 2 was collected in a manner to provide statistically sound data using a suitable sampling method.

Response: 1. Class 1 and 2 wetlands will be identified during the pre-disturbance assessment (PDA). As EnCana will be avoiding wetlands, baseline information, particularly on the effects of infill development is not required for an assessment of the effects of the Project on wetlands.

2. Classes 1 (ephemeral) and 2 (temporary) are difficult to detect by remote methods; however, they will be detected during pre-disturbance assessment site visits. Their presence will be determined based on topography, soil and vegetation wetness and greenness, and most importantly by specific wetland plant species occurrence. Typical indicator plants of ephemeral and temporary wetlands include: Poa pratensis, Poa palustris, Agropyron trachycaulum, Carex lanuginosa, Carex brevior, Carex praegracilis, Hordeum jubatum, Calamagrostis inexpansa, Spartina gracilis, Juncus balticus, Glycyrrhiza lepidota, Rosa woodsii, Artemisia ludoviciana, Agoseris glauca, Agropyron 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-012 2 #Terr - 270 - A

smithii, Sophia, Solidago spp, Mentha arvensis, Grindelia squarrosa, and Sonchus arvensis can be used as an indicator of wetlands class 1 or 2.

3. Variability of wetland area was not considered in the assessment. Wetlands will ultimately be identified and avoided by pre-disturbance assessments.

4. Variability in wetland area will not affect assessment of Project impacts. Pre- disturbance assessments will be conducted and wetlands will be avoided except in exceptional circumstances.

5. During summer of 2007, baseline information for wetlands class 1 and 2 was collected using 25 meter transects, that comprised five 1m2 plots and five 10m2 plots. The smaller plots were used to collect floristic information, bare ground cover, litter cover, and litter depth while the 10 m2 were used to collect information about weed and invasive species presence and cover.

Reference: Volume 3, Section 4.7.2, Page 4-11

Preamble: EnCana summarizes the existing footprint by wetland type.

Request: GOC recommends that EnCana:

1. discuss the accuracy of the existing footprint analysis, and specify how wetlands which have not been currently mapped have been considered in the footprint analysis; 2. produce estimates of the projected footprint by wetland type; 3. document the current and proposed level of habitat fragmentation; 4. identify and evaluate the extent of effects from fragmentation, such as introduction of non-native plant species on native species composition, and any changes to wetland plant communities that may result; 5. quantify wetland habitat change as mediated by structural change, reduced effectiveness, or alteration; and 6. identify the resulting effects of increased footprint and/or fragmentation of wetlands on wildlife.

Response: 1. A total of 132 sites were checked in the fall of 2006 to assess footprint classification accuracy. An overall accuracy of 75.8% was obtained. Of the 36 leases mapped and checked, 35 were correctly classified. The single error was actually a pipeline junction. Of the 33 linear features mapped and checked as double track trail, 30 were correctly classified. Of the three errors – two were actually pipelines with double track trail and one was a pipeline with single track trail. Of the 14 linear features mapped and checked as single track trails, 7 were correctly identified. Of the 7 errors five were actually double track trails, one was a pipeline and one was a pipeline with a double track trail. Of the 33 features mapped and checked as pipelines, 12 were correctly classified. Of the 21 errors 20 were actually pipelines with double track trails and one was a double track trail. See Table 1 below.

2. The preliminary project layout completely avoids wetlands.

3. Current fragmentation of wetlands is minimal (<1% footprint effect). For details on habitat fragmentation see Volume 3, Appendix 5-I.

4. The 2007 wetland field study report details the effects of past pipeline 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-012 2 #Terr - 271 - B

construction on wetlands, including introduced, weedy/invasive species occurrence on and off pipelines, biodiversity measures and similarity of plant species on and off of pipelines. Comparisons of species on and off of pipelines showed 70% to 83% similarity of plant species and abundance with no specific reclamation measures (i.e. natural recovery). Vegetation structure as measured by vegetation layer height did not differ significantly on and off of pipelines.

5. The minimal footprint and 70% to 83% similarity of past shallow gas impacts to wetlands in addition to the avoidance measures that will be taken lead EnCana to conclude that impacts on wildlife habitat in wetlands will be negligible.

6. There will be negligible increased footprint resulting from the Project in wetlands because of avoidance except in exceptional circumstances.

Table 1: Comparative Analysis of Ursus Field Investigation and Air Photo Investigations. PL PL+DT RGR TDT-TR TST L pipeline + raised gravel trail double trail single Feature pipeline double track Lease road track track Variable trail Air Air Air Air Air Air Field Field Field Field Field Field Photo Photo Photo Photo Photo Photo Sample Size 16 6046 36 6140 6 1468 41 30200 7 9098 38 3629 Mean Total Feature 2.90 3.08 5.80 3.64 8.30 7.15 2.48 3.41 0.42 2.05 860.1 469.50 Width/Area (m) Standard 1.40 1.68 2.20 1.43 1.00 2.02 0.40 1.21 0.20 1.54 368.9 Deviation 0.09

Reference: Volume 3, Section 4.8.2.1, Page 4-12

Preamble: EnCana states “A total of 54 preliminary well sites and some pipelines fell within the 100-m buffers established around wetlands. These wells will be flagged and closely investigated during pre-disturbance assessments when options for further avoidance or mitigation will be explored…Wetlands will be avoided wherever possible during construction of well sites and pipelines. A set-back of 100 m from the centre of the well will be used as a buffer; this distance may be reduced in exceptional circumstances where resource extraction would be severely compromised and effects on the environment would be more adverse if the buffer was adhered to.”

Request: GOC recommends that EnCana: 1. Specify whether access trails will avoid wetlands; 2. define the actions that will be taken for further avoidance and mitigation for those 54 wells which fall into 100 m setback buffers; 3. discuss how the mitigation proposed is expected to meet the Federal Policy on Wetland Conservation; 4. define the criteria and thresholds which will be used for the assessing possibility of wetland avoidance; 5. identify the potential impacts to vegetation, soils, vegetation and wetland VECs where wetland avoidance is not possible; and 6. specify the proposed mitigation where buffer distances may be reduced, and its assess its effectiveness.

Response: 1. Yes, access routes will avoid wetlands. Access trails will be no closer than 15m from a wetland with the standard practice being a 100m away setback distance. 2. EnCana will conduct a pre-disturbance assessment (PDA) to determine whether each well can be located 100m away from all wetlands. See the response to Terr 27. 3. The goal of mitigation associated with exceptional incursions into wetland setbacks (not into wetlands) would be the same as that of the Federal Policy on Wetland Conservation, specifically “no net loss of wetland function”. EnCana will locate wells no closer than 15m to any wetland and, in that case would have appropriate mitigation measures in place; therefore, it is not anticipated that there would be any loss of wetland function. 4. As this is a National Wildlife Area, EnCana will prioritize maintaining wildlife setbacks over wetlands setbacks (assuming the wetland doesn’t have any wildlife); therefore, wetland setback incursions will occur more frequently than incursions into other setbacks. EnCana’s methodology for surveying for 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-012 2 #Terr - 273 - B

wetlands is described in the response to Terr 161. 5. EnCana has assessed the potential effects of the Project on wetlands, including the potential of reducing the setback distance in exceptional circumstances. See Volume 3, Section 4.8. 6. Mitigation measures may include: • Soil erosion controls (see I.5.3. of the draft Environmental Protection Plan (EPP) in Volume 1, Appendix I); • Spill plans and procedures (see I.4 (para. 86-90) of the draft EPP in Volume 1, Appendix I); • Re-seeding of disturbed areas with spring, summer and fall monitoring to ensure successful reclamation and undesirable vegetation control; and • Undesirable vegetation control including mowing of tumbleweeds and wick application of herbicides, where necessary, prior to construction.

Reference: Volume 1, Appendix I. Draft Environmental Protection Plan. Page I-23 Volume 3, Section 4.8.2.1, Wetlands, pages 4-12, Volume 3, Section 5.8.2, Wildlife and Habitat VECs, pages 5-45 and 5-46

Preamble: The EPP states (point 134) “A buffer distance may be reduced in exceptional circumstances where resource extraction would be severely compromised and/or effects on the environment would be more adverse if the buffer was adhered to.” This is repeated in the “Construction Phase” sections for a number of the VECs in Volume 5 Section 5.8.3.

EnCana states “Wetlands will be avoided (well centre setback 100m) when ever possible; a buffer distance may be reduced in exceptional circumstances where resource extraction would be severely compromised and effects on the environment would be more adverse if the buffer were adhered to”. (Vol 3, page 4-12)

Request: To allow an assessment of whether the constraints mapping will be effective and make meaningful changes in the projects impact on VECs, the GOC recommends that EnCana provide: 1. Describe exceptional circumstances. 2. The threshold that will trigger exceptions to set backs and the need for well shifts.

Response: 1. Please refer to the response to Terr 27. 2. Please refer to the response to Terr 27.

Reference: Volume 3, Section 5.8.2, Page 5-46

Preamble: EnCana states “Buffers may be reduced in exceptional circumstances where resource extraction would be severely compromised and/or effects on the environment would be more adverse if the buffer was adhered to”.

Request: GOC recommends that EnCana clarify the term “compromise” in terms of degree of impediment to resource extraction and frequency which this may incur, and justify why EnCana believes environmental buffers can suffer incursions to an unknown degree and frequency while having no restrictions on resource extraction.

Response: Please refer to the responses to Terr 25 and 27.

Reference: Volume 3, Section 5.2 Introduction, Page 5-4

Preamble: EnCana states” The wildlife baseline information is derived from intensive field study conducted in 1994 to 1996 by the CWS, focused field surveys conducted by EnCana in 2006, habitat suitability ratings and literature review.”

Request: GOC recommends that EnCana: 1. Indicate literature sources which were used to derive habitat suitability ratings for snakes. 2. Provide the rationale for this rating process. 3. Provide a detailed description of habitat use both spatially and temporally, with consideration of snake occurrence and dispersal information from CWS 2000- 2002 assessments 4. Present impact concerns regarding both direct and indirect impacts from construction and operation, and. 5. Clarify how CWS assessment date was used.

Response: 1. A comprehensive literature search was conducted for each wildlife VEC. Key findings with respect to snake VEC status and habitat associations have been provided in Section 5.7.2.44 to 5.7.2.48.

2 The habitat suitability rating methodology is described in 5.7.1.1.

3. A comprehensive literature search was conducted for each wildlife VEC. Key findings with respect to snake VEC status and habitat associations have been provided in Sections 5.7.2.44 to 5.7.2.48.

4. Assessment of potential impacts on snakes is presented in sections 5.8.3.44 to 5.8.3.48.

5. CWS data was considered during the comprehensive literature search which was conducted for each wildlife VEC. Key findings with respect to snake VEC status, habitat associations, potential impacts of the project and proposed mitigation have been provided in Sections 5.7.2.44 to 5.7.2.48 and 5.8.3.44 to 5.8.3.48.

Reference: Volume 3, Section 5.3, Study Area Boundaries, Page 5-4

Preamble: EnCana uses the NWA and the LSA for descriptions of snakes as Valuable Ecological Components and assessments of impacts and proposed mitigation. Request: GOC recommends that EnCana include areas adjacent to the NWA, LSA and RSA that represent access corridors to the development area, and provide an assessment of the implications to regional populations of snakes.

Response: The Project interactions with snakes is primarily associated within the LSA and the RSA; therefore, EnCana has confined the assessment to these areas. As Box Spring Road is considered to be a potential source of snake mortality associated with the Project, EnCana has included this aspect into the evaluation of significance. EnCana has predicted that the Project effects on snakes are insignificant; therefore, the effect on the regional population is insignificant.

Reference: Volume 3, Section 5.6.2 Page 5-9

Preamble: EnCana states “Rather a detectable change in biological parameters was relied upon based on assessors’ experience and expertise along with consideration of potential effects on population viability.” and “Where quantification was not available (direct mortality, sensory disturbance, barriers to movement) the rating was based on the assessors’ experience and expertise, applicability of field surveys and scientific literature.”

Request: GOC recommends that EnCana provide a comprehensive description of the local and regional issue of snake mortality arising from traffic and associated persecution.

Response: Please see the response to Terr 267.

EnCana has reviewed the reports provided by the CWS as part of determining the effects of the Project on snakes. As is discussed in section 5.8.3.44 to 5.8.3.53 of Volume 3, the Project is predicted to have negligible to insignificant effects on snakes. The assessment of the effects of the Project on wildlife and wildlife habitat was made in the context of five major areas of conservation biology: direct habitat loss and alteration; sensory disturbance and effective habitat loss; habitat fragmentation; direction mortality; and, barriers to movement (see section 5.8.2). Therefore, snake mortality due to Project effects was evaluated for all phases of the Project.

EnCana is not aware of persecution of snakes being an issue in the RSA. EnCana has taken special precautions to reduce snake mortality including closing a road where snake mortality was an issue. In 2006, EnCana hired a snake researcher to monitor the snake migration so are to reduce the effects of gas activities on snakes. Section 5.8.2 (pg 5-46) discusses the extensive mitigation measures to prevent snake mortality, particularly during the snake migration period.

Additionally, EnCana has committed to consulting with other stakeholders regarding snake mortality on Box Spring Road and working with the DND regarding snake mortality on CFB Suffield.

Reference: Volume 3, Section 5.8.1, Page 5-44

Preamble: EnCana states under the topic Direct Mortality that “Potential for mortality due to entrapment in below ground caissons will be eliminated by installing all wellheads above ground” Request: GOC recommends that EnCana identify the current impact of existing ground caissons on the mortality of snake populations. Response: The Project is not proposing to use caissons. The cumulative effects of past gas development and other past, current and future land uses on wildlife are considered in Volume 3, Section 7.3.

Reference: Volume 3, Section 5.8.1, Page 5-44, 42

Preamble: EnCana states under the topic Direct Mortality that “Potential for mortality due to collisions with vehicles exists. EnCana will minimize this potential by restricting speeds in the NWA to 70 kph from 15 October – 15 April, 50 kph from 15 April to 15 October, educating personnel to be alert to avoid collisions with wildlife, confining drilling, completion and decommissioning to 15 October – 15 April when most susceptible wildlife is inactive or not present and accessing the NWA using single primary access routes established as required during construction (they and existing access will be used throughout the Project, no random access).”

EnCana states under the topic Direct Habitat Loss and Alteration that “Species persistence is related to its ability to withstand and recover from disturbances either anthropogenic or natural. Any loss in population size increases vulnerability to stochastic events and proportionally increases the chances of population extinction.”

EnCana states under the topic Direct Mortality that “Increased mortality, whether caused directly or indirectly, is a concern for species that have naturally low reproductive rates and limited ability to rebound from population losses. In contrast, increased mortality is less of a concern for species that have high reproductive rates and can repopulate relatively quickly.”

EnCana has not provided a comprehensive presentation of the primary impact of the proposed development upon snake populations within the NWA and adjacent LSA – mortality of snakes from traffic and associated persecution with this traffic.

Request: GOC recommends that EnCana describe the impacts to snakes from traffic and persecution and other activities which can be expected to arise from the project, using extensive literature addressing this issue and information from the history of addressing of this issue by EnCana, DND, CWS and the government of Alberta, using the biological data from CWS assessments of this issue on the NWA and the LSA and adjacent areas.

Response: EnCana has reviewed the reports provided by the CWS as part of determining the effects of the Project on snakes. As is discussed in section 5.8.3.44 to 5.8.3.53 of Volume 3, the Project is predicted to have negligible to insignificant effects on snakes. The assessment of the effects of the Project on wildlife and wildlife habitat was made in the context of five major areas of conservation biology: direct habitat loss and alteration; sensory disturbance and effective habitat loss; habitat fragmentation; 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-012 2 #Terr - 286 - A

direction mortality; and, barriers to movement (see section 5.8.2). Therefore, snake mortality due to Project effects was evaluated for all phases of the Project.

EnCana is not aware of persecution of snakes being an issue in the RSA. EnCana has taken special precautions at Suffield to reduce snake mortality. For example, EnCana closed a road where snake mortality was known to occur. Further, in 2006, EnCana hired a snake researcher to monitor snake migration with the intention of attempting to reduce the effects of gas activities on snakes. Section 5.8.2 (pg 5-46) discusses the extensive mitigation measures to prevent snake mortality, particularly during the snake migration period.

Additionally, EnCana has committed to consulting with other stakeholders regarding snake mortality on Box Spring Road and working with the DND regarding snake mortality on CFB Suffield.

Reference: Volume 3, Section 5.8.2, Page 5-45

Preamble: EnCana states “Pipeline construction will be restricted to October 1 to April 15; pipeline construction from October 1 to 15 will be spider plough only and will be restricted to the western portion of the NWA. Decommissioning (non-reclamation portion) will be restricted to October 15 to April 15.”

Request: GOC recommends that EnCana discuss anticipated additive mortality of snakes from construction and operation of well sites within the LSA adjacent to the NWA due to dispersal of snakes. Address anticipated additive mortality of snakes from operation of well sites year round within the NWA, and describe proposed mitigation measures.

Response: Please see the responses to Terr 267, Terr 279, and Terr 292.

Additionally, EnCana has committed to consulting with other stakeholders regarding snake mortality on Box Spring Road and working with the DND regarding snake mortality on CFB Suffield.

Reference: Volume 3, Section 5.8.2, Page 5-46

Preamble: EnCana states “In addition to those measures identified above, the following mitigation measures will be implemented to minimize project effects on snakes: Between 15 April and 15 October within the high risk snake area (east of Bingville and Fox Roads), the following measures will be taken: • all vehicles from south of CFB Suffield to enter via Bingville Gate • Bingville Rd will be the primary access route from Bingville Gate to Antelope Rd • Fox Rd will be the primary access route from Kangaroo Rat Rd to Antelope Rd • no grading or mowing of ROWs (access routes and pipelines) except where required as an undesirable vegetation control measure, the mowing area will be checked by a qualified representative to ensure that no snakes or other wildlife are present • grading of roads to be undertaken only with an environmental inspector • accompanying vehicles working E of Bingville Rd or Fox Rd will use E-W access as much as possible • vehicle speeds restricted to 50 kph • EnCana will collaborate with other stakeholders (FWD, PFRA, local ranchers) on strategies to reduce snake mortality on Box Springs Rd including the possibility of fencing to encourage snakes to cross through culverts • Workers (including grader operators) will be educated and required to be alert to avoid snakes on roads, both within and outside the NWA”

Request: GOC recommends that EnCana: 1. Describe the implementation plan for each proposed mitigation measure, and an assessment of the potential for success of each mitigation measure. 2. Examine and describe the history of addressing mortality of snakes on Box Springs Road by EnCana, DND, CWS and the government of Alberta. 3. Utilize the biological data available from CWS assessments and the government of Alberta regarding the magnitude, location and timing of observed mortality, to provide an assessment of relative potential of success for proposed mitigation measures to eliminate or minimize snake mortality on these access roads adjacent to the NWA and LSA.

Response: Please see the response to Terr 286.

Reference: Volume 3, Sections 5.8.3.44 to 5.8.3.48 Pages 5-116, 5-119, 5-120, 5-122, 5-124

Preamble: EnCana states Page 5-116 western hognose snake “The effect of snake mortality due to entrapment in to caissons is likely low but warrants further study (Didiuk 1999)”.” EnCana presents the same statement of a source of mortality for the bullsnake Page 5- 118, wandering garter snake Page 5-120, plains garter snake Page 5-121, and prairie rattlesnake Page 5-123 with observations of rattlesnakes in caissons during EnCana’s 2006 surveys.

Request: GOC recommends that EnCana address the impacts of caissons on snake mortality.

Response: Please see the response to Terr 285.

Reference: Volume 3, Sections 5.8.3.44 to 5.8.3.48 Pages 5-117, 5-119, 5-120, 5-122, 5-124

Preamble: EnCana states Page 5-116 “Trenching during pipeline construction can also cause mortality although less so than with rattlesnakes and bullsnakes because of the western hognose snake’s sedentary nature (Wright and Didiuk 1998).” EnCana does not specifically address this issue for the other four species of snakes when addressing the environmental effects on valued ecological components by project Pages 5-117 to 5-124.

Request: GOC recommends that EnCana assess the potential for additive mortality of snakes from entrapment in open trenches, and describe mitigation measures.

Response: The potential for snakes to be entrapped in open trenches during pipeline construction was implicitly considered during impact assessment. Mitigation of this potential effect is presented in section 5.8.2 and includes:

• Pipeline construction will be restricted to October 1 to April 15; pipeline construction from October 1 to 15 will be restricted to the western portion of the NWA • All well tie-in pipelines will be installed using the low impact spyder plough or chain trencher; loop lines will be trenched with limited (2 to 4 m) disturbance.

Pipelining that results in an open trench will be undertaken only when the chances of a snake being entrapped are remote.

Reference: Volume 3, Sections 5.8.3.44 to 5.8.3.48 Pages 5-117, 5-119, 5-120, 5-122, 5-124

Preamble: EnCana states Page 5-119 “Residual environmental effects of the Project on the western hognose snake are rated as insignificant/negligible assuming successful implementation of mitigation measures as outlined above.” and makes the same statement for the bullsnake Page 5-120, the wandering garter snake Page 5-121, the plains garter snake Page 5-123, and the prairie rattlesnake Pge 5-125.

Request: GOC recommends EnCana describe the impacts to snake populations from additive mortality from activities associated with the project, particularly additive mortality arising from traffic and persecution, and describe mitigation measures.

Response: Please see the responses to Terr 267, Terr 279, and Terr 286.

Reference: Volume 3, Section 5.9, Pages 5-125 to 5-126

Preamble: EnCana states Page 5-125 “The cumulative effect of the Project on wildlife cumulative assessment VECs in combination with increased military training and infill drilling in the MTA is rated as insignificant …” and Page 5-126 “Attempt to work cooperatively with CWS and DND to understand the additive effect of increased military training on snake mortality and develop a cooperative cumulative mortality management plan.”:

Request: GOC recommends that EnCana provide an assessment of the potential impacts of current and proposed EnCana activities upon snakes, and provide a detailed description of the mitigation procedures.

Response: Please see the responses to Terr 267, Terr 279, and Terr 286.

Reference: Volume 3, Section 5.9, Pages 5-125 to 5-126

Preamble: EnCana states Page 5-125 “The cumulative effect of the Project on wildlife cumulative assessment VECs in combination with increased military training and infill drilling in the MTA is rated as insignificant …The disturbance footprint associated with the Project when added to the existing footprint from past land actions in the NWA is cumulatively less than 5 percent for all but two cover types in the NWA. Average cumulative footprint for individual cover types is 1.0 percent and 2.4 percent for the north and south portions of the NWA respectively. The two cover types will be avoided, where possible, during the pre-planning phase of the Project.”

Request: GOC recommends that EnCana clarify how dispersal behaviour and demographics of snakes was considered in the cumulative effects assessment for snakes. Response: No additional consideration of dispersal behaviour and demographics of snakes were included in the cumulative effects assessment beyond what was in the impact assessment. The methodology for the cumulative effects assessment was to assess the potential cumulative effects of the four cumulative land use interactions on wildlife as a whole not as individual species.

Cumulative sources of mortality are the dominant factor influencing snake population sustainability. The effect of snake mortality was rated as insignificant.

Reference: Volume 3, Section 5.10, Page 5-126

Preamble: EnCana states Page 5-126 “The following cooperative monitoring efforts are recommended: EnCana continue to monitor wildlife mortality due to collisions with vehicles particularly snakes during routine operations from 15 April to 15 October.

Request: GOC recommends that EnCana provide the details to avoid or minimize additive mortality of snakes during the construction and operation of the project. Response: Please see the responses to Terr 267, Terr 279, Terr 286 and Terr 292.

Reference: Volume 3, Section 5.8.3.44 , Pages 5-116 to 5-117

Preamble: EnCana states Page 5-116 “The primary effect of oil gas activity is likely from vehicular traffic on existing roads and on roads created during well and pipeline construction (Wright and Didiuk 1998).”

EnCana does not indicate traffic to be a concern for the operations phase on Page 5-116 but indicates this to be a source of direct mortality under the topic Operations Phase on Page 5-117. EnCana indicates observations of western hognose snakes on roads during their 2006 assessments on Page 5-116.

Request: GOC recommends that EnCana describe the impacts to the western hognose snake based on its known or expected distribution in the NWA and adjacent LSA, its movement and demographic characteristics and vulnerability to additive mortality from traffic and persecution and other effects from the proposed development, and describe proposed mitigation measures.

Response: Please see the response to Terr 286.

Reference: Volume 3, Section 5.8.3.45 , Pages 5-118 to 5-119

Preamble: EnCana states Page 5-118 “The bullsnake is threatened by traffic mortality, direct persecution and habitat loss.” and Page 5-119 “Effects associated with the operations phase are mainly related to sensory disturbance and effective habitat loss, and direct mortality (e.g., as a result of vehicle collisions). EnCana indicates observations of bullsnakes on roads during their 2006 assessments on Page 5-116.

EnCana indicates mortality from traffic is a threat to the species. EnCana proposes mitigation measures within the NWA during the construction period however not for the adjacent LSA where construction will occur throughout the year and where there is dispersal of bullsnakes from the adjacent NWA.

Request: GOC recommends EnCana describe the impacts to the bullsnake based on: its known or expected distribution ands movement patterns in the NWA and adjacent LSA from CWS assessments and other information available; demographic characteristics and vulnerability to additive mortality from traffic and persecution and other effects from the proposed development; the history of addressing this concern on the NWA and adjacent LSA by EnCana, DND, CWS and the government of Alberta; and describe proposed mitigation measures.

Response: Please see the response to Terr 286.

Reference: Volume 3, Section 5.8.3.46 Pages 5-120 to 5-121

Preamble: EnCana states Page 5-120 “Project construction activities may result in effects associated with three of the five potential issues described in Section 5.8.1:… direct mortality” and Page 5-120 “Effects associated with the operations phase are mainly related to sensory disturbance and effective habitat loss, and direct mortality (e.g., as a result of vehicle collisions).”

Request: GOC recommends EnCana describe the impacts to the wandering garter snake based on: its known or expected distribution ands movement patterns in the NWA and adjacent LSA from CWS assessments and other information available; demographic characteristics and vulnerability to additive mortality from traffic and persecution and other effects from the proposed development; the history of addressing this concern on the NWA and adjacent LSA by EnCana, DND, CWS and the government of Alberta; and describe proposed mitigation measures.

Response: Please see the response to Terr 286.

Reference: Volume 3, Section 5.8.3.47 Pages 5-121 to 5-123 Volume 3, Section 5.8.3.47 Table 5-52 Page 5-123 Preamble: EnCana states Page 5-121 “Project construction activities may result in effects associated with three of the five potential issues described in Section 5.8.1:…direct mortality” and Page 5-122 “Effects associated with the operations phase are mainly related to sensory disturbance and effective habitat loss, and direct mortality (e.g., as a result of vehicle collisions”. EnCana Page 5-121 indicates plains garter snakes were found on roads during EnCana’s 2006 surveys.

Various ratings applied to criteria in the Table entitled Summary of Residual Environmental Effects on the plains garter snake Table 5-52 Page 5-123 :

Request: GOC recommends that EnCana describe the impacts to the plains garter snake based on: its known or expected distribution ands movement patterns in the NWA and adjacent LSA from CWS assessments and other information available; demographic characteristics and vulnerability to additive mortality from traffic and persecution and other effects from the proposed development; the history of addressing this concern on the NWA and adjacent LSA by EnCana, DND, CWS and the government of Alberta; and describe proposed mitigation measures.

Response: Please see the response to Terr 286.

Reference: Volume 3, Section 5.8.3.48, Pages 5-123 to 5-125 Volume 3, Section 5.8.3.48, Table 5-53, Page 5-125 Preamble: EnCana states Page 5-123 “Although it appears that the number of rattlesnakes has declined in Suffield from 1995 through 2001, particularly the larger and longer dispersing cohort, it is unclear what the causes are. However it is prudent to assume that mortality due to traffic may be a contributing factor (Didiuk 2003).” EnCana Page 5-123 indicates that prairie rattlesnakes were found on roads during EnCana’s 2006 surveys.

Request: GOC recommends that EnCana describe the impacts to the prairie rattlesnake, with a particular focus on the effects of increased traffic and existing traffic and other activities upon long term population effects upon the species, by examining the history of attempts to address this issue at CFB Suffield and Suffield NWA, by using relevant biological information from CWS assessments.

Response: Please see the response to Terr 286.

Reference: Volume 3, Section 5.8.3.34, Ord’s Kangaroo Rat, Pages 5-100.

Preamble: EnCana states, “...mitigation presented in Section 5.8.2 will be implemented, as applicable, to minimize environmental effects on this VEC.” EnCana has not provided which mitigation measures presented in Section 5.8.2 will be implemented to minimize environmental effects on this VEC. This information is missing for the remaining small mammal VECs.

Request: GOC recommends that EnCana describe the species specific mitigation measures, including those presented in Section 5.8.2, that will be implemented to minimize environmental effects from the Construction and Operations phase of this development on Ord’s Kangaroo Rat, Western small-footed bat, Olive-backed Pocket mouse, Long- tailed weasel, American Badger, Bobcat, Richardson’s ground squirrel, and the Small Mammal Prey VEC.

Response: Of the mitigation measures listed in Section 5.8.2, the following will specifically minimize effects on Ord’s Kangaroo Rat and other mammal species listed. • Avoidance of wetlands (Long-tailed Weasel) • No pipelines or wells in the South Saskatchewan River valley (Long-tailed Weasel, Bobcat, small mammal prey, Olive-backed Pocket mouse, Western small-footed bat) • Drilling, completion and decommissioning restricted to October 15 to April 15 (Ord’s Kangaroo rat, Western Small Footed Bat) • Drilling and waste removed from NWA (all species) • Vehicle speeds restricted to under 70 km/h. Speed is restricted to 50 km/h in the high risk snake area from April 15 to October 15 (all species) • Minimal disturbance plowing and trenching (all species) • Single primary access routes (all species)

Reference: Volume 3, Section 5.8.3.34, Ord’s Kangaroo Rat, Table 5-39, Pages 5-100 – 5-101.

Preamble: Encana states, “Residual environmental effects of the Project on Ord’s Kangaroo Rat are rated as insignificant assuming successful implementation of mitigative measures as outlined above.” The NWA includes a large amount of critical habitat for this endangered species and EnCana does not indicate how it will avoid impacting these areas.

Request: GOC recommends that EnCana provide a detailed description and assessment of how Encana plans to avoid impacting Critical Habitat (CH) for this important VEC (Ord’s Kangaroo Rat) and other SAR and rare small mammals, the Western Harvest Mouse and the Olive-backed Pocket Mouse.

Response: Please see the responses to Terr 96 and Terr 256. When EnCana conducts PDAs, biologists survey for sensitive environmental features including denning sites for Ord’s Kangaroo Rat. At this time, EnCana is not aware of any critical habitat being identified in recovery strategies to date for the Ord’s Kangaroo Rat, the Western Harvest Mouse and the Olive-backed Pocket Mouse. Once critical habitat is identified, EnCana will incorporate same into its siting process.

The environmental assessment of these VECs included a consideration of the potential to impact critical habitat.

Reference: Volume 3, Section 5.8.3.34, Page 5-99.

Preamble: EnCana concludes that winter construction activities will minimize effects on the kangaroo rat. Request: GOC recommends that EnCana discuss in detail how winter construction activities will minimize effects on the kangaroo rat. Describe how EnCana will incorporate and implement setback distances.

Response: Please see the response to Terr 256. EnCana’s experience at CFB Suffield indicates that properly mitigated construction activities in the winter will have insignificant effects on Ord’s Kangaroo Rats. See Gummer and Robertson (2003) for a discussion of the effects of pipeline construction on Ord’s Kangaroo Rats.

Reference: Appendix 5J, Breeding Bird Survey, Section 5J.2, Page 5J-3, page 5J-4 Section 6, Biodiversity, Section 6.8.2 relies on results from Section 5 Preamble: EnCana states (page 5J-3) “Surveys were done under low wind conditions, with no significant precipitation. All birds seen or heard were noted and interpreted as within or outside the 100-m survey radius.”

Request: To substantiate conclusions based on data collected with these methods in Sections 5 and 6 the GOC recommends that EnCana provide: 1. Criteria used to determine “where appropriate”. 2. Describe “low wind” and “significant precipitation”. 3. A description of how the 100 m radius was determined in the field and the training or techniques used to establish the location of birds relative to the 100 m radius.

Response: 1. EnCana is not certain what the information request refers to as the words “where appropriate” are not utilized in appendix 5J or Volume 3, section 6.8.2.

2. Low wind was considered to be <15 kph and significant precipitation was considered to be any steady precipitation.

3. Birds were ascribed to the 100 m radius based on the significant experience of the observers, all of whom were senior personnel (> 20 years experience) who have specialized in issues relative to birds (including auditory recognition). As discussed in section 5.J.2 potential variation in the ability of observers to correctly determine the 100 m radius in the field and any other bias was minimized by confining individual observers to different well density treatments within the same unique conditions.

Reference: Volume 3, Section 5.6.5.2 Breeding Bird Survey, Page 5-13

Preamble: EnCana conducted point count surveys which are ineffective for detecting and estimating distribution and abundance of the prairie loggerhead shrike, did not utilize existing CWS assessments of shrike occurrence and distribution in the Middle Sandhills, and did not address the limitations of a one-year survey in terms of inter- year variation in abundance.

Request: Species specific surveys for loggerhead shrikes are required. GOC recommends that EnCana undertake these surveys for a meaningful evaluation of impacts and mitigation measures.

Response: Specific surveys, prior to PDAs, are not required to evaluate the effects of the Project on Loggerhead Shrikes as the PDAs will identify breeding sites and establish appropriate setbacks (please see the response to Terr 96). EnCana will utilize a setback distance of 250m except in exceptional circumstances where resource extraction would be severely compromised and effects on the environment would be more adverse if the setback was adhered to. Key findings with respect to potential impacts of the project on the Loggerhead Shrike and proposed mitigation have been provided in Sections 5.8.1, 5.8.2 and 5.8.3.24.

Reference: Volume 3, Section 5.8.1, Page 5-42

Preamble: EnCana describes a range of sources of sensory disturbance, many of which are applicable to the prairie loggerhead shrike. EnCana does not provide an assessment of how some or most of these might be applicable to shrikes, and does not indicate if the proposed 250 m buffer will be appropriate protection for this species, particularly in the major breeding area in the Middle Sandhills.

Request: GOC recommends that EnCana describe the relative risk of these potential sensory disturbances to the prairie loggerhead shrike in the Middle Sandhills during the breeding season and during operation of the project.

Response: A comprehensive literature review was conducted for each wildlife VEC including the Loggerhead Shrike. Key findings with respect to potential impacts of the Project on the Loggerhead Shrike and proposed mitigation have been provided in Sections 5.8.1, 5.8.2 and 5.8.3.24. PDAs will be undertaken to identify Loggerhead Shrike breeding sites and a 250m setback established except in exceptional circumstances (see Terr- 316). The setback distance will reduce any potential sensory disturbance to the Loggerhead Shrike during the breeding season. Operational activities will be occasional and thus unlikely to result in sensory disturbance. Operational activities are predicted to have negligible effects on Loggerhead Shrikes.

Reference: Volume 3, Section 5.8.1, Page 5-43

Preamble: EnCana states “Sensory disturbance and resultant reduction in effective habitat was quantified by applying disturbance buffers (Section 5.7.1.1) to major facilities and reducing habitat suitability ratings within the buffer. This approach was necessary only within the RSA outside the NWA as no major facilities are, or will be, located within the NWA

Request: GOC recommends that EnCana provide an assessment of the potential effects of operations activity upon breeding shrikes in the Middle Sandhills.

Response: EnCana assessed the potential effects of the operations phase upon loggerhead shrikes in Volume 3, section 5.8.3.24. The potential project effects on wildlife and habitat were assessed within the context of five major conservation biology issues: • direct habitat loss and alteration • sensory disturbance and effective habitat loss • habitat fragmentation • direct mortality • barriers to movement The Middle Sandhills region is part of the LSA as is described in Volume 3, Section 1.2.

Reference: Volume 3 Appendix 3F, Well and Pipeline Projections based on Constraints, Section 3F.2.4.7 and 3F.2.4.8, page 3F-5 Volume 3, Section 5.8.3, pages 5-46 to 5-125

Preamble: EnCana states in Section 3F.2.4.7 “Some constraints provided by the discipline leads were either too general or too spatially prohibitive to completely restrict access.” Such constraints were assigned as avoidance rather than exclusion. EnCana asserts repeatedly (for most Wildlife VEC) in Section 5.8.3 that cumulative effects are negligible assuming mitigation is applied.

Request: In order to understand how mitigation has been applied in the Project constraints planning, the GOC recommends that EnCana provide: 1. A table which includes all wildlife VECs. For each VEC include the set back distance applied, its source and whether it was applied as an avoidance or exclusion or both. 2. Justification for why constraints considered only winter construction. 3. For each VEC provide the number of occurrence that were supplied for the constraints mapping, their source, and the number of occurrences which had avoidance or exclusion constraints applied, the date range for which they were applied.

Response: 1. Please see Volume 3 Section 5 Table 5-1 for a list of all VECs. For setback distances applied to each VEC, see Table 5-5. For those species not listed in Table 5-5, a setback distance has not been applied.*** Please see the table produced below for avoidance or exclusion constraints.

2. The Executive Summary of the EIS lists key mitigation strategies to avoid or minimize the environmental effects of the Project, which include constraint avoidance through pre-planning and avoidance of sensitive locations and timing periods. With these strategies as guiding paradigms, sensitive time periods were identified in order for appropriate constraints to be applied, resulting in the winter construction constraints.

3. The provided table illustrates the wildlife VECs included in the constraint mapping, their source, the number of occurrences for each, their avoidance status, and the season which they apply. Other wildlife VECs as listed in Section 5.8.2 were not included in cases where no spatial data or location existed (ie. No known occurrence). Species were included in the table below multiple times where multiple sources of data existed for the same species. 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-012 2 #Terr - 324 - A

Buffer Number of Wildlife Species Size Occurrences Source Constraint Season Compiled by Burrowing Owl 250 3 DND1 Avoid Winter Burrowing Owl nest 500 4 URSUS 20062 Avoid Winter Burrowing Owl nest 500 3 CWS 20063 Avoid Winter Burrowing Owl site 500 15 FWMIS 20054 Avoid Winter Compiled by Ferruginous Hawk 1000 21 DND1 Avoid Winter Ferruginous Hawk nest 1000 2 URSUS 20062 Avoid Winter Compiled by Great Plains Toad 150 23 DND1 Avoid Winter Loggerhead Shrike nest 250 1 URSUS 20062 Avoid Winter Northern Leopord Compiled by Frog 150 4 DND1 Avoid Winter Compiled by Ord's Kangaroo Rat 250 578 DND1 Exclude Winter University of Ord's Kangaroo Rat 250 37 Calgary5 Exclude Winter Compiled by Prairie Rattlesnake 150 10 DND1 Avoid Winter Sharp Tailed Compiled by Grouse Lek 500 22 DND1 Avoid Winter Short-eared Owl nest 400 1 URSUS 20062 Avoid Spring Only Swainson’s Hawk nest 100 3 URSUS 20062 Avoid Winter

***Sources: 1 – DND. These locations were provided by DND. Only the species, location, and buffer were provided (i.e. no dates). 2 – URSUS 2006. This data is directly out of EnCana’s 2006 Avian sampling program. 3 – CWS 2006. This data was provided by Ursus Ecosystem Management Ltd. and includes CWS sampling points which were revisited in 2006. 4 – FWMIS. This data was also provided by Ursus Ecosystem Management Ltd. 5 – University of Calgary. This dataset came from Dr. Darren Bender at the University of Calgary out of their Ord’s Kangaroo Rat long term monitoring and study sites. 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-012 1 #Terr - 325 - A

Reference: Volume 3, Section 5.8.1, Page 5-44

Preamble: EnCana states under the topic Direct Mortality that “Fire is a possible source of mortality but confining drilling, completions and most of the pipeline installation to winter will minimize the potential effect. In any event EnCana personnel are trained in fire prevention and fighting and carry fire-fighting equipment with them in the field at all times”.

Request: GOC recommends that EnCana describe the effects of fire during longterm operations, including loss of shrub regrowth, loss of recruitment spatial and temporal aspects of dispersal of snakes, Shrikes and all other shrub associated VEC species.

Response: Please see the responses to Terr 343 and Terr 10. The effects of fire on wildlife are inherently considered in the assessment of wildlife VECs.

Reference: Volume 3, Section 6.1, Table, Pages 6-1 to 6-2

Preamble: EnCana states Page 6-1 “Conservation of habitat diversity requires that the identity, relative abundance, frequency, and richness of wildlife and plant species groups remains similar (within the range of natural variability) during all phases of the Project (Noss 1997).” and Page 6-1 ”Results showed that for the vast majority of habitat types, dominant species and total native plant species occurrence, cover and richness did not vary significantly between quarter sections with either 8 or 16 wps. Based on the above empirical data, biodiversity analyses, localized project footprint and mitigation measures, it is concluded that the effects of the Project on habitat diversity will likely be negligible.”

EnCana states the requirement for relative abundance, frequency and richness of wildlife species remains similar but their assessment does not address direct mortality and other effects upon population trends (e.g. additive mortality of snakes due to traffic, persecution and other activities during construction and operation of the project).

Request: GOC recommends that EnCana provide an assessment that addresses direct mortality and other effects upon population trends. Response: EnCana has assessed wildlife VECs in the context of five areas of conservation biology including mortality. See Volume 3, Section 5.8.

Reference: Volume 3, Section 6.6.1, Pages 6-3 to 6-4

Preamble: EnCana Page 6-4 indicates the spatial distribution measures of herptiles was an example of the data collected to address biodiversity. Request: GOC recommends that EnCana provide a detailed assessment of the potential occurrence of amphibian and reptile species in specific cover types based on habitat use information. Response: See response to Terr – 333.

Reference: Volume 3, Section 6.8.2 Page 6-6

Preamble: EnCana states Page 6-6 “Conservation of species diversity requires that populations are maintained in sizes and distributions that assure long-term population viability (Noss 1997). Listed species are components of biodiversity that are inherently most vulnerable to species-level effects.

Assessments of the environmental effects of the Project on 32 rare plant species and 46 vertebrate listed species were completed in Sections 3.6 and 5.7. Both assessments concluded that residual environmental effects of the Project on rare plants and listed species were insignificant or negligible. Hence it is concluded that effects of the Project on species level biodiversity are also insignificant or negligible.”

Request: GOC recommends that EnCana provide a detailed assessment of the potential occurrence and importance of specific cover types for amphibians and reptiles, and effectively address the importance of anticipated additive mortality of snakes from traffic and persecution and other activities.

Response: EnCana has identified the high suitability habitat for each VEC (listed species). EnCana has determined that the Project will have less than 0.2% loss of high suitability habitat for each herptile species. Therefore, a detailed assessment of the potential occurrence and importance of specific vegetation cover types is not necessary. PDAs will identify amphibian breeding areas and snake hibernaculas.

Reference: Volume 3, Section 6.8.3 Page 6-6

Preamble: EnCana states “Conservation of habitat diversity requires that the identity, relative abundance, frequency, and richness of wildlife and plant species groups remains similar (within the range of natural variability) during all phases of the Project (Noss 1997).” and “Based on the above empirical data, biodiversity analyses, small project footprint and mitigation measures, it is concluded that the effects of the Project on habitat diversity will likely be negligible.”

Request: GOC recommends that EnCana provide an assessment of the potential occurrence and importance of specific cover types for amphibians and reptiles. Response: Please see the response to Terr 333.

Reference: Volume 3, Section 3.9, Vegetation, page 3-30 Volume 3, Section 4.10, Wetlands, page 4-19 Volume 3, Section 5.10, Wildlife and Habitat, page 5-126 Volume 3, Section 6.10, Biodiversity, page 6-8

Preamble: These sections discuss follow-up and monitoring, and propose continuation of some aspects of the original assessment but are lacking in detail as to sample size, timing, and justification for which surveys were selected.

Request: GOC recommends that EnCana: 1. State the purpose of the monitoring and follow up program. 2. Describe sample sizes for paired-pipeline follow up; a detailed description of the proposed range health/ecosystem function monitoring; a time post- construction that monitoring will begin; and a justification for why project footprint size will not be monitored immediately post-construction in the first year so that any discrepancies between predicted and realized footprint can be addressed. 3. Provide justification for why avoidance constraint effectiveness and project footprint size will not be monitored immediately post-construction in the first year. 4. Describe details on the number of years of monitoring and when each monitoring project will be initiated; a justification for why avoidance constraint effectiveness and project footprint will not be monitored immediately post- construction in the first year, and a justification for why no avian survey follow up is included.

Response: 1. See Volume 1, Section 4.7.

2-4. See the response to Terr 17.

Reference: Volume 3, Section 9.2, Page 9-1

Preamble: EnCana states that “Severe weather is an important consideration in wellsite design, construction, operation, and decommissioning and abandonment. Severe weather over the Prairies generally consists of blizzards, thunderstorms and lightning, heavy precipitation, and tornadoes.”

Request: GOC recommends that EnCana: 1. discuss the effect of drought on all phases of the Project, and how it will address such factors as increased erosion potential, failure of mitigation measures to prevent erosion, and reclamation failure; 2. detail the effect of Chinooks on the Project during frozen ground conditions, how it will address such factors as thawed and saturated soils, increased soil and vegetation sensitivities, and poor vehicle access conditions: 3. and how potential delays in construction and access will be addressed.

Response: 1. Mitigation measures being unsuccessful is unlikely as a result of drought. Drought may increase the length of time that may be required for disturbances to recover and may also increase the number of mitigation measures used to prevent erosion. Recovery of disturbances will be evaluated against the expected trajectories of recovery in recognition of the climatic conditions. Recovery will be ongoing for the life of the development. By continuously reclaiming the disturbed area, it is anticipated that, by the end of life of the Project, there will be very minimal reclamation work required. Mitigation measures required for the increased erosion potential associated with drought will be implemented according to the erosion control section of the EPP (Volume 1, Section I.5.3, page I-20).

2. Chinooks (if severe enough to thaw the ground) will be responded to in the same manner as outlined in the wet weather shutdown section of the EPP (Volume 1, Section I.5.1, page I-17).

3. EnCana is prepared to work around interruptions due to inclement weather. The wet weather shutdown approach will be adhered to. Despite constraining construction activities to dormant conditions within a three construction season timeframe, EnCana is confident the Project can be conducted within the time allotted allowing for inclement weather.

Reference: Volume 3, Section 9.2, Page 9-1

Preamble: EnCana states that “Severe wind or precipitation events are not likely to cause adverse effects on the Project; however, the EPP contains guidance for EnCana staff and contractors regarding activities during heavy precipitation events in order to protect soil and vegetation during wet conditions. Where severe weather conditions have the potential to, or are causing, wind erosion or water erosion, EnCana’s Environmental Inspector will take appropriate action to prevent or mitigate any potential adverse effects. Such action may include suspension or modification of specific activities until weather conditions aBASe or effective mitigation procedures have been implemented.”

Request: GOC recommends that EnCana: 1. provide the specific criteria and threshold values EnCana will use in identifying severe weather, including heavy precipitation, and how it will ensure the protection of soil and vegetation resources during wet conditions; 2. identify the specific actions which it will take to prevent or mitigate potential adverse effects of severe weather; 3. identify the specific activities which will be suspended or modified in the event of severe weather; and 4. identify the frequency of monitoring which will be carried out by the Environmental Inspector to mitigate and prevent adverse effects of extreme weather events.

Response: 1. The Wet Weather Shutdown protocols are in the Environmental Protection Plan (Volume 1, Appendix I, Section I.5.1, pg I-17). The EPP contains the criteria EnCana will use to ensure the protection of soil and vegetation. 2. The primary action EnCana will take to prevent the potential effects of severe weather is to shut down and wait for appropriate working conditions. EnCana will ensure disturbances are reclaimed promptly so vegetation growth will minimize erosion potential. 3. All activities may be suspended pending the severity of the weather. All activities will be evaluated independently pending their potential for damage given the severity of the weather event. Access will generally be phased in after a severe weather event, starting with light footprint traffic (i.e. quads) and progressing to the heavier footprint traffic (i.e. drilling rigs and completions trucks). 4. Environmental inspectors will be onsite, working with the construction crews to ensure good field based decision making. Weather forecasts will be checked regularly by construction coordinators when forecasts are favorable and in real 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-012 2 #Terr – 337 - A

time when there is a threat of severe weather.

Reference: Volume 3, Section 9, Pages 9-1 to 9-3

Preamble: EnCana references several articles in Volume 3, Section 9, which are not provided in Section 10 References.

Request: GOC recommends that EnCana provide references for the articles cited.

Response: The following missing references from Volume 3, Section 9 are as follows:

Adams, G. D., A. B. Didiuk, and I. D. MacDonald. 1998. Wetlands component report: Canadian Forces Base Suffield National Wildlife Area – Wildlife Inventory. Canadian Wildlife Service, Environment Canada, Prairie and Northern Region. Saskatoon, SK. 37 pp.

Alberta Environment. 2007. Alberta’s Climate Change Facts Book. Available at: http://www3.gov.ab.ca/env/climate/docs/Fact_Book.pdf

Alberta Fish and Wildlife. 1985. A policy for the management of threatened wildlife in Alberta. Alberta Fish and Wildlife, Edmonton, AB. 34 pp.

Alberta Water Resources Commission. 1993. Wetland management in the settled areas of Alberta: An interim policy.

Coote, D.R., and W.W. Pettapiece. 1987. Wind erosion risk, Alberta. Canada-Alberta Soil Inventory. Land Resoure Research Centre, Research Branch, Agriculture Canada. Contribution Number 87-08. Publication 5255/B. 11 pp. + expanded legend and map.

Environment Canada. 1990. The Climates of Canada. Minister of Supply and Services Canada. Canadian Government Publishing Centre, Ottawa, Ontario, Canada. 176 pp.

Environment Canada. 2003. Lightning Activity in Major Cities in Canada. Meteorological Service of Canada, Ottawa, Ontario. Online. Available at: http://www.msc.ec.gc.ca/education/lightning/cities_e.html

Environment Canada. 2004. Lightning . Online. Available at: http://www.pnr-rpn.ec.gc.ca/air/summersevere/ae00s19.en.html

Environment Canada. 2004. Tornadoes. Online. Available at: http://www.pnr-rpn.ec.gc.ca/air/summersevere/ae00s02.en.html

Hegmann, G., C. Cocklin, R. Creasey, S. Dupuis, A. Kennedy, L. Kingsley, W. Ross, H. Spaling, and D. Stalker. 1999. Cumulative effects assessment practitioners guide. Prep. by AXYS Environmental Consulting Ltd. and the CEA Working Group for the Canadian Environmental Assessment Agency, Hull, Quebec.

IPCC WG1 AR4 Final Report. 2007. Online. Available at: http://ipcc-wg1.ucar.edu/wg1/wg1-report.html

Kjearsgaard, A.A., 1973. Soils of the Suffield Military Reserve. Alberta Institute of Pedology,Report No. M-73-9. Maps and Legend.

LaLonde, K., B. Corbett, and C. Bradley. 2005. Southern Alberta watersheds: An overview. Published by Prairie Conservation Forum. Occasional Paper Number 5. 51 pp.

Madhav L. Khandekar. 2004. Canadian Prairie Drought: A Climatological Assessment. Online. Available at: http://www.environment.gov.ab.ca/info/library/6673.pdf

Marty, J.T. 2005. Effects of cattle grazing on diversity in ephemeral wetlands. Conservation Biology, 19(5): 1626-1632.

Nav Canada. 2001. The Weather of the Canadian Prairies. Online. Available at: http://www.navcanada.ca/ContentDefinitionFiles/publications/lak/CanadianPrai res/P32E-V.PDF.

Pettapiece, W.W., and R.G. Eilers. 1990. Soil salinity, Alberta. Land Resource Research Centre, Research Branch, Agriculture Canada. Contribution Number 87-13. Publication 5262/B. 9 pp. + expanded legend and map.

Poston, B., D. Ealey, P. Taylor and G. McKeating. 1990. Priority Migratory Bird Habitats of Canada’s Prairie Provinces. Canadian Wildlife Services, Edmonton, AB. 107 pp.

Sonntag, N.C., R.R. Everitt, L.P. Rattie, D.L. Colnett, C.P. Wolf, J.C. Truett, A.H.J. Dorcey, and C.S. Holling. 1987. Cumulative effects assessment: A context for further research and development. A background paper prepared for the Canadian Environmental Assessment Research Council. Minister of Supply and 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-012 3 #Terr - 339 - A

Services Canada. 91 pp.

Webber, M.D., and S.S. Singh. 1995. Contamination of agricultural soils. Chapter 9 in: D.F. Acton and L.J. Gregorich (Editors). The health of our soils – Towards sustainable agriculture in Canada. Centre for Land and Biological Resources Research. Research Branch. Agriculture and Agri-Food Canada. Publication 1906/E. Ottawa, Ontario.

Reference: Volume 3, Appendix 3F, Page 3F-8, Figure 3F-2

Preamble: EnCana shows in EIS Volume 3, Appendix 3F, Page 3F-8, Figure 3F-2 an Example of [Well and Pipeline] Projection [on Constraints-Detailed Methods] at the North end of the South NWA Compartment.

Request: GOC recommends that EnCana provide projections for all areas of the NWA.

Response: See response to AWA-5.

Reference: Volume 3, Section 8.1, , Page 8-2, Heading Blowouts and Surface Casing Vent Flow Volume 1, Section 2.2.5.3, page 2-24

Preamble: EnCana states Low well-bore pressures combined with years of experience in drilling and constructing wells in shallow gas operations demonstrate the possibility of a blowout is near zero – there has never been a blowout in 30 years of EnCana’s operations at CFB Suffield.

There have been at least two losses of well control in the National Wildlife Area in 2007 alone, one of which occurred prior to submission of the Environmental Impact Statement. The sound was audible for at least one kilometre. These have not been included in the assessment.

Request: GOC recommends that EnCana calculate the risk of surface venting given the age of many existing wells and the abundance of ungulates that might come in contact with above ground infrastructure and impacts to other wildlife VEC’s. Documents how the risk was calculated. Provide a revised risk assessment and make adjustments to the environmental plan to mitigate that risk effectively.

Response: No loss of well control occurred during the dates indicated and EnCana has confirmed a well blow out has not occurred in the NWA.

However, a Surface Casing Vent Flow repair was remedied in 2006 which had some associated noise. Additionally, construction and completion activity occurred in 2006 and 2007 in areas adjacent to the NWA, which also had some associated noise.

Surface venting is incorporated into the Project assessment. Previous experience at Suffield is indicative of the risk of venting in the future. The methodology for measuring the risk of these events is regulated by the EUB and found in Interim Directive ID 2003-01. Accordingly, EnCana believes the assessment conducted is appropriate and does not require modification.

Reference: Volume 3, Section 8.1, Page 8-1

Preamble: EnCana states that “Specific mitigation measures to prevent interaction with snakes have been established. These mitigation measures include: no mowing or grading on ROW during snake season; avoidance of roads that have high snake frequency.”

Request: GOC recommends that EnCana: 1. identify proposed mowing locations and spatial extent in the NWA for the Project; 2. identify and assess the impacts of mowing on plant, soil, and animal VECs; 3. specify when the snake season begins and ends; and 4. identify which roads have high snake frequency, and the criteria used in the determination of snake frequency.

Response: 1. Environmental assessment is conducted early in the planning stages of a project. This permit changes arising from the environmental assessment and consultation process to be incorporated in the final design. EnCana will engage in a lengthy planning process in advance of determining final locations. As such, the proposed mowing locations and spatial extent in the NWA have not yet been determined.

2. In developing this Project, EnCana has taken an expansive approach to considering potential impacts to ensure the cumulative impacts of full development are known, understood and mitigated. EnCana has the benefit of its knowledge of and experience in the area, having drilled over 1100 wells in the NWA between 1975-2005 and having continually updated and improved its practices to minimize impacts on the native prairie.

Vegetation mowing effects on vegetation will be minimal on ROWs because vegetation in these areas are dominantly introduced species. Mowing during seed-set is not favoured because of potential seed dispersal issues.

Impacts of mowing on wildlife VECs will be negligible due to: • the small area involved • no mowing will occur during the period 15 April to 1 Aug to avoid the majority of the migratory bird breeding period • mowing contemplated during the period 1 Aug – 15 October will require clearance by a qualified representative to ensure that no nesting birds or other 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-012 2 #Terr - 342 - A

wildlife (particularly snakes) are present

3. The time period during which snake activity has been assumed is 15 April – 15 October. The exact migration times vary year to year.

4. Section 5.8.2 describes specific mitigation measures to minimize impacts to snakes. All roads east of Bingville and Fox Roads have been considered high risk areas for snake encounters. The mitigation measures proposed are anticipated to minimize the impact to snakes during activities between 15 April and 15 October.

Reference: Volume 3, Section 8.1, Page 8-3, Volume 3, Section 9.3, Page 9-2

Preamble: EnCana states that “The Project is in a grassland region where wildfire has been a common historical occurrence. Should a wildfire occur the risks to wildlife are expected to be negligible as these events tend to be of short duration, low intensity and restricted to the dry surface vegetation cover.” However, EnCana also states that “Due to fire suppression in the Suffield region, dead vegetation matter accumulates to high levels throughout the area.” EnCana further states that “Should a wildlife occur the risks to overall diversity are expected to be negligible as these events tend to be part of the natural grassland ecology.”

Request: GOC recommends that EnCana: 1. explain the differences between the first two statements, in terms of wildfire risk and intensity, and clarify which statement is correct; 2. identify the potential impacts of high intensity fires on vegetation, soil, and animals VECs as a result of accidents or malfunctions; 3. identify the specific fire prevention and control actions it will employ to minimize the impacts of fire on vegetation, soil, and animals VECs; and 4. identify the assumptions and hypotheses that underlie the statement that effects to overall diversity are expected to be negligible, and discuss the degree of certainty of the prediction; and how wildfire may affect its proposed mitigation activities, including reclamation.

Response: 1. Wildfires occur frequently during the summer season in the Suffield block outside the NWA. While there is a high risk for wildfires, the impact of such wildfires on wildlife and the grassland ecosystem are negligible. The NWA is also protected from fires by fire breaks, in addition to other fire control measures.

2. Fires can cause direct mortality and habitat alteration, albeit of an infrequent and localized nature. The potential impacts of high intensity fires on vegetation, soil and animal VECs are detailed in Volume 3 of the EIS in Section 8.2, pages 8-4, Section 8.4, pages 8-7, and Section 8.1, page 8-3 respectively.

3. Please see the response to Terr 10.

4. EnCana’s assumption is that wildlife species in the Dry Mixedgrass Subregion 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-012 2 #Terr - 343 - A

are adapted to widely varying fire and drought conditions. Populations of species ebb and flow with fire and drought cycles. It is not anticipated that any species will be experience threats to population stability due to natural fire events. No hypotheses are required as this assertion was not tested with field data.

Reference: Volume 3, Section 8.1, Page 8-3

Preamble: EnCana states that “Although unlikely, potential malfunctions and accidental events may occur during the Project that could affect vegetation communities. Among these events are: damage resulting from vehicle traffic outside the prescribed access routes”.

Request: GOC recommends that EnCana: 1. specify how it identifies prescribed access routes; 2. specify how it has enforced the use of prescribed access routes and measures of its success within the NWA; and 3. specify how it has addressed the Suffield Environmental Advisory Committee (SEAC)’s concerns with respect to access management and trespass access; and discuss the success of mitigation when vehicle traffic has occurred outside the prescribed access route.

Response: 1. Prescribed access routes will be determined during the PDAs. EnCana selects access routes based on terrain and the type of vehicles to utilize the route. Once identified, the route is staked for clear identification by professional surveyors. These routes will be identified on access route maps which will be made available to all staff. 2. Single access routes have not been used as a “best practice” in the past. EnCana has used a “two track protocol” approach where trails are not to be used numerous times, which reduces the compaction of access trails. Details regarding controls and stewardship of track discipline can be found in the EPP. 3. EnCana has developed single access maps for activity in the NWA. Future activities will utilize access maps which will be generated as a result of the PDAs. Currently, for the rest of the Base, single trail access routes are in the process of being adopted, firstly in areas on the Base with new infill development. Stewardship of trail discipline is being integrated into EnCana’s operational practices.

Reference: Volume 3. Pg. 8.1. Collisions with vehicles.

Preamble:

Request: GOC recommends that EnCana provide any supporting policies or management plans that will minimize vehicle impacts with species. Examples would include details such as the use of headlights at all times or the minimization of vehicle use at certain times of the day or night.

Response: The following mitigation measures are to be employed:

- Vehicle speeds will be restricted to 70 kph, 50 kph between April 15 and October 15 within the high risk snake area (east of Bingville and Fox Roads); - Workers will be educated and required to be alert to avoid snakes and other species on roads, both within and outside the NWA; and - The grading of roads will be undertaken only with an environmental inspector.

These mitigation measures are incorporated into the project specific draft EPP located in Volume 1, Appendix I. The highest period of activity will be the construction phase which occurs between October 1 to April 15. The majority of wildlife will be hibernating, left the region (migratory species) or be at less sensitive times so less encounters with wildlife are predicted.

Reference: Volume 3. Pg. 8-5. Wild fires.

Preamble:

Request: GOC recommends that EnCana provide details of fires caused at CFB Suffield as a result of gas development.

Response: EnCana has had one fire which occurred during post construction seeding activities. The fire occurred during a dry summer period and was initiated by the vehicle exhaust system. The area impacted was approximately 1.6 km2. Containment, control and extinguishment was accomplished by activating EnCana’s Emergency Response Plan. Details on prevention and control can be viewed within the response to IR Health-9-A.

Fire prevention and control measures employed to minimize the negative impact of fires are contained in the EEP in Volume 1, Appendix I of the EIS. A non-exhaustive list of examples include: vehicles will not be parked in high vegetation to avoid potential for wildfires; a water truck will be made available in areas where vegetation is dry; fire breaks will be put in place; smoking will only be allowed in vehicles and designated areas; and vehicle and equipment idling will be restricted to necessary activities and equipment. EnCana has not evaluated prescribed burns and other techniques for habitat management.

Reference: Volume 3. Pg 8.6. Pipeline Release.

Preamble: Encana states “given the setback requirement from wetlands as described in the EPP. There will, as a result, be no residual environmental effects to wetlands”. However, in EPP Pg. I-25 Section 2.5.7 Para 148 and 149 state that “setback distances may be reduced in exceptional circumstances” “An estimated 50 to 100 preliminary well locations are predicted to fall within the 100 m buffers”

Request: GOC recommends that EnCana explain the apparent contradiction between the two statements, Response: There is no contradiction between the two statements. In the event that setback distance is reduced and mitigation measures are necessary particularly to prevent sedimentation, salinization or contamination then EnCana will put in the necessary controls (i.e. erosion controls of spill plans and procedures in the draft EPP located in Volume 1, Appendix I). These measures will ensure that there is negligible effects on wetlands.

Reference: Volume 5, Section 4.8.2, Page 4-22

Preamble: EnCana states “EnCana will continue to repair the damage or replace grazing-related infrastructure damaged as a result of its activities” Request: GOC recommends that EnCana clarify who or where such damage should be reported to and how disputes over damage or repairs required are proposed to be resolved. Response: Damage will be reported to the grazing owner as well as to SIRC and DND. Disputes over repair to damages of this nature are rare and are almost always settled through negotiations.

Reference: Volume 5, Chapter 4, Section 4.8.1

Preamble: EnCana suggests that it will: continue to enforce requirements that its staff and contractors close all gates in the community pasture and adopt appropriate driving standards while in designated pastures, continue to regularly contact CWS to identify current and potential research programs underway and will harmonize its drilling and pipelining activities where possible, continue to fix any ruts and other damage resulting from EnCana's activity on individual VECs in Section 4.8.2.

Request: GOC requests that EnCana specify how each of the activities listed above will be carried out and enforced. Response: Initially, this requirement will be addressed in the training orientation for all personnel associated with the project. “Good Neighbor” concerns will be addressed and communicated. Monitoring and audit will confirm compliance with these requirements.

Reference: Volume 3, Section 4.8.2.7, Page 4-35

Preamble: EnCana states that “the NWA is currently being used by the CWS and others for biological and ecological research…While there is some potential for the Project to interfere with research activities…EnCana will regularly contact CWS to identify current and potential research programs are underway and will harmonize its drilling and pipelining activities where possible to avoid research sites.”

Request: GOC recommends that EnCana: 1. identify the specific effects of the Project on the integrity of the NWA to serve as a control location for measuring the effects of land-use activities on native prairie ecosystem, including considerations of fragmentation, well density, and industrial footprint relative to the local and regional study areas;

2. identify the specific effects of the Project on the integrity of research activities, including consideration of confounding factors resulting from the Project;

4. specify the criteria and thresholds in determining the possibility of avoiding research sites;

Response: 1. The effects of the Project on vegetation, wildlife and wildlife habitat are predicted to be negligible or insignificant; therefore, the effects on the integrity of the NWA as it relates to CWS research are predicted to be negligible or insignificant. Volume 3, Section 7.5.4 calculated the existing disturbance footprint on vegetation cover types for the NWA-South (2.3%) and NWA- North (1.3%) while the footprint associated with the proposed infill drilling of 1,275 wells and associated lateral and loop pipelines was also estimated for the NWA-South (0.39%) and NWA-North (0.41%). Based on these footprints, it is unlikely that there will be measurable effects on the suitability of the NWA to serve as a control location. The main inventory done by the CWS in 1994/5 was conducted after over 1000 wells were drilled; therefore, if the NWA was a control in 1994/5, it should still be a control location going forward.

2. As EnCana is not aware of the exact studies being conducted by the CWS currently or in the future, it is not possible to determine whether the Project may be a confounding factor. As is discussed in point #1, EnCana does not anticipate any significant effects on research activities.

4. The construction season is from October 1 to April 15 which is outside the majority of research season for the CWS; therefore, EnCana does not anticipate any difficulty in avoiding interfering with CWS research activities. If the CWS and/or the DND provide specific sites that are currently used for control sites or long-term monitoring, EnCana will avoid those sites using appropriate setback distances.

Reference: Volume 3, Section 4.8.2.7, Page 4-35

Request: GOC recommends that EnCana: 3. specify how it will coordinate its activities with DND, which issues permits for all research activities; 5. discuss its history of avoiding research sites in the NWA, and specify how it avoided them; and 6. identify the resulting effects on research, and specify how it mitigated such effects, where it could not or did not avoid research sites.

Response: 3. All coordination of activities with DND (and other users) is conducted through SIRC. 5. EnCana has avoided research sites by obtaining locations from SIRC or the DND, then maintaining a buffer between those activities and EnCana’s activities. For example, in conducting field research in 2006, EnCana had either spatial or temporal separation to avoid CWS and DND research sites. 6. EnCana is not aware of any effects on the research based on their activity.

Reference: Volume 3, Section 4.8.2.7, Page 4-35

Preamble: EnCana states that “Potential project effects of concern included direct interference with grazing, the potential loss of grazing capacity due to surface land disturbances…With respect to potential changes in grazing capacity, the assessment of project effects on vegetation communities (Volume 3 Section 3) indicates that project construction will no significant effects on the abundance or distribution of plant species that support grazing. Thus no reduction in grazing capacity is expected.”

Request: GOC recommends that EnCana: 1. justify the statement that the project-related effects will not result in reduced grazing capacity, including how grazing capacity was assessed; and 2. specify how vegetation recovery and soil erosion will be managed for the Project in the presence of cattle grazing, without reductions in total grazing area or stocking rates;

Response: 1. No quantitative assessment of grazing capacity was completed for the Project. It was assumed that because of the minimal surface disturbance footprint (<0.5%), Spyder Plowing or chain ditching of lateral pipelines, and the re-seeding of areas of larger surface disturbances (bellholes and looplines) that effects on cattle forage supply would be negligible, particularly as the areas will be only temporarily affected for the purposes of grazing cattle. The Project effects on native prairie integrity are insignificant, therefore, effects on cattle grazing capacity are not anticipated. 2. Fencing will be utilized to prevent cattle grazing in localized areas where it is necessary to allow for vegetation recovery. Soil erosion measures are described in the draft EPP (Appendix I, Volume 1). The small footprint of the Project means that there will be no significant reduction in total grazing area even if all areas disturbed or reclaimed are excluded for cattle.

Reference: Volume 3, Section 11. Glossary, pages 11-1 to 11-6

Preamble: The terms Well Pad and Well Lease / Lease appear to be used interchangeably throughout Volume 3, often in methods describing locations of assessment or determination of footprint.

Request: GOC recommends that EnCana clarify the terms Well pad, Well, Well Lease and Lease.

Response: The terms can be clarified as follows:

Well: A hole drilled or bored into the ground, cased with metal pipe and cemented in place, for the production of oil or gas. It can also be a hole used for the injection under pressure of water or gas into a subsurface rock formation.

Well Lease: The surface area of a piece of land used for the purpose of drilling a well (“lease” is a short form of “well lease”).

Well Pad: A well lease with one or more than one well drilled from it. This term is used in industry but is not referred to in the glossary to the EIS as it is not applicable. Well pads will not be used.

In the case of CFB Suffield, well locations do not have individual surface lease agreements. Therefore, when used in the context of surface footprint for CFB Suffield (including the NWA), the ‘Well Lease’ or ‘Lease’ should be interpreted as the designated working area for an individual well location – which is deemed in CFB Suffield to be 100 × 100 m.

Reference: Volume 5, page 4-17

Preamble: EnCana states: No Traditional Land Use Study was conducted because First Nations "...have not accessed this area since at least 1941..."(page 4-17). It is possible that First Nations have traditional accounts of the places contained with Suffield NWA even if access has been denied to them.

Request: Describe EnCana contact and consultations with First Nations, along with documented comments from First Nations, including an evaluation of First Nation interests (particularly in regards to archaeological sites) in this area.

Response: EnCana will file its public consultation record with the Joint Review Panel (including reference to First Nations Consultation) once consultation is complete. Siksika Nation provided Information Requests as part of this process.