Review of the Nova Gas Transmission Line North Corridor Expansion Project Environmental and Social Effects Assessment Technical Report

Prepared in Collaboration with:

Melanie Daniels Consultation Coordinator Louis Bull Tribe Maskwacis, Alberta

10714 - 124 Street NW, Edmonton, AB, Canada T5M 0H1 December 5, 2019

5 December 2019

Melanie Daniels Consultation Coordinator Louis Bull First Nation Maskwacis, Alberta

Dear Ms. Daniels; Re: Review of the Nova Gas Transmission Line (NGTL) North Corridor Expansion Project Environmental and Social Effects Assessment Technical Report Please find attached the technical report for Louis Bull Tribe’s Written Evidence submission to the NGTL North Corridor Expansion Project. The report provides a scientific overview of the potential environmental sensitivities raised as concerns by the Louis Bull Tribe that are relevant to the NGTL North Corridor Expansion Project Environmental and Social Effects Assessment Technical Report. We summarize the scientific and technical information related to the pipeline expansion and conclude with recommendations on how this could be completed based on our reported materials. Please contact the undersigned if you have any questions or concerns. Sincerely, Solstice Canada Corp.

Johnathan Potter, B.Sc., P.Ag. Louise Versteeg, B.Sc., P.Biol. Sr. Environmental Scientist Sr. Terrestrial and Wetland Ecologist (Reviewer)

Brianna Lorentz, B.Sc. Environmental Scientist

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TABLE OF CONTENTS 1. Introduction ...... 1 2. Review Objectives ...... 1 3. Review Findings ...... 2 3.1. Soil Survey ...... 2 3.1.1. Summary of ESA Content...... 2 3.1.1. Evaluation and Recommendations ...... 3 3.2. Temporary Workspace ...... 5 3.2.1. Summary of ESA Content...... 5 3.2.2. Evaluation and Recommendations ...... 5 3.3. Permafrost...... 5 3.3.1. Summary of ESA Content...... 5 3.3.2. Evaluation and Recommendations ...... 7 3.4. Fisheries Act AMendment ...... 7 3.4.1. Summary of ESA Content...... 7 3.4.2. Evaluation and Recommendations ...... 10 3.5. Biophysical Survey ...... 10 3.5.1. Summary of ESA Content...... 10 3.5.2. Evaluation and Recommendations ...... 10 3.6. Onsite Environmental Monitoring ...... 11 3.6.1. Summary of ESA Content...... 11 3.6.2. Evaluation and Recommendations ...... 11 3.7. Watercourse Crossings ...... 11 3.7.1. Summary of ESA Content...... 11 3.7.2. Evaluations and Recommendations ...... 12 3.8. Reseeding of Vegetation ...... 12 3.8.1. Summary of ESA Content...... 12 3.8.2. Evaluation and Recommendations ...... 12 4. Conclusion ...... 12 5. References ...... 14

LIST OF FIGURES Figure 1. Illustration of potentially misclassified soil polygons as wetlands ...... 4 Figure 2. Red Earth Section 3 pipeline runs directly through and near where permafrost is predicted to be present. ... 6

LIST OF APPENDICES Appendix A. CVs of Report Contributors

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1. INTRODUCTION

Solstice Environmental Management (Solstice) has been retained by Louis Bull Tribe (LBT) to conduct a technical review of the Jacobs Engineering Group Inc. (Jacobs) Environmental and Socio-economic Assessment (ESA) for the Proposed NOVA Gas Transmission LTD. (NGTL) North Corridor Expansion Project (the Project) and potential impacts to resources of concern to its community members. LBT was granted intervenor status and has had this technical report produced in support of the Written Evidence submission to the Canadian Energy Regulator (CER) and NGTL , the results of which are documented here. NGTL filed an application for the Project with the National Energy Board (NEB) on April 4, 2019 proposing additional construction and operation on the currently existing NGTL system. A list of intervenors for the Project was issued by the NEB on August 16th, 2019 and a hearing order was issued for the Project on August 19th, 2019. This hearing order describes the written hearing process which allows the opportunity for sharing oral Indigenous knowledge, provide written questions, and provide written argument on any proposed conditions. On August 28, 2019, the NEB transitioned into the CER which will continue the assessment of the Project under the National Energy Board Act and will be referenced throughout this report. The Project will serve to transport gas along 81 km of pipeline from the Peace River Project Area to North of Bens Area intra-basin markets and consists of three pipeline sections referred to as North Star Section 2 (~24 km), Red Earth Section 3 (~32 km), Bear Canyon North Extension (~25 km), and a compressor station unit addition referred to as the Hidden Lake North Unit Addition. It is expected that construction of the pipelines will take place during the third quarter of 2021 until the first quarter of 2022 and the construction of the Hidden Lake North Unit Addition will take place from the first quarter of 2021 until the first quarter of 2022. The scope of this review was framed by the concerns of the Louis Bull Tribe. Although the Louis Bull Tribe is a Treaty 6 Nation and the Project will occur in Treaty 8 territory, Indigenous Nations have historically utilized the landscape without being confined to specific areas defined by borders. Additionally, of significant concern is the impact of cumulative effects that have incurred in Treaty 6 lands, which have inhibited Traditional practices. For instance, wild game has become increasingly difficult to find and private ownership of land has created barriers to accessing cultural sites. Thus, members of Louis Bull have had to travel further from the reserve lands within Treaty 6 to engage in Traditional practices in other areas such as Treaty 8, which is less fragmented by development and offer more areas and opportunities for Traditional practices to take place. However, if development continues to expand without due consideration for cumulative effects, there is considerable concern from the Louis Bull Tribe that there will be continued erosion of the ability for Indigenous Nations to engage in and practice their Traditional way of life. The inability to engage in Traditional practices has impacts that are of major concern to the Louis Bull Tribe. These practices are important in preserving culture, transmitting skills and knowledge to the youth and future generations, and in maintaining food security for the community. As such, given the potential for the proposed Project to impact Louis Bull Tribe’s ability to engage in Traditional practices, there is an obligation to duly consult with, incorporate and fully address the concerns that are discussed. All concerns noted above were incorporated into the original Information Request submitted to CER and have been further explained in the review findings. 2. REVIEW OBJECTIVES

The objectives of this third-party technical review of the Project ESA are to: • Identify technical issues found within the Project ESA that may affect the practice or exercising of LBT’s treaty rights, and • Suggest how these issues may be addressed through revisions, additions, and engagement between NGTL and LBT.

In keeping with our scope and the limited resources made available to LBT for this review, the review team at Solstice focused on reviewing the technical information related to the following subjects throughout the Project ESA: • Soil and Soil Productivity • Water Quality and Quantity • Wetlands

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• Vegetation • Wildlife and Wildlife Habitat

Additionally, Solstice collaborated with Pisces Environmental Consulting Services Ltd. (Pisces) to complete the technical review of Fish and Fish Habitat components associated with Watercourse Crossings, whose findings are incorporated in this report. The review materials included herein focus on the conservation science relevant to the issues and concerns raised by Louis Bull members, including an integration of the socio-ecological and socio-cultural implications of the Project for these issues. 3. REVIEW FINDINGS

3.1. SOIL SURVEY

3.1.1. Summary of ESA Content The following summarizes issues found in the soil survey component after a review of the following: • NGTL North Corridor Expansion Project Environmental and Socio-economic Assessment for the Proposed NOVA Gas Transmission Ltd. North Corridor Expansion Project, Section 5.2.2 • The Exploratory Soil Survey of Alberta Map Sheets 84-C (east half), 84-B, 84-A, and 74-D (Research Council of Alberta 1957) • Alberta Environment and Parks 2018 Alberta Merged Wetland Inventory • Appendix 2B, North Central Corridor Loop (Red Earth Section 3), Environmental Alignment Sheets (EAS), map numbers 002 of 012 and 003 of 012 • NEB/CER Filing Manual, Filing Requirements for Soil and Soil Productivity • Canada Land Inventory, National Soil DataBase, Agriculture and Agri-Food Canada. 1998 Field-based soil surveys were not completed for a large portion of the pipeline alignment in the Green Zone, including the entirety of Red Earth Section 3, 9.8 km of the Bear Canyon North Extension, and all of the Hidden Lake North Unit Addition. As noted in Section 5.2 of the ESA, soil mapping for the pipeline alignment in the Green Zone was completed as a desktop review of existing literature including aerial imagery, exploratory soil surveys, derived vegetation inventory datasets and other publicly available information such as Alberta Merged Wetland Inventory (AEP 2018) data, of which many, if not all, are based off of limited field verification. For example, the Exploratory Soil Survey of Alberta Map Sheets 84-C (east half), 84-B, 84-A, and 74-D (Research Council of Alberta 1957) was completed from a helicopter at a scale of ~1:40,000 and was significantly limited in the field-based soil information that was collected. The Alberta Merged Wetland Inventory (AEP 2018), which was also used to complete the desktop survey, specifically states that it was “…not intended to replace site specific or local information to describe wetland type, area, and location” and is highly pixelated with up to 30 meters of error. With no ground-truthing of mapped soil polygons there is increased risk of error in soil classification, particularly as it relates to organic versus mineral soils, several examples of which have identified through our review of the alignment sheets. In Red Earth Section 3 there are a number of examples of where the desktop soil mapping may not accurately reflect on the ground soil conditions as noted below: • On EAS 002 of 012 and 003 of 012 it appears that upland forest area and forestry cut-blocks have been classified as wetland soils and vice versa (Figure 1). • Inconsistent mapping of wetland polygon boundaries. On some alignment sheets (e.g., EAS 007of 012), wetland polygons are mapped entirely, while on other alignment sheets (e.g., EAS 008 of 012) mapped wetland polygons appear to extend into upland forest areas and arbitrarily end at some distance on either side of an inconsistently applied buffer on either side of the pipeline’s alignment

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• On EAS 008 of 012 there are inconsistencies between wetland mapping and information contained in the resource band for soils information, and vegetation and wetland information. For example, in NE SEC 26-91- 7-5, the soil band identifies soils as being upland-fine/2-4, while the vegetation and wetlands band identifies this area as being a wooded coniferous fen and a portion of the alignment is mapped as a wetland. The coarse scale of the reference material on which the desktop soil survey was based, along with the potentially misclassified soil polygons noted above put into question the methodology employed in the desktop survey and any confidence that the alignment sheets can effectively be used to direct and plan construction activities. It is important to note that wetlands and forested soils are of ecological and cultural importance to the Louis Bull Tribe. These “non-agricultural” soils are important to species and communities of ecological and human importance (e.g. traditional land use such as medicinal plants and subsistence animals) and must be considered as equally important. This importance is heightened by the loss of wetlands in Treaty 6 lands which increases the need to maintain wetlands in Treaty 8 for the perpetuation of Traditional practices associated with those features. Although NGTL states that they “will implement minimal disturbance construction techniques under frozen conditions where possible, which is proven to successfully reclaim forested lands”, provisions must be made for when it is not possible. Best management practices to ensure adequate conservation and reclamation of these areas require the completion of soil surveys with accurate mapping. NGTL has not considered the ecological value of these soils in terms of traditional land use and has not completed a field-based soil survey along the pipeline right-of way. It is important to note these soils are considered Class 4-5 by the Canada Land Inventory National Soil Database and as such, are considered “forested lands with agricultural capability”. Additionally, the Green Area within the Bear Canyon North Extension is directly adjacent to the White Area. As the Green and White Areas of the province are strictly administration boundaries that are not ecologically defined, it would be incorrect to conclude that agricultural lands and forested lands with agricultural capability would strictly end at this boundary line. As per the NEB/CER Filing Manual, Filing Requirements for Soil and Soil Productivity, “agricultural lands and forested lands with agricultural capability” require that appropriate soil survey and soil descriptions be completed. The justification for limiting the soil survey based solely on the agricultural capability as defined by Green and White Area administration boundaries does not allow for adequate soil mapping and ignores the potential for soil mitigation concerns that could be encountered in areas along the administration boundary, which are considered forested lands with agricultural capability. This is of concern as the soil mapping is used to inform the soil handling and limitations on the alignment sheets and in the EPP, both of which are used to direct and plan construction and reclamation activities.

3.1.1. Evaluation and Recommendations a) NGTL should undertake supplemental soil surveys of the non-surveyed pipeline right-of-way to field verify soil mapping units in the Green Area to ensure proper planning and management in terms of the conservation and reclamation of soil resources in order to protect these ecosystems and minimize local disturbance and cumulative effects.

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Figure 1. Illustration of potentially misclassified soil polygons as wetlands. Figure 1A) shows the Red Earth Section 3 alignment which identifies the area circled in red as a shrubby fen “muskeg”. However, as indicated by Figure 1B this area is not classified as a wetland (blue polygons) according to the colour image of the Alberta Merged Wetland Inventory data. Additionally, Figure1C (black and white image from 2006) suggests this area may be part of a mosaic of cutblocks in the area. Red Earth Section 3 pipeline runs directly through and near where permafrost is predicted to be present.

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3.2. TEMPORARY WORKSPACE

3.2.1. Summary of ESA Content • The following summarizes issues found in the identification of temporary workspaces after a review of the following: • NGTL North Corridor Expansion Project Environmental and Socio-economic Assessment for the Proposed NOVA Gas Transmission Ltd. North Corridor Expansion Project, Section 2.1.8 Construction Right-of-Way and Temporary Workspace, Project Description • NGTL North Corridor Expansion Project Environmental and Socio-economic Assessment for the Proposed NOVA Gas Transmission Ltd. North Corridor Expansion Project, Section 2.1.4 Mainline Valve Sites • NGTL North Corridor Expansion Project Environmental and Socio-economic Assessment for the Proposed NOVA Gas Transmission Ltd. North Corridor Expansion Project, Section 8.1 of the Environmental Protection Plan As noted in Section 8.1 of the Environmental Protection Plan one of the mitigation measures identified is to “not use temporary workspaces within the boundaries of wetlands”. However, temporary workspace has not been identified on any of the alignment sheets, nor have the mapped soil polygons been field verified in the Green Zone for the entire Red Earth Section 3, 9.8 km of the Bear Canyon North Extension, and all the Hidden Lake North Unit Addition, or on the yet to be identified temporary workspace areas. Additionally, this review has identified soil map units that appear to have been incorrectly classified through the desktop review that was completed for this ESA (see Section 3.1 above). In order to effectively implement the mitigation measure to avoid placing temporary workspace within the boundaries of wetland it is important to have accurate delineation of wetlands and soil map units. The lack of this information is of concern, as wetland and forested soils are of ecological and cultural importance to the Louis Bull Tribe, as is the management of cumulative effects on our Alberta Landscapes where areas to practice traditional land use are becoming more and more limited. Best management practices to ensure adequate conservation and reclamation of soils requires sufficient ground- truthing of mapped units through field-based soil surveys to obtain accurate soil mapping. A desktop survey at this scale is not the best approach to substantively plan the construction of a pipeline with avoidance and mitigation prescriptions and is better used to plan the preliminary assessment of a field-based soil survey. Given the limitations of the desktop information and the increased risk of misclassifying soil map units, particularly of organic versus mineral soils, it is not effective to use this information as a meaningful planning and mitigation tool, given the significant limitations noted with the soil mapping and alignment sheets.

3.2.2. Evaluation and Recommendations a) NGTL should Identify the locations of temporary workspaces and undertake field-based soil surveys of the non-surveyed pipeline areas and temporary workspaces to ensure proper conservation and reclamation of these resources to protect these ecosystems, and to accurately determine wetland boundaries.

3.3. PERMAFROST

3.3.1. Summary of ESA Content The following summarizes issues found in the identification of permafrost after a review of the following: • NGTL North Corridor Expansion Project Environmental and Socio-economic Assessment for the Proposed NOVA Gas Transmission Ltd. North Corridor Expansion Project, Section 5.1.1, Section 5.1.2.4, and Section 5.2.2 • Section A.2, Filing Requirements for Soil and Soil Productivity National Energy Board 2017 • Master Schedule of Standards and Conditions, Section 4.0 Soil Government of Alberta 2018

• NGTL North Corridor Expansion Project Environmental and Socio-economic Assessment for the Proposed NOVA Gas Transmission Ltd. North Corridor Expansion Project, Section 7.0 Permafrost Contingency Plan • Pawley, S.M. 2018. Generalized Outlines of Northern Alberta Regions Containing Permafrost (GIS data, polygon features); Alberta Energy Regulator, AER/AGS Digital Data 2018-0010.

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• Pawley, S.M. and Utting, D.J. 2018. Permafrost Classification Model for Northern Alberta (gridded data, GeoTIFF format). Alberta Energy Regulator, AER/AGS Digital Data 2018-0008 • NGTL North Corridor Expansion Project Environmental and Socio-economic Assessment for the Proposed NOVA Gas Transmission Ltd. North Corridor Expansion Project, Appendix 2B, North Central Corridor Loop (Red Earth Section 3), Environmental Alignment Sheets (EAS), map numbers 008 of 012, 009 of 012, 012 of 012, etc. Permafrost degradation is a significant contributor to the accumulation of greenhouse gases and the exacerbation of climate change which is of concern to Louis Bull Tribe. As per Section A.2 of the NEB Filing Manual Locations of permafrost must be identified, and necessary mitigation and avoidance measures must be taken. There is concern that NGTL has not adequately performed due diligence to identify the appropriate mitigations around permafrost prior to construction as permafrost locations were not field verified. Without a field-based soil survey being completed in the non-agricultural wetland (includes organic or poorly-drained areas) and forested areas, implementation of the necessary mitigation and avoidance measures prior to construction may be severely limited. Section 5.1.2.4 of the ESA states that “Permafrost may be present in limited locations of organic or poorly-drained areas that comprise approximately <1% of the Red Earth Section 3 PCF…”. However, this assumption is based on data that were mapped at a scale of ~1:1,000,000 (Pawley 2018) and the mapped polygons do not necessarily reflect accurate boundaries of permafrost areas. These are instead aggregations of points derived from a machine learning algorithm employed in the Permafrost Classification Model for Northern Alberta (Pawley 2018). Further investigation of the finer scale machine learning algorithm from the metadata (Pawley & Utting 2018), indicates that the pipeline intersects with one of the predicted permafrost aggregations, is near another aggregation, and is surrounded by area where near-surface permafrost is predicted to be present, but were not aggregated (Figure 2). Although NGTL has a “Permafrost Contingency Plan” in Section 7.0 of the Environmental Protection Plan there are several concerns that need to be addressed. The Plan is prefaced by: In the unlikely event that isolated pockets of permafrost are identified throughout the Project during construction, the following mitigation measures will be implemented to the extent practical. According to the Pawley 2018 dataset, it seems very likely that permafrost could be encountered in this area. Thus, ground truthing of soil conditions in this area should be undertaken to determine if permafrost is present in order to determine and implement appropriate avoidance and mitigation measures, as required.

Figure 2. Red Earth Section 3 pipeline runs directly through and near where permafrost is predicted to be present. Areas of predicted permafrost aggregations are indicated by the purple polygons, while potential areas of isolated predicted permafrost areas are indicated by the white polygons. Permafrost was not considered as a factor in the route selection criteria, despite it being a clear “sensitive environmental feature” that has a reasonable likelihood of being present along portions of the alignment route as indicated in Section 5.2.Furthermore, the contingencies highlighted in the EPP imply that permafrost locations will have been encountered and disturbed, thus rejecting any possibility for implementing proactive avoidance or mitigation of permafrost impacts, which is contrary to best management practices and conditions. This brings into question if NGTL intends to implement efforts to feasibly avoid areas of permafrost.

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Disturbance of permafrost layer in frozen conditions will not help mitigate permafrost degradation if the permafrost layer is disturbed or removed. There are several instances where there is evidence of collapse scarring/disturbed areas around what is likely the center line of the existing pipeline, which may be evidence of permafrost in the existing right-of-way and that historic mitigation measures were unsuccessful. Further field work (soil survey) would be required to verify if the collapse is related to permafrost or other soil issues.

3.3.2. Evaluation and Recommendations a) NGTL should ensure that the soil surveys map the areas of permafrost in the PCF (the land area directly disturbed by Project construction activities) both on the right-of-way and in the temporary workspaces to ensure adequate protection of this sensitive environmental feature. b) As per Section A.2 of the NEB Filing Manual: Identify and describe any areas with permafrost conditions, including discontinuous permafrost, high ice content soils, thaw-sensitive slopes, and riparian areas. c) NGTL will determine the cause of the visible collapse scaring/disturbed areas around the existing right-of- way and address.

3.4. FISHERIES ACT AMENDMENT

3.4.1. Summary of ESA Content The following summarizes issues found in the addressing of the Fisheries Act Amendment after a review of the following by Pisces and Solstice: • NGTL North Corridor Expansion Project Environmental and Socio-economic Assessment for the Proposed NOVA Gas Transmission Ltd. North Corridor Expansion Project, Section 5.7 Fish and Fish Habitat • Fisheries Act Amendment-2019, c. 14, s. 22 • NGTL North Corridor Expansion Project Environmental and Socio-economic Assessment for the Proposed NOVA Gas Transmission Ltd. North Corridor Expansion Project, Application, Section 1.12, Table 1-1 • NGTL North Corridor Expansion Project Environmental and Socio-economic Assessment for the Proposed NOVA Gas Transmission Ltd. North Corridor Expansion Project, Appendix 6, Aquatics Technical Data Report Table 3.2-1 of the ESA lists the federal and provincial regulations that may apply to the project and require permit applications. However, there were no approved permits included with the documentation that Pisces was able to find. According to the CoP for Pipelines and Telecommunication Lines Crossing a Water Body, Class C waterbodies can be trenched using an isolated open cut method or using an open cut method with the specifications and recommendations of a QAES. According to the CoP (AEP 2013), the definition for “fish”; is fish used for domestic, sport, and commercial purposes and fish of special concern, including but not limited to rare, endangered, threatened or vulnerable species. This definition would exclude species such as Brook Stickleback from being considered “fish”. However, the 2019 Fisheries Act prevents the harmful alteration, disruption, or destruction (HADD) of fish habitat, which includes species such as Brook Stickleback. If HADD is expected, then the project is to be submitted to DFO to determine if HADD would occur and what offsetting measures are required. Fish and fish habitat assessments were performed along the proposed pipeline route in 2018 (Aquatics Technical Data Report in Appendix 6 of the ESA) by Jacobs Engineering Group Inc. (Jacobs) in an effort to determine the presence of fish and fish habitat. The assessments identified two watercourses in North Star Section 2, three watercourses and three fish bearing drainages in Red Earth Section 3 and one watercourse in Bear Canyon North Extension that will be crossed by the pipeline. During the assessment of the watercourses, fish habitat was rated as unsuitable, low, marginal important and/or critical based on the habitat requirements of four fish species; Northern Pike (Esox lucius), Walleye (Sander vitreus), Arctic Grayling (Thymallus arcticus) and Longnose Sucker (Catostomus catostomus). Habitat quality for hardy forage fish species was not included within the Aquatics Technical Data Report. In the North Star Section 2, the Notikewin River located in NW 25-93-22 W5M and an unnamed tributary to Meikle River in SW 32-93-22 W5M will be crossed by the proposed pipeline project (Table 5.2-2 of the ESA). The tributary’s fish habitat potential was rated as unsuitable for important fish species, such as Northern Pike and Walleye at the time of the assessment (Table 3-5 of the Aquatics Technical Data Report). The subject tributary had large sections of

| 7 dry channel with the substrate being composed mostly of fines (Appendix A of the Aquatics Technical Data Report). The current plan is to use an isolated open cut method if water is present or an open cut method if the watercourse is dry or frozen to bed (Section 5.7.3 of the ESA). The Notikewin River is a mapped Class C waterbody with a RAP of April 16 to July 15 (Table 5.7-2 of the ESA). During the 2018 assessment, the habitat of Notikewin River, in the vicinity of the crossing, was rated as important habitat for all life stages for Arctic Grayling, Longnose Sucker and Walleye, and marginal to important for Northern Pike (Table 3-5 of the Aquatics Technical Data Report). The substrate of Notikewin River was composed of a mix of gravel, cobble and boulders that provide good spawning habitat and cover for fish species in the area (Appendix A of the Aquatics Technical Data Report). Fish sampling was not conducted at the time of the assessment as it was deemed that there was adequate historical information available (Table 5.7-2 of the ESA). Indigenous Nations shared that Jackfish (Esox lucius) and Pickerel (Sander vitreus) can be fished from the Notikewin River (Section 3.15.2 of the Traditional Knowledge Report). Pisces reviewed the available information and queried FWMIS (AEP 2019) and found that the most recent fish survey in the vicinity of the crossing was in 2009 and no fish were caught at the time. The next most recent surveys were completed in 1980 17.5 km upstream of the crossing and 11 km downstream of the crossing. The surveys resulted in the capture of Northern Pike, Walleye and Longnose Sucker at both locations and Flathead Chub (Platygobio gracius) at the upstream survey. Table 5.7-4 of the ESA lays out one of the management and recovery plans for Walleye, Arctic Grayling and Northern Pike, is to protect, rehabilitate and develop habitat for these three species. The current plan to open cut with partial isolation (Section 5.7.3 of the ESA), which appears to have a high potential to introduce sediment into the watercourse resulting in the loss of important spawning gravels and boulder cover. This method can result in the death of fish through entrapment within the construction area and through the introduction of deleterious substances from heavy equipment. The plan to open cut the Notikewin River has a high risk of causing HADD (DFO 2019) under the amended 2019 Fisheries Act, due to the high quality of habitat available near the crossing location. Similarly, the large size of the river and the substantial flow rates also contribute to the high potential for adverse affects. Partial isolation of this river may also impact fish passage during construction by creating a velocity barrier through the constriction of flow. As such, a trenchless (horizontal directional drill) is recommended. It is recommended that if a trenchless method is used that frac-out monitors and mitigation measures be on site through the duration of the drill to identify and contain any drilling fluid release prior to it entering the watercourse. In the Red Earth Section 3 the Project will cross Loon River (NW 27-91-8 W5M), an unnamed tributary to Loon River (NE 28-91-7 W5M), Hunt Creek (NE 26-91-6 W5M) and three unnamed drainages located in NE 26-91-8 W5M, NE 24-91-6 W5M and NE 18-91-5 W5M (Table 5.2-2 of the ESA). The Loon River is a mapped class C watercourse with a RAP of April 16 to July 15 (Table 5.7-2 of the ESA). During the 2018 assessment, the habitat of Loon River was deemed as important habitat for all life stages of Longnose Sucker, Northern Pike and Walleye and as marginal to important habitat for Arctic Grayling (Table 3-5 of the Aquatics Technical Data Report). The substrate of the Loon River was composed of a mix of fines and gravels with some cobble and boulders present, which provides spawning and cover for fish species in the area (Appendix A of the Aquatics Technical Data Report). Fish sampling was not conducted at the time of the assessment as it was deemed that there was adequate historical information available (Table 5.7-2 of the ESA). Pisces reviewed the available information and queried FWMIS (AEP 2019) and found that there have been no documented fish surveys within 10 km upstream or downstream of the proposed crossing location. This information, being from greater than 10 km away from the crossing is not accurate for the specific location of the crossing. The current plan is to use a trenchless method to cross the Loon River (Section 5.7.3 of the ESA), which will minimize the impact that the pipeline crossing will have on the watercourse. It is recommended that frac-out monitors and mitigation measures be on site through the duration of the drill to identify and contain any drilling fluid release prior to it entering the watercourse. The unnamed drainage located in NE 26-91-08 W5M has no defined bed or banks (Appendix A of the Aquatics Technical Data Report), within the crossing location; therefore, it is not classified as a “waterbody” under the CoP (AEP 2013). However, the crossing would still require a Water Act approval as it is a standing body of water. During the 2018 assessment, the crossing was determined to be a flooded wetland due to the presence of beavers (Appendix A of the Aquatics Technical Data Report). The subject drainage has no historical documented evidence of fish presence according to FWMIS (AEP 2019), with one survey taking place in 2013 where no fish were captured. During the 2018 assessment one Brook Stickleback (Culaea inconstans) was captured (Appendix A of the Aquatics Technical Data Report). The fish habitat potential was rated as unsuitable for important fish species, such as Northern Pike and Walleye at the time of the assessment (Table 3-5 of the Aquatics Technical Data Report). The substrate of the drainage was composed solely of organic matter and the dissolved oxygen content, 2.00 mg/L at

| 8 time of assessment, is a limiting factor to fish presence (Appendix A of the Aquatics Technical Data Report). The current plan is to use an isolated open cut method if water is present or an open cut method if the watercourse is dry or frozen to bed. The unnamed tributary to Loon River is an unmapped Class C waterbody with a restricted activity period (RAP) of April 16 to July 15 (Table 5.7-2 of the ESA). The subject tributary has no historical documented evidence of fish presence according to FWMIS (AEP 2019). The 2018 assessment resulted in the capture of 124 Brook Stickleback, 84 Pearl Dace (Margariscus margarita) and 3 Finescale Dace (Chrosomus neogaeus) (Appendix A of the Aquatics Technical Data Report). The fish habitat potential was rated as unsuitable for important fish species, such as Walleye but important habitat for Northern Pike at the time of the assessment (Table 3-5 of the Aquatics Technical Data Report). The substrate of the tributary was composed solely of organic matter and fines (Appendix A of the Aquatics Technical Data Report). The current plan is to use an isolated open cut method if water is present or an open cut method if the watercourse is dry or frozen to bed (Section 5.7.3 of the ESA). Hunt Creek is an unmapped Class C waterbody with a restricted activity period (RAP) of April 16 to July 15 (Table 5.7-2 of the ESA). The watercourse has no historical documented evidence of fish presence according to FWMIS (AEP 2019). The 2018 assessment resulted in the capture of 85 Fathead Minnow (Pimephales promelas) and 64 Brook Stickleback (Appendix A of the Aquatics Technical Data Report). The fish habitat potential was rated as unsuitable for important fish species, such as Walleye but unsuitable to marginal for Northern Pike at the time of the assessment (Table 3-5 of the Aquatics Technical Data Report). The substrate of Hunt Creek was composed mostly of fines and organic matter with some gravel present (Appendix A of the Aquatics Technical Data Report). The current plan is to use an isolated open cut method if water is present or an open cut method if the watercourse is dry or frozen to bed (Section 5.7.3 of the ESA). The unnamed drainage located in NE 24-91-06 W5M has no defined bed or banks (Table 5.7-2 of the ESA), within the crossing location; therefore, it is not classified as a “waterbody” under the CoP (AEP 2013). However, the crossing would still require a Water Act approval as it is a standing body of water. During the 2018 assessment, the crossing was determined to be a flooded wetland due to the presence of beavers (Appendix A of the Aquatics Technical Data Report). The subject drainage has no historical documented evidence of fish presence according to FWMIS (AEP 2019). During the 2018 assessment one Brook Stickleback was captured (Appendix A of the Aquatics Technical Data Report). The fish habitat potential was rated as unsuitable for important fish species, such as Northern Pike and Walleye at the time of the assessment ((Table 3-5 of the Aquatics Technical Data Report). The substrate of the drainage was composed solely of organic matter and the dissolved oxygen content, 1.00 mg/L at time of assessment (Appendix A of the Aquatics Technical Data Report), is a limiting factor to fish presence. The current plan is to use an isolated open cut method if water is present or an open cut method if the watercourse is dry or frozen to bed. The unnamed drainage located in NE 18-91-05 W5M was not assigned a waterbody class or RAP as it was defined as a wetland by Jacobs, however, the drainage has a defined bankfull width within the crossing location (Table 5.7-2 of the ESA); therefore, it meets the classification of a “waterbody” under the CoP (AEP 2013). The drainage should be classed as an unmapped class C waterbody with no RAP. During the 2018 assessment, the crossing was determined to be a flooded wetland due to the presence of beavers (Appendix A of the Aquatics Technical Data Report). The subject drainage has one fish survey in 2004, approximately 2 km downstream from the crossing site, which resulted in the capture of one Brook Stickleback FWMIS (AEP 2019). During the 2018 assessment 45 Brook Stickleback were captured (Appendix A of the Aquatics Technical Data Report). The fish habitat potential was rated as unsuitable for important fish species, such as Northern Pike and Walleye at the time of the assessment (Table 3-5 of the Aquatics Technical Data Report). The substrate of the drainage was composed solely of organic matter and fines creating a homogenous habitat type. The current plan is to use an isolated open cut method if water is present or an open cut method if the watercourse is dry or frozen to bed (Section 5.7.3 of the ESA). In the Bear Canyon North Extension, the proposed pipeline project will cross Bear Canyon Creek in NE 06-84-12 W6M. Bear Canyon Creek was classed as an unmapped Class C waterbody with a restricted activity period (RAP) of April 16 to July 15 (Table 5.7-2 of the ESA). The planned crossing location of the tributary is approximately 12 km upstream from the mouth. The subject tributary has no historical documented evidence of fish presence according to FWMIS (AEP 2019) and no fish were captured or observed during the 2018 assessment (Appendix A of the Aquatics Technical Data Report). The fish habitat potential was rated as unsuitable for important fish species, but as marginal habitat for fish migration and as marginal rearing habitat for Northern Pike (Table 3-5 of the Aquatics Technical Data Report). The subject tributary had sections of undefined channel with substrate being composed of fines and organic matter. The current plan is to use an isolated open cut method if water is present or an open cut method if the

| 9 watercourse is dry or frozen to bed (Section 5.7.3 of the ESA). For most of the crossings mentioned, a low risk of HADD is expected if proper mitigation measures are in place and the watercourses are dry or frozen to bed. However, the current plan of open cutting the Notikewin River is expected to have a high risk of HADD. Provided that these crossings are properly isolated and monitored, there is a low chance of sediment introduction, and as long as the bed and banks are restored to their natural shape, there is low risk of harm to fish. However, in areas with no defined bed and banks, it can be more difficult to monitor sediment or substance releases; therefore, special care should be given to these crossings.

3.4.2. Evaluation and Recommendations a) NGTL shall directly request for input from the Indigenous stakeholders on composition of fish species and abundance within the specific watercourses associated with the Project to complement the western science knowledge evaluated for this project and conduct fish surveys where required based on this new information and to fill in data gaps where data is greater than 5 years. b) NGTL shall ensure all approvals are in compliance with the new Fisheries Act Amendment requirements prohibiting the death of fish by means other than fishing. c) If no previous approvals have been granted, provide details on what re-assessment methods will be applied to ensure that the impacts associated with the watercourse crossings are in compliance with the amended Fisheries Act, including the general prohibition on the death of fish by means other than fishing and the need to address and mitigate harmful alteration, disruption, or destruction of fish habitat.

3.5. BIOPHYSICAL SURVEY

3.5.1. Summary of ESA Content The following summarizes issues found in the biophysical survey component after a review of the following: • NGTL North Corridor Expansion Project Environmental and Socio-economic Assessment for the Proposed NOVA Gas Transmission Ltd. North Corridor Expansion Project, Section 5.10 Wildlife and Wildlife Habitat • NGTL North Corridor Expansion Project Environmental and Socio-economic Assessment for the Proposed NOVA Gas Transmission Ltd. North Corridor Expansion Project, Appendix 9 Wildlife Technical Data Report Appendix 9 states that the 2018 field work was completed outside of the appropriate timeframe for many of the necessary wildlife surveys that need to be conducted prior to construction. NGTL lists auditory amphibian surveys, breeding bird surveys, common nighthawk and short-eared owl surveys, yellow rail surveys, and ground searches for wildlife habitat features as surveys that were to be completed in spring/summer 2019. The results of these supplemental wildlife surveys were to be incorporated into the Environmental Protection Plans (EPPs) as required. The findings of these surveys should also be presented as an addendum to the original ESA and incorporated into the wildlife assessment and mitigation sections. The role of Indigenous nations in assessing wildlife habitat is not presented in the ESA and should be considered. Indigenous Knowledge of the fauna in the area can provide valuable insight in determining important habitat features that should be avoided or otherwise protected through implementation of wildlife specific mitigation measures.

3.5.2. Evaluation and Recommendations a) NGTL shall provide the completed surveys and associated reports with the findings from these 2019 surveys. b) NGTL shall complement data collected through ground surveys for wildlife habitat with Indigenous knowledge. c) CER should include as conditions to any approval, the requirement that the information from the completed surveys be incorporated in appropriate Project planning, should the Project be approved.

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3.6. ONSITE ENVIRONMENTAL MONITORING

3.6.1. Summary of ESA Content The following summarizes issues found in the implementation of onsite environmental monitoring after a review of the following: • NGTL North Corridor Expansion Project Environmental and Socio-economic Assessment for the Proposed NOVA Gas Transmission Ltd. North Corridor Expansion Project, Appendix 11 Traditional Knowledge Report NGTL states that post-construction monitoring will take place in year one of the Project following clean- up. Indigenous environmental monitors with a familiarity of the land should be involved in onsite post-construction monitoring to ensure that mitigation measures were successful in maintaining important environmental features required for the continuation of Traditional practices in the area.

3.6.2. Evaluation and Recommendations a) NGTL shall ensure that Indigenous environmental monitors with a strong familiarity of the land are engaged in onsite post-construction monitoring activities at each of the Project sites. b) NGTL shall provide an indication of the timing of potential opportunities that may be available during post- construction monitoring for Indigenous environmental monitors to attend.

3.7. WATERCOURSE CROSSINGS

3.7.1. Summary of ESA Content The following summarizes issues found in the management of watercourse crossings after a review of the following by Pisces and Solstice: • NGTL North Corridor Expansion Project, Project Description, Section 5.1.2 • NGTL North Corridor Expansion Project, Environmental and Socio-economic Assessment, Table 5.3-5 • NGTL North Corridor Expansion Project, Application, Section 7.7 Pipeline Watercourse Crossings; and Section 8.8.4 Watercourse and Road Crossing Construction • Fisheries Act Amendment-2019, c. 14, s. 22 • Mercury in Fish in Alberta Water Bodies 2009 – 2013, Alberta Health, Health Protection Branch, February 2016 • Mercury: biogeochemistry, Government of Canada https://www.canada.ca/en/environment-climate- change/services/pollutants/mercury-environment/about/biogeochemistry.html • Government of Canada 2019 Water-The Transporter • NGTL North Corridor Expansion Project, Environmental and Socio-Economic Assessment, Section 3.7.1, Traditional Knowledge Report Louis Bull Tribe significant concerns regarding the use of trenched/open cut watercourse crossing methods and its effect on aquatic resources, including water quality and fish resources as indicated by Reference ii. Aquatic resources have significant value to Indigenous nations, not only from the importance of this resource in supporting ecological functions and Traditional Use (e.g., fishing, use of medicinal plants or culturally important plants) but also in terms of the cultural importance of water as a sacred resource. The use of an open cut method in the Notikewin River is likely to introduce sediment, and potentially deleterious substances, into the watercourse. Due to the amount of flow observed in the Notikewin River at the time of the assessment it is likely that any sediment or deleterious substance introduction will impact the Indigenous Nations fishing downstream. However, a trenched (open cut) method is expected to be the least impactful in sediment introduction if the watercourses, wetlands and drainages are dry or frozen to bottom at the time of construction. For crossings that are flooded from beaver dams, such as the drainage in NE 26-91-08 W5M, it is likely that multiple drilling fluid releases will occur from an HDD, which will be difficult to spot, contain and clean up. If the watercourses are dry or frozen to bottom, it is expected that sediment introduction from an open cut method would be minimal.

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However, if water is present at the time of construction, the site should be isolated according the specifications and recommendations of a QAES, with monitoring being provided by First Nations communities, where feasible, in order to mitigate for sediment introduction into watercourses. Increased sedimentation in waterbodies can negatively affect fish populations and health through direct and indirect means. Many fish populations are already under pressure stemming from ongoing habitat loss and disturbance. As such, even the incremental addition of small projects can contribute to the overall cumulative effects that are impacting their long-term survival. Although a number of mitigation measures have been identified to limit the impacts of sedimentation, there is no mention of methylmercury and the risk of its introduction into waterbodies through sediment release. This is of considerable concern to Louis Bull Tribe as fish remain an important food source for Indigenous groups as any impacts to fish populations, including fish health has the potential to directly impact the use of this resource in terms of ability to harvest for food. In addition, there are concerns regarding the potential for bioaccumulation of methylmercury, as very little information is known about the methylation pathway. Of note, many Indigenous communities have already received Health Advisories for Fish Consumption from Alberta, including restrictions for fish consumption, especially for women and children, which contributes to concerns regarding food security in the community.

3.7.2. Evaluations and Recommendations a) Implement trenchless water crossing practices and minimize sedimentation and disturbance to wetlands, watercourses and riparian areas in compliance of the new Fisheries Act. b) For all of the watercourse crossings, trenched and trenchless, an onsite QAES will be present along with Environmental monitors from the Louis Bull Tribe to ensure that sediment and drilling fluid is properly mitigated and contained. c) Where trenchless water crossings absolutely cannot be accommodated, environmental monitors from the Louis Bull Tribe will be granted opportunities to visit the site post-construction to ensure mitigation measures were successful.

3.8. RESEEDING OF VEGETATION

3.8.1. Summary of ESA Content The following summarizes issues found in the management of reseeding of vegetation after a review of the following:

• NGTL North Corridor Expansion Project, Environmental and Socio-economic Assessment, Table 5.9-5 NGTL states that “Where natural recovery is not preferred, seed disturbed areas as per site requirements and as specified by the Environmental Inspector(s) or designate(s)” and that “seed disturbed banks and riparian areas with an approved native seed mixture and/or cover crop as directed by the Environmental Inspector(s) or designate(s).” NGTL does not highlight how the information held by Indigenous nations would be used in the process of reseeding vegetation, or if Indigenous nations would be consulted on the composition of species included in the native seed mix. The Louis Bull Tribe should be consulted on areas that are left to reclaim naturally to determine whether culturally important plant species will successfully regrow. In areas deemed to require reseeding, the content of the native seed mix should be approved by the Louis Bull Tribe as the primary user of the land, to ensure areas are restored to their ecological and traditional use capacity.

3.8.2. Evaluation and Recommendations a) Clearly state how NGTL will involve and consult with the Louis Bull Tribe regarding the natural regeneration of culturally important plant species and whether or not additional mitigation may be required to facilitate regeneration of these plant species in certain areas. b) Clearly state how input from Louis Bull Tribe will be used to inform or adjust the plant species composition of seed mixes to ensure that they meet traditional use needs. 4. CONCLUSION

During meetings with the Louis Bull knowledge keepers, elders and staff to prepare this report, it was established that there is a strong connection between some Louis Bull members and the areas within and surrounding Project area.

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The Louis Bull Tribe has expressed concerns with respect to both direct and indirect effects of the Project. These concerns span both the ecological and cultural realms and include concerns regarding potential impacts to water resources, fish, soils, wildlife, vegetation, including medicinal and culturally important plants, as well as community, cultural and socioeconomic wellbeing. Some key areas that were identified during the technical review include, but are not limited to: Terrain and Soils: inadequate mitigation measures regarding permafrost; information critical to clearly identifying soil handling and limitations on the alignment sheets and in the EPP needs to be rectified. Vegetation and Wetlands: issues and mitigation measures pertaining to medicinal and traditional plants used for harvesting noted in this review need to be addressed. Wildlife and Wildlife Habitat: limited scope and issues of seasonality with wildlife surveys, resulting in many pre- construction wildlife surveys not being completed (e.g., amphibian surveys, breeding bird surveys, common nighthawk and short-eared owl surveys, yellow rail surveys, and ground searches for wildlife habitat features). These surveys will need to be completed prior to construction and the Louis Bull Tribe must be provided with opportunities to participate in wildlife surveys. Fish and Fish Habitat: information that is critical to the assessment is missing from the baseline data (such as updated fish surveys that include indigenous knowledge, where required); re-evaluation of the watercourse crossing for the Notikewin River as there is a high risk of ensuing harmful alteration, disruption, or destruction (HADD) of fish habitat, as described under the amended Fisheries Act. Water Quality and Quantity: issues and mitigation pertaining to sedimentation risk and impacts to fish and fish health. The inability to engage in Traditional practices has impacts that are of major concern to the Louis Bull Tribe. These practices are in preserving culture, transmitting skills and knowledge to the youth and future generations, and in maintaining food security for the community. Of great concern to Louis Bull are aquatic resources, which have significant value to Indigenous Nations, not only from the importance of this resource in supporting ecological functions and Traditional Use (e.g., fishing, use of medicinal plants or culturally important plants) but also in terms of the cultural importance of water as a sacred resource. Water is tied to every aspect of the Traditional way of life and the quantity and quality of the water on the landscape has declined with the increased level of development in the area. Projects that cross, or otherwise impact waterbodies are of particular concern, as many fish populations are already under pressure stemming from ongoing habitat loss and disturbance. As such, even the incremental addition of small projects can contribute to the overall cumulative effects that are impacting long-term survival of fish populations. Additionally, access to and continued perpetuation of populations of medicinally and culturally important plants are critically important to the Louis Bull Tribe, as Traditional plant medicines play a large role in Traditional practices. However, the availability of these plants has declined in the Louis Bull traditional territory, due in part to increased fragmentation of the landscape from linear development projects such as the one examined by this review. Medicinally and culturally important plants are typically not considered during the revegetation process for many of these projects and as a result there is potential for increased loss of medicinally and culturally important plants. This may be exacerbated by the practice of vegetation control through herbicide spraying along Rights of Way, which may have detrimental effects to the health of adjacent ecosystems and the traditional and medical use plants that occur there. As part of proper consultation and accommodation of Treaty Rights as an Indigenous Nation, Louis Bull Tribe should have meaningful involvement in monitoring and oversight through the lifecycle of this proposed Project. This includes acknowledgement and incorporation of traditional knowledge in Project planning phases, as well as providing opportunities for on the ground environmental monitoring and collaborative input into adaptive management strategies. In addition to consultation with Louis Bull Tribe in respect of Project specific impacts, both the Crown and NGTL should consult with Louis Bull Tribe with respect to the cumulative impacts that are arising from, and may be contributed to, by the Project. Through true collaboration, Louis Bull Tribe can ensure that their interest and rights are given due consideration and thus, ensure that a high standard of environmental protection and oversight is attained.

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5. REFERENCES

Alberta Environment and Parks (AEP). 2019a. Fish and Wildlife Management Information System (FWMIS). Retrieved November 27, 2019 from https://maps.srd.alberta.ca/FWIMT_Pub/default.aspx?Viewer=FWIMT_Pub on. Alberta Environment and Parks (AEP). 2018. Alberta Merged Wetland Inventory. Government of Alberta, Edmonton, Alberta. Alberta Environment and Parks (AEP). 2018. Master Schedule of Standards and Conditions. Government of Alberta, Edmonton, Alberta. Alberta Environment and Parks (AEP). 2013. Code of Practice for Pipeline and Telecommunications Lines Crossing a Water Body (made under the Water Act and the Water (Ministerial) Regulation). Queen’s Printer for Alberta Canada Land Inventory, National Soil DataBase, Agriculture and Agri-Food Canada. 1998. Fisheries and Oceans Canada (DFO). 2019. Fish and Fish Habitat Protection Policy Statement from https://www.dfo- mpo.gc.ca/pnw-ppe/policy-politique-eng.html on November 27, 2019. Ottawa, Ontario. 31 pp. + App. National Energy Board. 2017. Filing Manual. National Energy Board, Calgary, Alberta. NGTL. 2018. NGTL North Corridor Expansion Project. Environment and Socio-Economic Assessment. Pawley, S.M. 2018. Generalized outlines of northern Alberta regions containing permafrost (GIS data, polygon features); Alberta Energy Regulator, AER/AGS Digital Data 2018-0010. Pawley, S.M. and Utting, D.J. 2018. Permafrost Classification Model for Northern Alberta (gridded data, GeoTIFF format); Alberta Energy Regulator, AER/AGS Digital Data 2018-0008. Research Council of Alberta. 1957. Exploratory Soil Survey of Alberta Map Sheets 84-C (east half), 84-B, 84-A, and 74-D. Preliminary Soil Survey Report 58-1. Edmonton, Alberta.

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APPENDIX A. CVS OF REPORT CONTRIBUTORS

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Louise Versteeg BSc, P.Biol., QWSP Senior Terrestrial and Wetland Ecologist Louise is the biophysical and regulatory team lead with Solstice. With over 20 years’ experience as a terrestrial and wetland ecologist, Louise has an extensive background in ecology, vegetation, wetlands, soils and wildlife. Through her experience in environmental consulting and in municipal environmental and regulatory compliance, Louise has acquired an excellent understanding of the regulatory and permitting processes at all level of government (municipal, provincial, territorial and federal) and has successfully navigated projects through various permitting and approval processes. She has worked throughout western and northern Canada undertaking and directing environmental impact assessments, as well as vegetation and wetland monitoring programs for a wide range of industries including mining, oil and gas, pipelines, municipalities and land developers. As a Professional Biologist, Louise is registered as a Wetland Practitioner under the provincial Wetland Policy and has extensive experience in overseeing and completing wetland inventories and assessments for various projects. She has also applied her expertise to support First Nation’s clients by providing senior technical support for technical reviews of pipeline environmental impact assessments and environmental sensitivity mapping projects.

With her experience in developing and implementing municipal policies, various management plans, ecological and wetland monitoring programs and completing environmental impact assessments, Louise had developed insight into the complexities associated with critically evaluating complex information and balancing competing needs from various stakeholders.

SELECT PROJECT EXPERIENCE • Managed and conducted the vegetation and wetland components of environmental impact Environmental assessments for various Oil Sand In-Situ operations in northeastern Alberta, and oil and gas Impact operation in northeastern British Columbia, including Meg Energy In-Situ Oil Sands, CNRL Assessments Kirby In-Situ Oil Sands, Cenovus Grand Rapids In-Situ Oil Sands, Shell Gundy, Shell Groundbirch, and Shell PRM. Instrumental in undertaking and directing vegetation and wetland baseline field studies and mapping components, as well as environmental impact and cumulative effect assessment data analysis and reporting (2007 – 2014). • Managed and conducted the vegetation and wetland components of environmental impact assessments for various TCPL pipeline projects in Alberta. Provided senior technical review and direction for completing vegetation and wetland baseline studies, as well as environmental impact and cumulative effect assessments, and regulatory permitting both provincially and federally through the NEB Section 52 and 58 application processes (2010 2014). • Managed and conducted the vegetation and wetland components of environmental impact assessments for several mining projects in Nunavut and the Northwest Territories, including the Meliadine EIS, Fortune Minerals EIS and Dominion Jay EIS. Instrumental in undertaking and managing vegetation and wetland baseline field studies and mapping components, as well as environmental impact and cumulative effect assessment data analysis and reporting (2008 – 2013). • Involved in the preparation of the vegetation and biodiversity components of two international environmental impact assessments for mining operations in South America and Africa (2008 – 2010). • Provided third-party technical reviews of the vegetation and wetland components of environmental impact assessments for various clients. • Directed and under took field data collection in support of environmental baseline studies including the collection of vegetation, site and soils data, along with wildlife habitat data for the purposes of ecological classification, field surveys and ecological research (1997 – 2016).

• Provide senior technical review and direction of various information requests and technical First Nations reviews to support First Nations clients in the consultation process with the National Energy Related Board / Canada Energy Regulator (2019). Experience • Provide senior technical review and direction for an environmental sensitivity mapping project for First Nation clients (2019). • Incorporated Traditional Ecological Knowledge (TEK) and Traditional Land Use information into the vegetation and wetland sections of several environmental assessments for various

| 1 Louise Versteeg, B.Sc., P.Biol., QWSP

mining and oil sands SAGD projects in northern Alberta, Nunavut and the Northwest Territories (2007 – 2014). • Developed and taught portions of an Environmental Monitoring Field Course to First Nations students at Keyano College.

• Worked collaboratively with colleagues, university researchers and government and industry Environmental partners on a caribou habitat linear restoration research project investigating the Research and effectiveness of enhancing vegetation recovery times through the application of site Monitoring treatments such as tree planting (2014 - 2015). • Managed, developed and implemented a statistically designed multi-year wetland monitoring program for assessing impacts to peatland wetlands to meet approval requirements for the CNRL Kirby In-Situ Oil Sand Project operational site. This required an understanding the needs of the client, regulatory requirements and ecological conditions of the site to develop the most effective monitoring program to achieve the desired results. Information was synthesized from various disciplines to design a monitoring program that effectively used critical threshold points as triggers for implementing management decisions (2011 – 2015). • Worked collaboratively with colleagues to develop and implement multi-year wetland monitoring programs for Cenovus Christina Lake and Brion Dover In-situ Oil Sands Projects. • Worked collaboratively with colleagues to complete various annual Vegetation Monitoring Programs to assess the effect of dust impacts on surrounding plant communities at the Diavik Diamond Mine in support of regulatory approval conditions. This involved field data collection, as well as statistical analysis of collected vegetation data to determine the impact of dust on vegetation communities adjacent to the active mine site.

• Worked with municipal planners and developers to develop policy frameworks and Municipal associated implementation procedures for a biophysical assessment process based on an Planning and integrated management concept for Parkland County (2016 – 2019). Environmental • Provided input and compiled sections of the environmental component of the Municipal Regulatory Development Plan for Parkland County (2017). Compliance • Reviewed biophysical assessments and other planning and development documents submitted as part of planning applications to ensure compliance with applicable municipal and provincial regulatory requirements (2016 – 2019). • Provided professional and technical oversight on environmental matters to managers and directors, as well as community led organizations, such as lake and watershed groups (2016 – 2019). • Represented Parkland County Administration at Subdivision and Development Appeal Board Hearings and provided professional technical advice pertaining to Administration’s position on various gravel pit and subdivision applications (2016 – 2019). • Presented technical information to Parkland County Executive Committee and Council where required (2016 – 2019).

Wetland • Senior technical review of compiled field data collection and associated analytical and reporting products. Assessments • Experience with the Alberta Wetland Policy and Water Act, Alberta Wetland Rapid Evaluation Tool (ABWRET-A and ABWRET-D) • Experience with wetland identification, classification, and delineation in accordance with provincial wetland related directives. • Preparation and submission of wetland related applications for approval under the Alberta Water Act.

| 2 Louise Versteeg, B.Sc., P.Biol., QWSP

ACADEMIC BACKGROUND B.Sc. in Ecology 1996 University of Calgary, Calgary, AB.

PROFESSIONAL AFFILIATIONS AND CERTIFICATIONS • Alberta Society of Professional Biologists • Qualified Wetland Science Practitioner

TRAINING Current Safety • Standard First Aid with Class C CPR & AED Training • Workplace Hazardous Material Information System (WHMIS) Training

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Michelle Cotton, B.Sc., P.Ag. President/Senior Environmental Scientist Michelle Cotton is the President and Senior Technical Advisor with Solstice Canada Corp. She has 30 years’ experience as an environmental consultant. The first half of her career Michelle focused primarily on assessment, remediation and reclamation activities for upstream oil & gas activities. Based on some important learnings from working in remediation and reclamation activities, Michelle has put a huge emphasis during the last 15 years of her career on baseline assessments, conservation and reclamation planning, and liability assessments in order to help her clients plan better developments and reduce their future liabilities. Her experience with full life cycle oil and gas environmental activities allows her to support her clients to develop and to operate in an environmentally sustainable way. Michelle’s professional development over the past 10 years has largely focused on understanding the relationship of indigenous people to responsible resource development.

SELECT PROJECT EXPERIENCE Environmental • Provided soils, vegetation and conservation and reclamation expertise for the following six environmental impact assessments as a third-party reviewer/contractor for Alberta Impact Environment: Assessments o (2007-2009) –Shell Carmon Creek In-Situ Oil Sands (application withdrawn in review process). o (2008-2009) –CNRL Kirby In-Situ Oil Sands. o (2009-2011) –Cenovus Christina Lake In-situ Oil Sands. o (2010-2011) –Cenovus Narrows Lake In-situ Oil Sands. o (2011-2013) –Laricina Germain In-Situ Project. o (2012-2014) –Cenovus Telephone Lake In-situ project.

• Conducted a gap analysis and provided professional opinion regarding potential environmental Environmental liability on multiple commercial facilities in central and northern Alberta for TransAmerica Site Group, The Truck Outfitters, Dave Austin Investments Ltd., Cleall Barristers Solicitors, and Assessment, McCuaig Desrochers LLP. Liability • Conducted a data gap analysis and designed and conducted a supplemental soil characterization Assessment & program at Domtar, a 37 ha former wood-preserving site located in Edmonton, for development of a risk management plan for the facility. The detailed assessment included evaluation of Management concentration and mobility of Pentachlorophenol (PCP), Copper, Chromium (total and VI+), and Arsenic in soils. Assisted with the regulatory re-zoning of the land with multiple government agencies (environment, city, health). • Supported a client in response to a significant regulatory change regarding asset accounting to the Alberta Energy Regulator (AER), which consisted of conducting a liability assessment program, including Phase I and Phase II ESAs and providing initial deemed liability cost estimates as per AER Directives 001, 006, and 024 for 36 large industrial facilities (gas plants) in Alberta. • Conducted a pre-purchase site assessment and provided liability cost estimates for 31 industrial assets in northwestern Alberta. • Senior Technical Lead and Reviewer for 87 Phase I ESAs, and 40 Phase II ESAs on abandoned wellsites and associated facilities in northwestern Alberta. • Project Manager and Senior Technical Lead of a multi-million dollar Phase I and II ESA, remediation planning, and liability estimate project involving 40 abandoned battery sites in Zama, Alberta. • Designed and managed ESAs and made remediation recommendations on over 180 facilities (including wellsites, satellites, batteries, flarepits, production complexes, gas conservation plants) in the areas of Whitecourt, Judy Creek, Devon, Big Lake, Joffre, and central Alberta. Participated in Divestment Projects on many of these same facilities. • Managed the investigation, provided government liaison, and made remediation recommendations of a produced water spill in Fort Assiniboine from a flare stack release. • Developed soils sampling and site assessment protocol for industry and government (development of a site assessment guide for the upstream oil and gas industry). • Conducted a liability assessment and provided liability cost estimates on 4 wellsites in Leduc County that we impacted by a historic pipeline release. The salinity impacts extended over an area of >8 ha. The assessment was part of a property transfer requirement to allow the client to

Michelle Cotton, B.Sc., P.Ag. make an informed decision regarding the liability responsibilities involved in acquiring and managing the assets. The assessment revealed >$40 Million dollars in environmental liability. • Project manager, senior technical soils lead, and regulatory liaison for the soil and sludge Assessment & assessment and clean-up of over 215,000 m3 of material, and the associated reclamation of 24 Remediation hectares for a high regulatory profile well blowout site. At over 48-million litres (48,000 m3), this was the largest spill in Alberta history to date at the time, and bordered both the City of Edmonton and the Enoch Cree Nation across from what is now the River Cree Resort & Casino. • Project Manager for the excavation and remediation of over 6,000 m3 of impacted soil associated with a former condensate tank and flare pit at a sour gas processing facility in Zama, Alberta. • Project Manager and Senior Technical Lead (Remediation and Reclamation) for a $3.8 million project in the Consort area focusing on addressing the assessment, removal and remediation of over 100,000 m3 of hydrocarbon and/or salt impacted soil originating from 200 underground containment devices associated with wellhead and dehydration units. • Project Manager and Senior Technical Lead for the assessment and remediation of a pipeline break involving eight intersecting underground pipelines, and directed the excavation, closure sampling and disposal of approximately 7,000 T of hydrocarbon impacted soil. • Assessment, excavation and closure sampling for a pipeline break in northern Alberta of approximately 2,000 m3 of salt and hydrocarbon impacted soil. • Project manager and technical expert for the design, implementation, and monitoring of two field-scale aerated static pile treatment units (1800 m3), as well as a land treatment approach to flare pit remediation in Willesden Green. • Co-designed and constructed a field-scale biopile, addressing a large volume of hydrocarbon- contaminated soil in Devon, Alberta. • Project manager and technical expert for the design, construction, and monitoring of two subsurface "biopockets" to address 800 m3 of flare pit waste and 900 m3 of amine and lube oil contaminated soil in central Alberta. • Assessed and remediated approximate 6000 tonnes of soil contaminated with hydrocarbons and organic halides utilizing a mobile thermal remediation unit. • Co-designed and implemented bench-scale landfarming and composting to optimize the bioremediation of flare pit sludge from multiple Alberta sites. A joint project between industry and government. • Co-designed, constructed and remediated severely acidified soils resulting from acid leaching from a former sulphur block and associated runoff pond in central Alberta

• Senior technical advisor to evaluate potential environmental liability and estimate the Legal/Insurance percentage of land owner responsibility between multiple land users. Conducted a third-party Related Projects review of existing Phase II ESA reports for a property located in Devon, Alberta, and to provide a summary of irregularities, discrepancies, and/or omissions found within the ESAs for Cleall Barristers Solicitors (later McCuaig Desrochers LLP). • Senior technical advisor for a liability assessment of a commercial property in Vegreville to determine the presence or absence of contamination liability in a context that might impact the price of the property or impact future development of the property prior to purchase. Acted on behalf of the purchaser for McCuaig Desrochers (LLP). • Senior technical advisor/agronomic expert witness, examination for discovery to evaluate the potential environmental liability and estimate the volume of pesticides applied by a County representative in the vicinity of a dug out providing water for a greenhouse operation. Acted on behalf of the County. • Technical lead to provide volume estimates of soil and sludge released during a wellsite blow out and allocated the volumes of waste between 3 different insurance policies. • Senior technical lead to provide volume estimates of oil well effluent released during a pipeline spill to assist the forensic engineers (Sintra Engineering) in determining the timing of the release on 2 different files/sites in northern Alberta. • Reviewed a gas well release file on behalf of Sintra Engineering to determine if an estimate of volume of gas could be calculated with existing data to determine the timing of the release.

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Michelle Cotton, B.Sc., P.Ag. • Conducted an audit and inspection report of over 170 wellsites specifically addressing Environmental compliance to Alberta Energy Regulator (AER) Directive 58 (Oilfield Waste Management Audits and Requirements for the Upstream Petroleum Industry, November 1996) and Directive 55 (Storage Reviews Requirements for the Upstream Petroleum Industry, December 2001).

• Program Manager and Senior Technical Lead on the Soil Monitoring Programs (SMPs)/Soil SMP & SMaPs Management Programs (SMaPs) for 14 Gas Plants for multiple reporting periods over the past 14 years.

Commercial • Conducted and/or provided Senior Technical Support on numerous Commercial Phase I Environmental Site Assessments on commercial properties in Athabasca, Smoky Lake, Zama City, Phase I ESA Edmonton, and Fort Saskatchewan for companies such as Big Eagle, All Reach Glass, Rain Main Irrigation, Dave Austin Investments Ltd., TransAmerica Group (TAG), and SGS Canada Inc.

• Solstice Program Manager & Senior Technical Lead of a multi-million dollar Pre-Disturbance Pre-Disturbance Assessment and Conservation & Reclamation (PDA C&R) plan project involving Field Teams/GIS Assessments Teams/Reporting Teams, and multiple sub-contractors involving 200+ multi-pad facilities, and and several km of pipeline and other linear facilities in the Cold Lake area (2008 to 2015). Conservation & • Program Manager and Senior Technical Lead for the PDA C&R program for an expansion project Reclamation involving 16+ facilities including multi-pads, pipelines and other linear disturbances in the Fort McMurray area (2011-2014). Planning/ • Senior Technical Lead for the preparation of the construction (soil salvage) packages for an Construction expansion project involving 16 facilities including multi-pads and pipelines in the Fort McMurray Management area (2011-2012). • Senior Technical Support & Review for an 11 km Disposal Pipeline Right-of-Way in the Fort McMurray area, and a 4.4 km Pipeline Right-of-Way in the Cold Lake area.

• Project manager and technical lead for the design, operation, and monitoring of a growth Herbicides/Pest chamber and three year field study addressing the remediation of herbicide-treated soils at icides – abandoned oil and gas sites in Alberta. A joint project between government and industry. Remediation & • Responsible for compiling a database of the chemical and physical properties of pesticides. This Environmental data was utilized to conduct an initial evaluation of the environmental significance of individual Modeling pesticides used in Alberta by ranking them according to mobility, persistence, and toxicity. Project conducted as part of the Canada-Alberta Environmentally Sustainable Agriculture (CAESA) agreement. • Evaluated the trends in agricultural pesticide sales data in Alberta, and responsible for producing a suggested list of pesticides for initial provincial and regional monitoring in Alberta for the "Phase II: Selection of soil landscape units and study design considerations for the surface water quality and monitoring program", funded by CAESA. • Responsible for the adaptation and utilization of a six compartment multi-media FUGACITY model to predict environmental concentrations of 28 commonly used agricultural pesticides in Alberta, and to use those predictions to identify appropriate environmental media for monitoring. The model was applied to 7 Soil Landscape of Canada polygons within Alberta known to have a high use of pesticides. Funded by Alberta Environmental Protection and the Pesticide Management Regulatory Agency. • Surveyed government and industry regarding the extent of residual herbicide use in the oil and gas industry. Produced a published government report regarding the results of the survey.

First Nations • Solstice Canada Aboriginal Collaboration Initiative: Co-developed a joint venture with an Aboriginal training organization (TSAG) to build working relationships with indigenous owned Related companies and initiatives. Experience • Dene Tha’ First Nation (DTFN): o Member of the Management Team of the corporate arm (N’deh Limited Partnership) of the DTFN working to support environmental initiatives, reduce liability, and build local capacity. o Working with the DTFN Operations and Management (O&M) department and INAC to reduce the environmental issues inventory at the Hay Lake, Upper Hay Lake and Bushe Reserves through Phase I & II ESA, and remediation/reclamation program.

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Michelle Cotton, B.Sc., P.Ag. o Both learning from and teaching local community members in environmental monitoring on the environmental assessment projects on DTFN ancestral lands. • Saddle Lake First Nation: o Working directly with the O&M department and INAC to reduce the environmental issues inventory at the Saddle Lake Reserve. o Both learning from and teaching local community member in environmental monitoring during the execution of this project. • Enoch Cree Nation (ECN): o Worked with ECN to acquire over 200,000 m3 of backfill material and resources (local environmental monitors) from the Band to facilitate site reclamation of the blow out site. o Senior technical lead on the assessment, remediation and reclamation of a pipeline break on Reserve. Working with Indian Oil & Gas and the ECN farmers where the pipeline transected.

• Provided senior technical support and senior review of a site-wide monitoring plan, a sediment Other and erosion control plan, and a conceptual closure and reclamation plan for an oil and gas development in the Northwest Territories. • Developed and conducted 2 bench sale bioremediation studies (landfarming, composting) in joint research ventures between Alberta Research Council and Imperial Oil Resources. • Peer reviewer for Dupont Canada/Ajax Ontario Bioremediation Feasibility Study. • Developed the curriculum and co-instructed (Michelle Cotton/Brent Moore) the Remediation Technologies: Soils and Groundwater Course at the University of Alberta, Faculty of Extension, Winter 2002 session. • Conducted bioassays and did dose response curves for multiple crops involving multiple herbicides on Alberta and Saskatchewan soils. • Designed vegetation control programs for hundreds of oil and gas facilities across Western Canada. • Conducted training programs for Alberta, British Columbia, and Saskatchewan herbicide applicators licenses for over 100 students over a 3-year period.

• Delegate at the Alberta Trade and Investment Mission to China: Guangzhou, Shanghai, Yantai, China November 21 to 26, 2016, additional travel to B2B meetings in Ningbo Experience • Presented at the Alberta-China Soil Remediation Seminar, Beijing Nov 29, 2016 • Alberta Delegate at the CNPC Energy & Environmental Seminar March 17th, 2017 Beijing. • Delegate at the China International Petroleum & Petrochemical Technology Exhibition (CIPPE) March 19th to 22nd, 2017 • Presented at the Canadian Energy & Clean Technology Showcase Seminar March 21st, 2017 Beijing. • Delegate at the Environmental Outreach Program: Beijing Coking Plant, Zhongke Dingshi

Environmental Engineering, Environmental Protection Research Institute of Light Industry, Beijing, March 23rd, 2017 • Toured the waste treatment facilities in the Shengli Oilfield in Dongying with Nelson Environmental and Vitalus Technolgoies where we met with a waste treatment facilities and local government officials who were interested in partnerships with technologies from Alberta. • Delegate at the IFAT/IE Expo 2017 in Shanghai May 3rd to 5th, 2017 – a leading trade fair for environmental technology solutions. • Delegate at the 5th International Forum & Exhibition on Contaminated Site Remediation May 4th th to 6 , 2017. • Delegate at the Government of Alberta, Edmonton Economic Development (EEDC) and Calgary

Economic Development (CED) Shandong-Alberta trade and Investment Promotion Seminar, May 9th, 2017. • Delegate at the Alberta Innovates Exploring Global Partnerships between Alberta, Canada and Shjiang, China, May 17th, 2017. • Delegate at the Global Petroleum Show (including the International showcase featuring China), Calgary Alberta, June 11 to 14th • Delegate at the 4th Annual Sino-Canadian Oil and Gas Symposium hosted by Chinese Professionals and Entrepreneurs Association of Calgary (CPEAC), Canada China Chamber of

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Michelle Cotton, B.Sc., P.Ag. Commerce Alberta (CCCC), and the Canada China Commercial Association (CCCA) at the Sheraton Suites Calgary, June 10th, 2017. China • Delegate and presented at the Canada China Cleantech Trade Mission, Shanghai, Nanjing & th th Experience Beijing, Dec 4 to 8 , 2017 • Invited panel speaker by the Honourable Catherine McKenna, Canadian Minister of Environment (con’t) and Climate Change, and China Council for International Cooperation on Environment and Development (CCICED) Executive Vice Chair for Session 1: Technological, Financial and Business Model Innovation, the Drivers of Green Development, at the CCICED 2017 AGM Environment and Development Open Forum for Business Roundtable on Innovation and Green Development, Diaoyutai State Guesthouse, Beijing, Dec 9th, 2017 • Delegate and speaker at the Alberta Environment and Clean Technology Mission to China; Alberta-Sichuan Environment and Clean Tech Seminar, Chengdu; Alberta-Zhejiang Environment and Clean Tech Seminar & Outreach site visits, Hangzhou; and China-Canada (Alberta) Soil Remediation Technology Seminar, Hangzhou January 21 to 30th, 2018

ACADEMIC BACKGROUND Course work (10 graduate level courses), laboratory & field-based research in Soils & Plant Science, laboratory instructor (TA) in weed science: University of Alberta (1990 – 1996) Research project title: Remediation/Reclamation of Soils Treated with Non-selective Residual Herbicides (Soil Sterilants) University of Alberta, Edmonton, AB. B.Sc. in Agriculture 1988 University of Alberta, Edmonton, AB.

PROFESSIONAL AFFILIATIONS AND CERTIFICATIONS • Canadian Land Reclamation Association • Alberta Institute of Agrologists • International Association for Impact Assessment

• Cotton, M., Neville, L.A., Kelly, S., Auger, J., Laboucan, L., Foster, M., Lorentz, B. 2019. The future Select of reclamation: an integration of western science and traditional knowledge to reconstruct Publications & natural environmental background in a world of climate change. Presentations • Comparelli, S., Beasse, M., Cotton, M. 2016. Fermentation under well pads on peatlands and its influence on toluene biogenesis. Canadian Land Reclamation Conference, Alberta Chapter, Red Deer Alberta, Feb 2016 • Beasse, M., Comparelli, S., Cotton, M. 2016. Modelling the influence of well pads on toluene biogenesis in peatlands. Alberta Soil Science Workshop, Grande Prairie, Alberta, Feb 2016 • Cotton, M., Kelly P. 2005. Well Blowout in Acheson Alberta, Emergency Response and Environmental Management. Remediation Technologies Symposium 2005. Banff, Alberta • Cotton, M.M., G. Byrtus, A.M. Anderson, and M.P. Sharma. 1996. Multi-media modeling of pesticide residues in the aquatic and terrestrial environment. Alberta Environmental Protection. • Cotton, M.M. 1995. Pesticide characteristics and a preliminary assessment of the potential environmental significance of pesticides to surface water. In: Cross et al. 1995. Phase 2. Selection of soil landscape units and study design considerations for the surface water quality monitoring program - Appendix B1. CAESA Water Quality Monitoring Committee. • Cotton, M.M. and G. Byrtus. 1995. Pesticide sales trends in Alberta. In: Cross et al. 1995. Phase 2. Selection of soil landscape units and study design considerations for the surface water quality monitoring program - Appendix B1. CAESA Water Quality Monitoring Committee. • Cotton, M.M. and M.P. Sharma. 1993. Reclamation techniques for soil treated with non-selective residual herbicides (soil sterilants). Alberta Land Conservation and Reclamation Council Report No. RRTAC 93-12. 84 pp. • Oil Degrading Fungus Isolated from the Waste Soil Matrix of a Flare Pit in Western Alberta. C. Qualizza, M. Cotton, R.S. Currah. Poster Presentation. 4th Annual Symposium on Groundwater and Soil Remediation, September 21-23, 1994. Calgary, Alberta. • Cotton, M.M. and M.P. Sharma. 1991. Reclamation of sterilant affected sites: A review of the issue in Alberta. Alberta Land Conservation and Reclamation Council Report No. RRTAC 92-1. 64 pp.

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Michelle Cotton, B.Sc., P.Ag. TRAINING • Mental Health First Aid Current Safety • Advanced Driver Training • Construction Safety Training System (CSTS) • Respirator Fit Testing Training • Excavation and Trenching Safety • Safety Leadership Performance • Exxon Mobil Fundamentals of Safety for Development I & II (Behavioral based Safety Leaders (EMFOS) Leadership Program) • Fire Extinguisher Training • Standard First Aid with Level C CPR • Fundamentals of Safety for Workers • Wildlife Awareness • H2S Alive • Workplace Hazardous Materials Information • Leadership in Safety Excellence System (WHMIS)

• Alberta Professional Biologists Conference 2019 – Connecting Biologists to their Resources, Lake Select Louise (Nov 2019) Professional • Environmental Services Association of Alberta – Remediation Technologies Symposium – Banff Development (Oct 2019) • Environmental Services Association of Alberta – Remediation Technologies Symposium – Banff (Oct 2018) • Alberta Soil Science Workshop – Harnessing Big Data to Advance Soil Science (Feb 2018) • Environmental Services Association of Alberta – Regulatory and Government Updates Forum (Nov 2017) • Remediation Technologies Symposium – Banff (Oct 2017) • The 5th International Forum & Exhibition on Contaminated Site Remediation -Shanghai, China (May 2017) • Remediation Technologies Symposium – Banff (Oct 2016) • 2016 Peatland Reclamation Criteria Roll Out – Grande Prairie (Feb 2016) • Alberta Soil Science Workshop – Challenges and Opportunities in the Management of Northern Soils, Grande Prairie (Feb 2016) • Environmental Service Association of Alberta Regulatory Forum – Regulatory Updates, Edmonton (Jan 2016) • Forest Reclamation Field Tour, Peace River, NAIT Boreal Research Institute (Sept 2015) • Aboriginal Participation in Land Reclamation: Enhancing the Dialogue (Mar 2015) • Alberta Soil Science Workshop, Edmonton Alberta (Feb 2015) • Canadian Land Reclamation Association General Meeting and Conference (Feb 2015) • Alberta Tier 2 Guidelines Training Workshop (Jan 2015) • Sustainable Peatland for ‘in situ’ Oil Sands, NAIT Boreal Research Institute (Sept 2014) • Aboriginal Cross-Cultural Workshop – Edmonton Chamber of Commerce (May 2014) • University of Calgary’s Aboriginal Relations Leadership Participatory Certificate (Feb 2014) • Canadian Soil Science Workshop, Calgary Alberta (Feb 2014) • 33rd Annual Conference of the International Association for Impact Assessment (May 2013) • Calliou Group’s Aboriginal Awareness Training (April 2011) • Dale Carnegie’s Effective Communication and Human Relationships (Feb 2010)

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Johnathan Potter, M.Sc., P.Ag. Senior Environmental Scientist John has 12 years of experience in managing and conducting field work and reporting for Phase I Environmental Site Assessments (ESAs), Detailed Site Assessments, Phase II ESAs, and contaminated site remediations. Since 2008, John has managed the field and reporting programs for several large Pre-Disturbance Assessment and Conservation & Reclamation projects in Northern Alberta. Some responsibilities involved in this include: controlling the technical, quality, schedule, and financial aspects of project management; collecting and interpreting soil, vegetation, and aquatic data; completing soil, rare plant, ecosite, and weed surveys; overseeing Pre-Disturbance Assessment and Conservation & Reclamation plan writing and reviewing; and field program management of soil salvage/construction monitoring and surface water quality monitoring programs. Since 2016, John has applied his technical experience on a projects for First Nations clients across Alberta including undertaking ESAs, traditional land use studies, providing technical reviews of pipeline environmental impact assessments, undertaking groundwater, surface water sampling monitoring programs, as well as completing various Indian Oil and Gas (IOGC) audits.

SELECT PROJECT EXPERIENCE • Coordinated and lead several contaminated site assessments field projects for various First ESAs, Nations, oil and gas, commercial, and industrial clients (2008-2019) Reclamation & • Prepares and assists with reporting for Phase I and II ESAs for various First Nations, oil and gas, Construction commercial, and industrial clients (2008-2019). Monitoring • Coordinated and monitored reclamation projects on decommissioned oil and gas sites (2010- 2019). • Lead and assisted in conducting Detailed Site Assessments for various reclamation sites (2010- 2019). • Monitored construction crews during the salvaging and conserving of topsoil as a qualified environmental field inspector in the Cold Lake and Fort McMurray areas. (2010-2012)

• Coordinated field and safety logistics and conducted field work for a traditional land use field First Nations assessment in western Alberta (2019) Consultation • Reviewed traditional land use assessments for technical accuracy and clarity (2019) • Wrote and reviewed several information requests and technical reviews to support First Nations clients in the consultation process with the National Energy Board / Canada Energy Regulator (2019) • IOGC audits for contaminated sites on various reservations across Alberta (2017-2019)

• Installed and sampled groundwater wells for monitoring programs with various First Nations and Wetland and industrial clients Groundwater • Completed surface water quality monitoring activities for various first nations and in-situ oil & gas Assessments clients which included on-site analysis of depth, pH, conductivity, temperature, and dissolved oxygen as well as laboratory sampling and analysis for nutrients, metals, and hydrocarbons. (2016-2019) • Experience with the Alberta Wetland Policy, Alberta Wetland Rapid Evaluation Tool (ABWRET-A), electrofishing, and hydrologic surveys for pipeline crossings. (2017-2019) • Experience with watercourse classification, erosion and sedimentation hazard, and culvert status and fish passage evaluation assessments using the “ESRD/Roadway Watercourse Crossing Inspection Protocol”. (2015-2018) • Experience classifying wetlands according to the Canadian Wetland Classification System. (2015- 2019) • Experience quantifying the effect of forestry and range related disturbances on water quality using the BC Ministry of Forests and Range Forest and Range Evaluation Program’s document titled “Protocol for Evaluating the Potential Impact of Forestry and Range Use on Water Quality (Water Quality Routine Effectiveness Evaluation)” (2015-2017)

| 1 Johnathan Potter, M.Sc., P,Ag,

• Executed various soil sampling field assessments for clients constructing Private Sewage Biophysical Treatment Systems around the Edmonton area (2019) Assessments • Conducted the initial sampling for a soil quality monitoring program for a client constructing a housing and golf course development (2018) • Conducts and manages the completion of rare plant surveys and reports. (2008-2019) • Prepares and assists with management and completion of biophysical reports, including the compilation of associated data. (2015-2019) • Conducted, managed, and trained staff in Pre-Disturbance Assessments including soil and ecosite classification and mapping, noxious and prohibited noxious weed surveying, rare plant surveying, and completing landscape inventories and timber assessments. (2008-2019) • Experience using quadrat sampling of plants to measure abundance, community composition, habitat affinity, and biodiversity. (2007-2019) • Performed vegetation identification, vegetation sampling, moss sampling, soil measurements, tree core extraction, tree height measurements, vegetation cover assessments, tree mensuration, and ecosite classification with the University of Alberta in conjunction with the Alberta Biodiversity Monitoring Institute (ABMI) (2007) • Prepares and assists with management and completion of Pre-Disturbance Assessment and Conservation and Reclamation/Construction reports including the compilation of associated data (2008-2019)

• Manages the execution and development of an image recognition machine learning project Academic, through a Canadian University (2019) Safety, and • Conducted the sampling and non-vascular identification for a peatland reclamation research Other project investigating various peatland reclamation methods in the Central Mixedwood region of Alberta (2017) • Extensive technical review as a soil science technical expert for a legal case to estimate the volume of oil well effluent released from a pipeline break (2016-2018). • Manages and trains staff in Safety Leadership Performance Indicators when acting under the role of a Team Lead to enhance Solstice’s behavioral based safety system (2010-2019) • Acted as a Teacher’s Assistant at the University of Alberta’s Renewable Resources 299: Environmental Conservation Sciences and Forestry Field School (2015-2017) • Volunteered to teach an introductory lesson on soil classification for students at the new Augustana Miquelon Lake Research station for a field ecology course (2016)

ACADEMIC BACKGROUND B.Sc. in Environmental and Conservation Sciences (Land Reclamation) 2007 University of Alberta, Edmonton, AB. Technical Master’s in Forestry M.F. (Course-Based) 2018 University of Alberta, Edmonton, AB.

PROFESSIONAL AFFILIATIONS AND CERTIFICATIONS • Alberta Institute of Agrologists • Interim Wetland Science Practitioner

TRAINING Current Safety • Accident Causation Theory • Respirator Fit Testing • Advanced Driver Training • Safety Leadership (Apache) Training • Argo Maintenance Training • Safety Leadership I (IOR) • Argo Safe Operation Training • Safety Leadership II: Frontline Supervisors • ATV Safety Training Development Program (IOR) • Bear Awareness and Avoidance • Safety Management Leadership Training • Construction Safety Training System (CSTS) (IOR) • Excavation and Trenching Safety • Safety Management Training (IOR)

| 2 Johnathan Potter, M.Sc., P,Ag,

• Fire Extinguisher Training • Safe Performance Trailering • Fundamentals of Safety for Workers (IOR) • Standard First Aid with Class C CPR & AED • Fundamentals of Safety for Leaders Training (ExxonMobil) • Transportation of Dangerous Goods (TDG) • H2S Alive • UTV Safety Training • Green Defensive Driving • Wildlife Awareness (Enform) • Ground Disturbance Level II Accident • Work Management Permit Holder Training Causation Theory (IOR) • Ground Disturbance Training (IOR) • Workplace Hazardous Material Information • Leadership for Safety Excellence (ACSA) System (WHMIS)

• Aquality Wetlands: From Classification to Policy 2019 Professional • Indigenous Consultation and Forestry: Finding common ground and learning from 2019 Development Indigenous knowledge • Visualizing Data with R 2018 • Electrofishing (Crew Leader II) Certificate 2015 • Project Management Fundamentals 2013 • Project Management Communications 2013 • Soil Competency Training Survey 2011-2013 • Central Alberta Plant Study Group Sessions 2012 • Calliou Group Aboriginal Awareness Training April 2011 • Ecosite Classification & Forested Reclamation Criteria and Record of Observations March 2010 Tool Course (Woodland Operations Learning Foundation) • GIS Level I • AIA Course 104 - Professional Ethics • ASPB Non-vascular ID course • ASPB Advanced Vascular ID course • Alberta Native Plant Council member/volunteer

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Lands & Consultation

Melanie Daniels B.Sc.

Melanie Daniels is the Lands & Consultation Coordinator for the Louis Bull Tribe and has more than 20 years of experience working with First Nations and Métis in an environmental or consultation related capacity. She gained her experience through working with both the Federal and Provincial Governments, First Nations and Métis, as well as industry. This experience has provided Melanie with a comprehensive understanding of all perspectives relating to environmental protection, land management and resource development. Through her years of service in various capacities she has built relationships based on mutual respect and trust with most of Alberta First Nations, the Métis Nation of Alberta (MNA) and the Métis Settlements. Melanie has led policy development relating to on Reserve environmental protection, served as a regulator and government advisor, developed consultation procedures for the MNA, and has led consultation for numerous resource developments on behalf of industry. During her employment with TransCanada, Melanie gained a thorough understanding of the NEB filing manual, specifically Chapter 3.4 as it relates to Aboriginal Consultation. Melanie’s primary work related to leading consultation with First Nations and Métis for several NGTL projects and two major oil projects (Northern Courier and Grand Rapids), Melanie also led consultation on KXL.

Career Present Louis Bull Tribe Lands & Consultation Coordinator

• Lead consultation on behalf of Louis Bull Tribe. • Conduct traditional land use studies. • Conduct monitoring and follow up of consultation commitments • Manage on and off Reserve oil and gas activities. • Liaise with industry partners in identifying economic opportunities.

September 2017 – April 2018 Government of Alberta, IR Engagement and Relationships Advisor • Supported Government of Alberta in Crown Led engagement with First Nations and Metis Communities. • Provided support to the Minister’s office for the First Nation’s Consultation Policy renewal. April 2015 – August 2017 Kisik Environmental Services Senior Advisor, Traditional Land Use and Consultation • Provided engagement support to First Nation and Métis communities for engaging with industry on proposed resource development. • Led Traditional Land Use studies with Aboriginal communities; plans study, gathers and records TLU information and drafts reports. • Review of environmental impact assessments on behalf of Aboriginal communities. • Business development.

June ’12 to April ‘15 TransCanada PipeLines Limited. Aboriginal Relations Engagement Lead

• Led Aboriginal engagement process for proposed gas and oil pipeline projects within Alberta. • Worked with Aboriginal communities in identification of potential impacts to traditional land uses and developed mutually agreed upon appropriate mitigations measures. • Hosted community open houses, Elder’s meetings, map review sessions, coordinated traditional land use and traditional ecological knowledge studies. • Reviewed traditional land use studies and appropriate mitigation with Aboriginal communities and third-party consultants. • Prepared regulatory filings for applications to the National Energy Board, the Alberta Energy Regulator and to the Aboriginal Consultation Office.

August ‘10 to June ‘12 ChickaDee Aboriginal Relations Services Ltd. President

• Lead Aboriginal relations advisor for Vantage Pipelines, a 700 km pipeline development in southern Saskatchewan. Involved in the Identification of communities, drafting of consultation plans, liaising with Government agencies regarding the duty to consult. Carried out consultation activities and negotiation of consultation agreements. • Liaison, advisor and ATK coordinator for the Métis Nation of Alberta, Region III in consultation with Alberta Transportation regarding the Little Bow Reservoir. • Lead advisor for Traditional land use study for a proposed copper and nickel mining developing in Northern Ontario.

July ‘09 – August ‘10 Métis Nation of Alberta Manager/ Industry Consultation and Regulatory Process

• Assisted the MNA in developing consultation processes in compliance with the MNA consultation policy. • Assisted MNA regions in pursuing consultation relating to land use and natural resource activity within each region. • Participated in Aboriginal traditional knowledge studies pertaining to Caribou in accordance with the Species at Risk Act, in cooperation with the Canadian Wildlife Service. • Pursued consultation opportunities with industry and government in the assertion of Métis rights.

Oct ’08 – July ‘09 Sole proprietor – self employed Wynterose Consulting Group/Enbridge Pipelines Aboriginal Relations Advisor • Provided advice and assistance to Enbridge Aboriginal Relations staff. relating to Aboriginal consultation, the duty to consult and Aboriginal issues. • Acted as liaison between First Nation and Enbridge pipeline. • Reviewed and made recommendations pertaining to Aboriginal matters within regulatory filings. • Provided Aboriginal awareness/sensitivity training to Enbridge staff and contractors.

Oct ’07 – Oct ’08 Government of Alberta – Alberta Environment Aboriginal Relations Senior Advisor

• Provided advice and assistance to Alberta Environment approvals staff in fulfilling the legal duty to consult. • Carried out activities in relation to the Government of Alberta’s First Nation Consultation Guidelines. • Reviewed consultation matrices, studies and other related submissions for adequacy and completeness. • Made recommendation to the Regional Director regarding completeness and adequacy of Aboriginal consultation efforts undertaken pertaining to Alberta Environment approvals.

April ’07 – Oct ‘07 Government of Alberta – Alberta Environment Reclamation Approvals Coordinator

• Reviewed and registered sand and gravel operations in accordance with Code of Practice for Pits. • Conducted site visits to ground truth information provided in registration applications as needed. • Liaised with other government departments to ensure all requirements are met. • Reviewed and approved the construction design of end pit lakes in accordance with Water Act. • Advised operators and environmental consultants on best management practices and regulatory requirements regarding sand and gravel operations.

2002 - 2005 Government of Canada - Indian Oil and Gas Canada Environment and Surface Analyst • Reviewed and interpreted environmental assessments for decision making regarding oil and gas activities on First Nation Lands. • Applied the Canadian Environmental Assessment Act, Indian Oil and Gas Act, the Indian Act and The Fisheries Act. • Conducted site inspections to determine compliance with regulatory and/or contractual terms. • Liaised with the Energy and Utilities Board to ensure environmental compliance.

1997 – 2002 Government of Canada – Indian and Northern Affairs Environment Officer • Acted for one year as Environment Policy Officer, Claims and Indian Government, managed regional environment budget, initiated change in the EIA process, and assisted other INAC directorates in meeting their environmental requirements. • Promoted environmental compliance on Indian Reserves in Alberta through project managing the development of awareness videos and environmental courses and workshops. • Developed terms of reference and project managed the remediation of various contaminated sites on Reserve. • Conducted site assessments to monitor First Nation activities for compliance to the Indian Act, Canadian Environmental Protection Act, Fisheries Act and Canadian Environmental Assessment Act. • Assisted First Nations in the completion of site selection and site assessments for new projects on Reserve. • Assessed and determined mitigation and monitoring of environmental impacts for a variety of on Reserve activities and recommending projects for approval. • Reviewed environmental screenings for quality control and assurance. • Represented the Department as well as First Nations when trans- boundary or traditional land use off Reserve issues occurred.

Education 1998 University of Alberta Bachelor of Science, Biology.

Certificates and Training • Land Management I & II, Indian and Northern Affairs Canada • Traditional Ecological Knowledge, Banff Centre for Management

• Pipeline Environmental Inspector, PITS Calgary • Valid driver’s license

Awards Deputy Minister’s Award for the development of above and below ground fuel storage tank registration procedures in accordance with Sec. 54(1) of CEPA.

JASON MACHNEY, P.BIOL. Pisces Environmental Consulting Services Ltd. (2006 to date) Senior Fisheries Biologist

Jason Machney, B.Sc., P. Biol., Fisheries Biologist with Pisces Environmental Consulting Services Ltd. has over 13 years of experience in fisheries assessment and management. As a Qualified Aquatic Environment Specialist, Mr. Machney has proposed budgets to ascertain work, conducted assessments and mitigation planning of over 275 watercourse crossings and several outfall structures throughout Alberta. In addition, Mr. Machney has conducted fisheries assessments and mitigation planning for open coal mines, municipal drainage projects, pipeline developments, and a railway construction project. Previous work experience before working with Pisces includes entomological field and lab experience with Alberta Agriculture (2002- 2005) and Natural Resources Canada (1998- 2001).

EDUCATION University of Alberta B.Sc. (2001) in Environmental Conservation Sciences majoring in Wildlife and Rangeland Resources Management PROFESSIONAL MEMBERSHIP Member in good standing with the Alberta Society of Professional Biologists since 2011 PROFESSIONAL EXPERIENCE TRAINING AND CERTIFICATION • ATV Training Course • Pleasure Craft Operator • Backpack Electrofishing Certified Crew Supervisor • Construction Safety Training System Certification • Bear Awareness Training • Ice Safety and Rescue Awareness • WHMIS • Fall Arrest Awareness • Standard First Aid AED/CPR FISHERIES RESOURCE ASSESSMENTS (QAES) • Conducted spawning surveys, tissue sampling for selenium analysis, fish surveys, fish population estimates, and water quality testing throughout several major drainage basins including the McLeod River, the Mackenzie River, the Gregg River, the Smoky River, the Pembina River, and the Embarras River as part of baseline conditions assessments or as part of established environmental monitoring programs (2006-2019). • Assessed fish populations and habitat for over 275 proposed watercourse crossings/outfalls in Alberta for transportation infrastructure, municipal drainage or pipeline construction projects (2006-2019). • Project management and report writing of fish resources and habitat assessments including large scale projects such as pipeline developments, large bridge crossings and mine environmental monitoring programs (2011-2019). • QAES support for temporary bridge crossings on the Panther River as part of the BTFR Program and on the Little Bow River for the purpose of accessing power lines. Tasks included conducting a site assessment, summarizing the fish and fish habitat potential, identifying potential impacts, and providing QAES specifications and recommendations (2015-2017).

CV for J. Machney

• Conducted annual monitoring program of fish populations in the Little Bow River between Travers Reservoir and Twin Valley Reservoir (2006, 2009, 2014) and within Willow Creek (2008) and Mosquito Creek (2009, 2014). LOWER TROPHIC AQUATIC COMMUNITIES AND HABITAT ASSESSMENTS • Baseline and periodic monitoring assessments of lotic benthic invertebrate communities and epilithic algae for the purpose of monitoring effluents and potential sediment from mining activity for three separate coal mines (2007-2019). • Project management, study design, statistical analysis and report writing for lower trophic monitoring programs. • Family level taxonomy of aquatic benthic invertebrates CONSTRUCTION MONITORING • Conducted fish capture and release operations at over 60 construction sites in Alberta (2006-2019). • Monitored Turbidity/TSS during instream construction at over 40 construction sites in Alberta (2007-2019) including QA monitoring on several major bridge projects over the North Saskatchewan River. • Developed Environmental Construction Operations (ECO) Plans for construction projects (2014- 2019). • Assessed post-incident water quality after the occurrence of a hydraulic fluid leak on a bridge demolition project on the North Saskatchewan River as a part of quality assurance construction monitoring for Alberta Transportation (2016). • Assessed post-incident stream conditions and provided remedial action recommendations for the Obed Mountain Mine initial response and Solids Recovery Project (2013-2015). • Conducted Post-Construction Environmental Assessments of watercourse crossing and bank stabilization projects throughout the Alberta Transportation North-Central Region for Alberta Transportation (2011-2013). • Environmental monitoring for early phase construction of an oil sands open pit mine (2012). FISH POPULATION MONITORING • Implanting pit tags in Rainbow Trout and Bull Trout to study population size, annual growth and migrations around end-pit lakes (2006-2019) • Installation/monitoring of fish traps for monitoring fish populations and spawning migrations on Sphinx Creek, the Gregg River and the Erith River (2007-2019) • Surveying compensation areas to determine fish utilization of constructed habitat (2007-2019) • Surgically implanting radio transmitters in Mountain Whitefish for monitoring fish passage through a constricted portion of the Athabasca River during bridge construction (2009) ENVIRONMENTAL PERMITTING –REGULATORY AGENCIES • Submittal of notifications and applications for approval under the Water Act • Submittal of request for review and applications for authorization under the Federal Fisheries Act • Discussion with regulating agencies regarding project timelines, preliminary design and habitat compensation/offsetting plans WATER QUALITY • Field preparation of background TSS water samples for TSS monitoring on instream construction projects following Alberta Transportation special provision procedures • Infield water quality testing for pH, conductivity, turbidity, temperature and dissolved oxygen • Comprehensive water quality sampling for lake studies, spill monitoring, and as part of regulatory requirements of specific projects

CV for J. Machney