Encana Shallow Gas Infill Development in the CFB Suffield National Wildlife Area IR Due Date: CEAA File #05-07-15620 August 2

EnCana Shallow Gas Infill Development in IR Due Date: the CFB Suffield National Wildlife Area CEAA File #05-07-15620 August 2nd, 2007 IR Requested By: IR No. Page Federal Government CEAA-EIS-001 1 #Terr - 1-B

Reference: Volume 1, Executive Summary, Page iii

Preamble: The proponent makes reference to baseline information used to define baseline environmental conditions. These data came from EnCana’s long term operations in the area.

Request: GOC recommends that EnCana provide a description of this baseline information including a copy of the data.

Response: EnCana has provided detailed reports from the field studies in 2006 which informed the determination of baseline conditions. See appendices 3C and D from Volume 3 for vegetation data. See appendices 5C-E, 5J-P for wildlife data.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 2

Requesting Party: Federal Government

EnCana undertakes to provide a response to the above referenced Information Request as soon as practicable. EnCana Shallow Gas Infill Development in IR Due Date: the CFB Suffield National Wildlife Area CEAA File #05-07-15620 August 2nd, 2007 IR Requested By: IR No. Page Federal Government CEAA-EIS-001 1 #Terr – 3 –B

Reference: Volume 1, Section I.5.9, Page I-26, Point Number 157

Preamble: EnCana states, “Undesirable vegetation may include restricted, noxious weeds, and may include specific nuisance weeds and species that are not native and compatible with the objectives of reclamation and the NWA”.

Request: GOC recommends that EnCana provide a list of species which will be identified as undesirable vegetation. GOC recommends that EnCana detail the mitigating activities in place to prevent Crested wheatgrass (Agropyron cristatum) and/or other undesirable agronomic species found on existing pipelines from spreading to new proposed pipelines, access trails, and wellsites.

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

EnCana defines undesirable plant species as those that negatively impact the functionality of the rangeland landscape (see definition, Volume 1, Appendix H, Section H.1). EnCana regards any species that impedes the establishment of desired plant species on disturbances created by The Project as undesirable and a trigger for taking control measures.

Measures to control the spread of undesirable vegetation during construction are described in the Draft Environmental Protection Plan (Volume 1, Appendix I, Section 1.5.9, pages 1-26). Pre-development Assessments (PDAs), timing of construction activities, clean equipment, and weed-free materials are recommended methods for preventing the spread of undesirable species (Sinton 2001). EnCana proposes to construct during the dormant season which reduces the spread of seeds of undesirable species because seeds are not being actively dispersed, frozen ground, and absence of mud that can harbor seed.

EnCana considers crested wheatgrass, yellow sweet clover, and smooth brome as undesirable in the NWA where they do not presently occur. However, Adams recorded 129 ha of disturbed prairie that had been seeded to crested wheatgrass and other exotic species in the NWA (Adams 1997). Successful control of invasive plants on rangeland requires a well-executed integrated weed management plan (Masters and Sheley 2004) and this necessitates the participation of all land users in the Suffield Military Block. EnCana Shallow Gas Infill Development in IR Due Date: the CFB Suffield National Wildlife Area CEAA File #05-07-15620 August 2nd, 2007 IR Requested By: IR No. Page Federal Government CEAA-EIS-001 2 #Terr – 3 –B

EnCana will seed desirable species (e.g. aggressive, native wheatgrass species) in an attempt to out compete and replace existing undesirable species but not remove the plants that successfully re-establishment from seeds in the topsoil seedbank or disperse from off-site. Crested wheatgrass seed bank elimination may be possible with several years of grazing, mowing, burning, or herbicide application (Romo and others 1994, Henderson and Naeth 2005).

Success is expected to be variable and will depend on pre-existing site conditions. A low level of stand replacement is expected on sites in large, well-established seeded fields of crested wheatgrass because the seed bank will contain predominantly undesirable species.

References Cited

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

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

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

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

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

Romo, J.T., Grilz, P.L., and Delanoy L. 1994. Selective control of crested wheatgrass (Agropyron cristatum L. Gaertn. and A. desertorum Fisch.) in the northern Great Plains. Natural Areas Journal 14:308-309.

Sinton, H.M. 2001. Prairie Oil and Gas: A Lighter Footprint. Alberta Environment 67 p.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 4

Requesting Party: Federal Government

EnCana undertakes to provide a response to the above referenced Information Request as soon as practicable. EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 5

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 6

Requesting Party: Federal Government

Reference: Volume 1, Section 2.2.3.3, Page 2-21

Preamble: EnCana states, “The following table is a summary of the locations used for storage of products used in the biocide and inhibitor program:”.

Request: GOC recommends that EnCana provide the table of locations used for storage.

Response: Although the table is missing from the EIS, bulk storage of corrosion inhibitor, biocide and diesel is located in storage facilities at the existing compressor stations.

Reference: Volume 1, Section 2.2.5, Page 2-23

Preamble: EnCana states that “in 30 years of operation in the NWA, there has never been significant damage to a pipeline or wellhead as a result of human error, military activities or extreme weather”.

Request: GOC recommends that EnCana clarify the threshold level at which “significant damage” occurs. Further, GOC recommends that EnCana discuss all previous pipeline failures and well site malfunctions, their resulting impact on the environment, the mitigation and management measures imposed, and measures of the success of mitigation within the NWA.

Response: EnCana’s EH&S Risk Matrix found within EnCana’s ERP has defined the criteria to be used when evaluating the impact and probability of a situation or incident. Once impact and probability have been evaluated, the level of risk can be determined. From the EH&S Risk Matrix “significant damage” (impact) can be defined as a damage which causes the level of risk to be medium or higher.

Pipeline release history in the NWA has been reported in Volume 1, Section 2.2.5.2, Table 2-4, page 2-24. All releases have had localized environmental impact which have been addressed through remediation. EnCana plans to continue with its pipeline corrosion inhibition program and to build upon the success of this program.

Well site malfunctions have been limited to one casing failure and a number of cases where wildlife/cattle have rubbed a valve open. Natural gas venting to atmosphere has been the resultant environmental impact of these incidents. Mitigation measures employed to reduce these occurrences include the removal of valve handles, the use of plugs on vent/gauge valves and the use of well head fences in areas where wildlife/cattle tend to gather.

Reference: Volume 1, Section 2.2.2.4, Page 2-19

Preamble: EnCana states that “in the unlikely event additional fill or soil is required for reclamation of lease areas, ROWs, or access routes, such material will be sourced from an existing borrow pit or stockpile outside the NWA”.

Request: GOC recommends that EnCana clarify “lease area” by providing standard dimensions for its leases and provide a list of locations (i.e. LSD or UTM) which may be used as existing borrow pits or stockpiles. GOC recommends that EnCana provide a list of mitigating measures to prevent undesirable species in existing borrow pits/stockpiles from being introduced to leases and pipeline ROWs. GOC recommends that EnCana detail previous reclamation efforts on lease areas, ROWs and access routes, the mitigation and management measures imposed, and measures of the success of mitigation within the NWA.

Response: As per the Suffield Surface Access Agreements, the deemed well lease is 100m by 100m. The actual disturbance footprint of well locations is 30 m2.

It is not possible to provide locations of borrow pits and stockpiles at this point as these locations are used and closed on a regular basis. EnCana can not anticipate what sources will be available at the time of need for fill, only that existing sources available at that time will be used. Undesirable species will be managed according to Volume 1, Section 1.5.9 of the Environmental Protection Plan (Undesirable Vegetation Control During Construction) and subject to the Environmental Effects Monitoring Program identified by points 284 and 288-291 in the Environmental Protection Plan.

Previous reclamation efforts (in addition to natural recovery) within the NWA generally consisted of seeding disturbed areas of wells and pipelines to the specified mixes for the time of development developed by SEAC, DND, and/or EnCana. Success of recent reclamation efforts was documented in the AXYS Environmental Consulting Ltd. Post Construction Vegetation Assessment of EnCana’s 16 Well per Section Pilot Project and the Suffield 2001 Shallow Gas Infill Drilling Program within the Riverbank and Middle Sandhill Zones of the National Wildlife Area. Success is also evident by reviewing the findings of this EIS in the Vegetation and Biodiversity sections (Volume 3, Sections 3 and 6) of the Terrestrial Biophysical Inventory where existing 16 well per section developments were compared to 8 well per section developments as well as off-site controls.

Reference: Volume 1, Section 2.8.1, Page 2-27

Preamble: EnCana states that “wildfires could result from military activities, lightning, oil and gas operations, vehicles, and accidents….environmental damage would likely result in the form of ignition and burning of vegetation….wildlife may be affect during the breeding and nesting season….Wildfires are rare in the NWA and emergency response in the NWA has been prioritized to limit damage in the NWA from fires arising in the Military Training Area (MTA).”

Request: GOC recommends that EnCana: 1. Provide information on previous fires in the NWA resulting from oil and gas operations, including the probable cause(s), the extent of fires, how the fires were controlled, resulting vegetation and wildlife impacts observed, mitigation, and follow-up monitoring conducted after; provide its Emergency Response Plan and its details as they apply to the prevention and control of wildfires in the NWA; and 2. Describe how fire management and prescribed fire are used as tools for habitat management in the NWA.

Response: 1. EnCana has had one fire which required assistance from external resources. The fire was a result of post construction seeding activities and covered an area of approximately 1.6 km2. EnCana’s Emergency Response Plan and details on prevention and control can be viewed within the response to IR Health-9-A.

2. Fire prevention and control measures employed to minimize the negative impact of fires are contained in the EEP in Volume 1, Appendix I of the EIS. A non- exhaustive list of examples include: vehicles will not be parked in high vegetation to avoid potential for wildfires; a water truck will be made available in areas where vegetation is dry; fire breaks will be put in place; smoking will only be allowed in vehicles and designated areas; and vehicle and equipment idling will be restricted to necessary activities and equipment. EnCana has not evaluated prescribed burns and other techniques for habitat management.

Reference: Volume 1, Section 2.8.1, Page 2-43

Preamble: EnCana states, “after evaluating the directional drilling technique, it was determined it was neither technically nor economically feasible; therefore, vertical drilling is the only technical and commercial option”.

Request: GOC recommends that EnCana compare and contrast the characteristics of directional drilling, slant drilling and vertical drilling and provide clarification as to the technical unfeasibility of directional drilling, and the costs versus benefits of directional drilling and slant drilling in terms of environmental impact as compared to vertical drilling. GOC recommends EnCana explain the feasibility of low impact directional drilling as an option as opposed to the construction of top soil stripped leases as indicated 2.8.1.

Response: A comparison of directional, slant and horizontal drilling is shown in the illustration and descriptions below:

Directionally Vertically Slant Drilled Horizontally Drilled Well Drilled Well Well Drilled Well

Horizontal: Wells are drilled vertically and then build angle to 90 ° and move horizontally way from the well head. Lateral distances range from 400+m to ~ 2000 m away. Slant: Wells are drilled at ~45 o angle from the surface and maintain that angle to get maximum reach. Directional: Wells are drilled vertically to a depth of ~ 60-100 m and then build angle (usually 55-70o)to reach the subsurface targets.

Encana has considered horizontal, slant, and directional drilling and found that they are not suitable alternatives to vertical drilling into the Milk River formation. While directional drilling is an available technology to the industry it is neither a technically feasible nor an EnCana Shallow Gas Infill Development in IR Due Date: the CFB Suffield National Wildlife Area CEAA File #05-07-15620 August 2nd, 2007 IR Requested By: IR No. Page Federal Government CEAA-EIS-001 1 #Terr – 11 –A

economic means of extracting this resource from the targeted shallow depths.

Slant drilling would allow us to hit only a small portion of the target formations and not at optimal spacing, resulting in an expected 20-30% reduction in the reserves per well. As show in the picture below, the drainage area of each wellbore is smaller and overlaps with other wellbores.

Directional drilling cannot hit the target zone due to the shallow depth (approximately 200- 250m) of our zone of interest. The large drilling angles that would be required significantly increase drilling time and costs; additionally, there is a higher risk of getting stuck in the hole.

The well bore configurations resulting from both slant and directional drilling are more difficult to operate, especially when unloading liquids, and could result in more problems in the event the well requires servicing. Deviated wellbores create more frictional losses resulting in higher pressure drops, more liquid loading and higher overall abandonment pressures, resulting in lower gas recovery

Horizontal drilling is too expensive to be commercial with the incremental reserves volumes expected for shallow gas infill drilling. Also, the nature off this reservoir - large stacked packages of unconsolidated, tight, discontinuous sands - makes it impossible to effectively drain the reservoir with a horizontal wellbore.

When the resource cannot be extracted economically by a certain technique or technology, this is not considered to be a viable alternative. EnCana believes that vertical drilling is the only way to best recover this resource and maintain a minimal environmental footprint while respecting regulatory well spacing requirements. EnCana Shallow Gas Infill Development in IR Due Date: the CFB Suffield National Wildlife Area CEAA File #05-07-15620 August 2nd, 2007 IR Requested By: IR No. Page Federal Government CEAA-EIS-001 1 #Terr – 11 –A

Reference: Volume 1, Section 2.8.7.2, Page 2-52

Preamble: EnCana states that “the nonfrac sand solids will be transported to a provincially approved waste disposal site”.

Request: GOC recommends that EnCana define a “provincially approved waste disposal site” and provide a list of locations (i.e. LSD or UTM) of the provincially approved sites that will be used.

Response: A “provincially approved waste disposal site” refers to third party waste disposal sites that are approved by the province of Alberta.

EnCana primarily uses Newalta in Brooks, AB. Newalta also has a facility in Hays, AB. EnCana may also use CCS in Brooks, AB or their Dunmore, AB location.

Reference: Volume 1, Section 2.4.2, Table 2-7, Page 2-37

Preamble: EnCana states that “the potential environmental effects of noise emissions from the Project are assessed in Table 2-7” and provides a table featuring noise source and predicted decibel level based on proximity to equipment operation.

Request: GOC recommends that EnCana explain the impacts of predicted noise levels on the valued ecosystem components in Volume 3.

Response: Any potential effects of noise on VECs in Volume 3 would be limited to wildlife. The greatest effects of noise on wildlife are associated with the inability to hear conspecifics (i.e. breeding songbirds) or predators, and habitat avoidance. Noise and related sensory disturbance effects are greatest during the breeding and fledging season (Bromley 1985). Highest levels of noise during shallow gas development in the NWA would occur during the construction phase (Volume 1 – Section .4.2). Construction is planned to occur only during fall and winter when breeding/fledging does not take place. Noise related and other sensory disturbance to wildlife is important (from a conservation perspective) only if the result is a population decline (Gill et al. 2001). Breeding songbird studies conducted during 2006 in quarter sections that had experienced past in-fill drilling did not show decreases in bird populations. Noise effects from construction and operations on the most sensitive group of wildlife (songbirds) are short-term (construction) and of negligible magnitude (operations) and will not result in long-term population decline.

Bromley, M. 1985. Wildlife management implications of petroleum exploration and development in wildland environments. USDA For. Serv. Gen. Tech. Rep. INT-191. Intermountain Research Station, Ogden, Utah. 42 pp.

Gill, J.A., K. Norris, and W.J. Sutherland. 2001. Why behavioral responses may not reflect the population consequences of human disturbance. Biological Conservation 97: 265-268.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 14

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 15

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 16

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 17

Requesting Party: Federal Government

Reference: Volume 1, Section H-6, Page H-35

Preamble: EnCana states “the following sources of organic matter are acceptable: [1] grass straw harvested within Suffield National Wildlife Area, [2] well composted municipal sewage sludge that has been certified weed free, [3] commercial grade peat moss”.

Request: GOC recommends EnCana clarifies which source of organic matter it proposes to use in the context of acceptable use within a protected area and the regulatory body which certifies its use in the NWA. GOC recommends that EnCana explain the methodology used to harvest grass straw from within the NWA and the impact upon the donor site.

Response: EnCana has described three alternative sources of organic matter to amend eroding sites in order to improve soil quality sufficiently to support a level of plant growth capable of providing ecosystem functionality. These are native grass straw harvested from within the SNWA, well-composted municipal sewage sludge, and commercial grade peat moss.

EnCana will follow strict CCME guidelines for compost quality if municipal sewage sludge is selected.

The decision to use locally harvested native grass straw will be made in consideration of any possible negative environmental impacts and in consultation with other users of the NWA.

CCME 2000. Support Document for Compost Quality Criteria - National Standard of Canada (CAN/BNQ 0413-200). Canadian Council of Ministers of the Environment (CCME) 43 p. http://www.ccme.ca/assets/pdf/pmozone_standard_e.pdf

Reference: Volume 1, Section 2.2.1, Page 2-16

Preamble: EnCana states that “in selecting site and route locations, the following criteria will be considered:… sensitive wildlife species… [and] rare plants and plant communities”.

Request: GOC recommends that EnCana clarify the above statement by providing a list of “sensitive wildlife species [and ]rare plants”.

Response: Sensitive wildlife species include the VECs listed in Volume 3, Table 5-1, pages 5-6 to 5-8. Rare plants are those listed in Volume 3, Appendix 3J, Table 3J-1, page 3J-5. Rare plant communities are those listed in Volume 3, Table 3J-2, page 3J-11.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 20

Requesting Party: Federal Government

Reference: Volume 1, Section I.5.1, Page I-18, Point 108

Preamble: EnCana states that “on native prairie where the topsoil has first priority, it will be protected from damages and effects associated with admixing and structural loss. The consideration for shutdown or work modification will begin when: top soil being rutted to within 5 cm of the bottom of the topsoil depth”.

Request: GOC recommends that EnCana provide a trail management plan for transport over existing trails, where topsoil has priority, that are rutted to within 5cm of the bottom of the topsoil depth, as well as a procedure to re-evaluate soil in a timely fashion and update this plan.

Response: An Access Management Plan for the Project will be developed once the locations are finalized and the distribution and volumes of traffic are further understood. Appropriate protection measures and any additional reclamation activities that may be required on existing trails will be assessed. General environmental protection measures for trails are outlined in Volume 1, Appendix I, Section I.5.2 – Traffic Control.

Reference: Volume 1, Section I.5.3, Page I-20, Point 117

Preamble: EnCana states that “the project will consider: application of water or tackifers to the RoW and soil stockpiles to inhibit dust and wind erosion”.

Request: GOC recommends that EnCana clarify if the water used to inhibit dust and wind erosion is included within the calculated volume of water required for the proposed project and what volume of water is allocated for this purpose. If the water used to inhibit dust and wind erosion is not included within the calculated volume of water required for the proposed project, GOC recommends that EnCana provide the locations of water sources for this usage. GOC recommends that EnCana detail the chemical composition of the proposed “tackifers” and the potential impact the tackifers would have on wildlife, vegetation and ground water.

Response: Reference should read: Volume 1, Appendix I Draft Environmental Protection Plan, Section I.5.3, Page I-20, Point 117

Annual consumption is based on estimates of historical consumption and would include those volumes used for dust and erosion control. As a result, the estimates stated in m3/well would include those volumes used for dust and erosion control.

For information regarding potential tackifiers see response to IR GEN 77-A. EnCana will consult with the appropriate regulators before the use of any tackifiers in the NEWA.

Reference: Volume 1, Section I.5.3, Page I-20, Point 117

Preamble: EnCana states that “the project will consider: sowing of cover crops to inhibit longer term wind erosion”.

Request: GOC recommends that EnCana provide a list of cover crops it intends to use for this purpose.

Response: Non-native annuals are generally used as cover crops to provide interim erosion control on erodible slopes while slower-growing native perennials are becoming established. Annuals should not be used where they compete with native plants for moisture or nutrients. Seeding of annuals is also not recommended for early spring grazed pastures in southern Alberta (Native Plant Working Group 2001).

The cover crops chosen for this purpose must meet the following criteria: • not too aggressive or competitive, • not persistent (2-3 years maximum), • safe for grazing but not too palatable, • tolerant of grazing, especially in the establishment year.

Cover crops that are suitable for the NWA (that meet the above criteria) include: • Fall rye • Triticale or winter wheat • Regreen (a cross between wheat and western wheatgrass) • Flax

References Cited:

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

Reference: Volume 1, Section I.5.3, Page I-21, Point 117

Preamble: EnCana states that “the project will consider: installation of two track gravel access”.

Request: GOC recommends that EnCana detail the impacts of two truck gravel access on modifying plant communities and habitat fragmentation impacts on wildlife.

Response: Two-track gravel may be established only where necessary to prevent erosion. Through careful routing and timing activities during dry or frozen periods, EnCana expects the need for two-track gravelling to be minimal.

All trails will fall under EnCana’s post construction monitoring plan to ensure timely management of any inadvertent introduction of undesirable vegetation. As the gravel would be applied to areas that either are or would be reduced to bare soil, the impact to plant communities would be no greater than a two-track trail without gravel. In cases where old trails have already braided, returning the access corridor to a single reinforced track will have a lesser impact on plant communities than the existing trail. As documented in the Terrestrial Biophysical Assessment (Vol. 3, pg. 5-3), disturbance widths of less than 4 meters are insufficient to cause a fragmentation effect. The combined width of the two gravel tracks will rarely exceed 2 meters.

Two-track gravelling has been used extensively outside CFB Suffield on both private and public native prairie lands.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 25

Requesting Party: Federal Government

Reference: Volume 1, Section I.5.6, Page I-24, Point 138

Preamble: EnCana states that “workers will be trained on methods to minimize the potential effect of the Project on wildlife”.

Request: GOC recommends that EnCana provide the training information used to train workers on minimizing wildlife impact.

Response: EnCana is still developing its training program. Once the training program is developed, its contents will be made available. The training will include wildlife identification, ways to minimize interactions with wildlife, and safe handling of encounters with snakes.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 27

Requesting Party: Federal Government

Reference: Volume 1, Section I.6.1, Page I-28, Point 169

Preamble: EnCana states that “wet areas and areas of poor drainage will be avoided when accessing and working. If this cannot be avoided, special equipment or topsoil stripping and grading measures will be considered. Alternatively, work may be scheduled during periods when soil is completely frozen”.

Request: GOC recommends that EnCana detail the procedure for topsoil stripping and grading measures it will use in wet areas and areas of poor drainage.

GOC recommends that EnCana explain the resulting impacts of vehicle to ground heat transfer of parked vehicles causing soil thawing and explain the mitigating steps of this situation and the reclamation practices to recover any impact. Response: Topsoil stripping and grading measures in wet areas and areas of poor drainage would be a very infrequent occurrence because these regions are generally avoided by the Project. It is therefore unlikely that EnCana would construct /operate under these conditions. For wet and/or poorly drained conditions, EnCana has developed mitigation measures as noted in the reference above. EnCana will adaptively manage this plan to ensure that operational procedures and special measures are considered to protect native prairie in these conditions.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 29

Requesting Party: Federal Government

This would be only Reference: Volume 1, Section I.6.1, Page I-29, Points 177 and 180, and Volume 1, Section I.6.4, Page I-32, Point 208

Preamble: EnCana states that “Access trails will not be bladed or graded unless the surface creates a barrier or safety hazard to travel.... Where localizing grading is required to facilitate access, the topsoil will be stripped and stockpiled to prevent loss and mixing due to the grade operation”. EnCana also states that “topsoil will be stripped from site specific well site areas that require grading and protection from excavation and abnormal surface disturbance. The excavation area is normally confined to an area 5 x 6 metres for a footprint of 30 square metres to facilitate the tie-in of the gathering system pipeline”.

Request: GOC recommends that EnCana explain the use of blading, grading or stripping of topsoil in the NWA as a viable option, in respect of habitat fragmentation, and impacts to soil, vegetation, and animal VECs. GOC recommends that EnCana clarify the definition of “abnormal surface disturbances” by providing and explaining a list of activities constituting abnormal surface disturbances.

Response: Stripping may occur for well head tie ins, road crossings, line crossings, and tie in points. The stripping of topsoil is restricted to chain ditching. Given the size of the stripped areas, fragmentation is not an issue. The effects of pipelining are assessed as part of the construction phase for each VEC.

Blading or grading would only occur on very rough terrain for rig access. This could be considered an abnormal surface disturbance.

Reference: Volume 1, Section I.6.1, Page I-29, Point 182, and Volume 1, Section I.5.9, Page I- 26, Point 162

Preamble: EnCana states that “only one access trail will be created to each development unless a decision is made to braid the trail to protect the vegetation” and “access will avoid known and discovered weed infestations by using alternate pathways on and off the right-of-way”.

Request: GOC recommends that EnCana explain the term “braid” in terms of trail creation and explain the resulting impact on habitat fragmentation, modifying plant communities, and impacts to wildlife habitat, as well as the aforementioned impacts from using alternate pathways off the right-of-ways. Further, GOC recommends that EnCana explain if use of alternative pathway will mean that more than one access route will be used and/or created.

Response: The term braiding refers to vehicular traffic that deviates from a single trail access route.

If it was determined through routing of the locations prior to construction or during ongoing monitoring that changing the use of an existing trail may reduce environmental effects, EnCana may consider alternative access routing.

The intent is to reduce overall disturbance, while protecting vegetation, wildlife habitat and soils.

Additional access routes may be created through braiding. Each access route for the Project will be assessed on a site specific basis. Designated access routes will be identified in the Access Management Plan for the Project.

Reference: Volume 1, Section I.6.3, Page I-31, Point 200

Preamble: EnCana states that “where brush removal cannot be avoided, brush mowers, or hand-clearing methods will be used to remove brush and keep roots intact to maximize the restoration potential”.

Request: GOC recommends that EnCana explain the viability of brush removal in terms on its impacts on increased soil erosion and the steps to control soil erosion because of brush removal.

Response: It is anticipated that there will be no erosion impact to soil because brush will be removed by flush cutting. Brush is cut at ground surface, and roots will remain intact. In addition, the ground surface and sod layer will not be disturbed using this method.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 33

Requesting Party: Federal Government

Reference: Volume 1, Section 2.2.5.2, Page 2-24

Preamble: EnCana states that “the gas gathering system will comprise primarily HDPE pipe and a corrosion inhibition program is and will be implemented, it is anticipated releases will not exceed one or two per year (due to internal corrosion)”.

Request: GOC recommends that EnCana detail the estimated volume per pipeline release, and the estimated number of releases and volume of each release not due to internal corrosion over the lifetime of the pipeline.

Response: Volumes released due to a pipeline release in the NWA are so small that they cannot be detected using conventional gas measurement equipment. For this reason EnCana believes a reasonable release rate/pipeline event would be equivalent to a non-serious surface casing vent flow. Once a year more sensitive equipment is used to detect pipeline leaks. Using these conditions a pipeline release could range from 10.6 to 3887.2 mcf. In Volume 1, Section 2.2.5.2, Table 2-4, Page 2-24, the pipeline leak frequency in the NWA has continuously improved to 0.5 leaks/year. Given this statistic the annual release rate due to pipeline leaks in the NWA is 5.3 to 1943.6 mcf.

Reference: Volume 1. Page 2-26.

Preamble: EnCana states “In the event of drought conditions, EnCana will develop contingency plans to obtain the required water from alternative sources. In extreme drought conditions, it may be necessary to stop/avoid certain activities that require water”.

Request: GOC recommends that EnCana detail the estimated volume GOC requests that EnCana provide the contingency plans, to allow an understanding of the potential impacts on the ecosystem and VECs of CFB Suffield.

Response: EnCana will develop contingency plans in the event of an extreme drought, at this time EnCana has provided its plans for water sourcing in Section 2.8.4 (water supply) of Volume 1. The majority of the water use for the Project will be during the construction phase and it is not predicted that there will be an extreme drought situation in the next couple of years which would result in the need for the development of a contingency plan.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 36

Requesting Party: Federal Government

Reference: Volume 1, Section 2.2.5.5, Page 2-26

Preamble: EnCana states that the estimated volume of water required for construction is “approximately 3 181,687 m which will be spread out over three construction years” and that this water will be , sourced from the South Saskatchewan River and “from existing water wells and spring-fed 3 dugouts within CFB Suffield, at 12-6-17-5 W4 (20,000 m /yr licensed), 4-4-16-6 W4 (73,000 3 m /yr licensed), 5-2-20-7 W4 (well and dugout), 10-16-20-7 W4 (well and dugout), and 10-16- 20-8 W4 (well and dugout)”.

Request: GOC recommends that EnCana provide detailed information on each aquifer in terms of actual aquifer size, water amount within aquifer and percent of water removed each year from each aquifer, and cumulative impact to the aquifer.

Response: Please see section 2.7.9 (Groundwater Use) in Volume 4 for a description of the regional and local aquifers for the Project. Detailed information on aquifers at CFB Suffield is also provided in well logs in Appendix 2E in Volume 4. This information is considered sufficient for quantifying Project effects on groundwater aquifers.

The project effects on groundwater were rated as negligible as described in Section 2.8 of Volume 4, therefore cumulative impact assessment on groundwater was not conducted.

Reference: Volume 1, Section 2.2.5.2, Page 2-26

Preamble: EnCana states that “it has been proposed by the Alberta Government that conflicts between water users will be resolved by allocating water based on a “first-in, first out” principle. Therefore, users who have been allocated water for a longer time period will be allocated water preferentially over new water users”.

Request: GOC recommends EnCana provide a list of water users and their respective priority for water allocation at CFB Suffield, and how Project-related impacts will affect other water users at CFB Suffield.

Response: EnCana does not have a list of water users or their respective priority as determined by Alberta Environment. As the project effects on surface water are predicted to be negligible, EnCana’s effects on the quality or quantity of water will have no measurable effect to other water users as mentioned in Volume 1, Section 2.2.5.5.

Reference: Volume 1, Section 2.2.5.6, Page 2-27 and Volume 1, Section 4.6.2, Page 4-6

Preamble: EnCana states that their “ERP includes a plan for responding to wildfires”.

Request: GOC recommends that EnCana provide a detailed ERP for fires in the NWA, including the parties responsible for extinguishing the fire as well as the personnel and financial resources that EnCana will provide for firefighting within the NWA.

Response: EnCana’s ERP can be viewed within the response for IR Health-9-A. If the fire is a result of EnCana’s activities, EnCana will be fully responsible for managing and acquiring the resources needed to extinguish the fire.

As always, if the fire is a result of lightning or activity unrelated to EnCana’s activities, EnCana will assist with the response in any way possible.

Reference: Volume 1, Section 2.5, Pages 2-39 and 2-40

Preamble: EnCana states that “the Project is planned to be implemented across three winter drilling seasons, which will span four calendar years, 2008 to 2012” and that “construction activity will typically occur between October and April”.

Request: GOC recommends that EnCana clarify the project schedule and explain the inclusion of 2012 when considering the proposed drilling seasons are October to April of 2008/2009, 2009/2010 and 2010/2011, where 2008, 2009, 2010 and 2011 comprise four years not including 2012. GOC recommends EnCana define “typically” and provide a more detailed schedule on acceptable/unacceptable beginning/end dates for impact and cumulative impact assessment.

Response: The Project can be implemented in the three drilling seasons, 2008/2009, 2009/2010 and 2010/2011. However, given the likelihood of project delays due to weather and access (military training schedules) it is reasonable to expect the Project will require one more season during which we can drill, complete or tie-in stranded locations and carry out any remedial work.

“Typically” as used in the context of scheduling means the expectation of carrying through with all project components within the October-April timeline.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 41

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 42

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 43

Requesting Party: Federal Government

Reference: Volume 1, Section 2.8.6.1, Page 2-49

Preamble: EnCana states “four potential alternatives for the use of vehicles for access: [1] the use of trucks; [2] the use of trucks that are only used at CFB Suffield; [3] the use of four-by-four trucks with balloon tires that are used only at CFB Suffield; [4] when conditions are dry or frozen, the use of 4x4 trucks, and, where possible, in wet conditions, the use of smaller vehicles”.

Request: GOC recommends that EnCana clarify the term “trucks” and provide a list of vehicles and their specifications as they apply to all vehicular equipment used in the construction and maintenance phases, and provide a list of vehicles which fall under each alternative access option.

Response: Reference above is related to operations and maintenance vehicles. Details of construction vehicles/equipment can be found in Volume 1, Appendix I Draft Environmental Protection Plan.

EnCana’s truck standard for operations and maintenance allows for the use of 4x2 (2 wheel drive) and 4x4 (4 wheel drive). These trucks have a gross vehicle weight rating (GVWR) of less than 4600 kg. This is the standard EnCana refers to in option #1. For use in the NWA, EnCana prefers the standard described in option #4. This option proposes the use of 4x4 (4 wheel drive) trucks only during dry or frozen conditions and the use of ATVs if access is required during wet conditions.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 45

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 46

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 47

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 48

Requesting Party: Federal Government

Reference: Volume 1, Section H.3.1.1, Table H-1, Page H-5

Preamble: EnCana provides a table of Typical Density Values for water, topsoil (Alberta-wide average, sandy loam, growth limiting and sewage sludge amendment), loam and clay loam, subsoil (Alberta-wide average, ripped, ripped plus amended with manure, ripped plus amended with peat moss) and peat.

Request: GOC recommends that EnCana provide the source of the density values and an estimation of how closely these values represent the soils found in the NWA.

Response: See responses to IR GEN-101-A and IR TERR-123-B.

Reference: Volume 1, Section H.3.1.1, Page H-5

Preamble: EnCana states “soil compaction can be determined by comparing the bulk density of sites with the same soil type… [and that] the cone penetrometer measures resistance to penetration into the soil”.

Request: GOC recommends that EnCana provide documentation on the suitability of using the cone penetrometer in sandy soils.

Response: EnCana notes that sandy soils, especially when dry or frozen, are unlikely to require decompaction and therefore a cone penetrometer would not only be ineffective but also unnecessary.

Thacker and others (1994) conducted a survey of soil compaction on oil and gas leases in East- Central Alberta to compare methods for evaluating soil compaction and to evaluate the extent of soil compaction on wellsites with different soil types. They concluded that measuring mechanical impedance with a cone penetrometer was the least expensive of six methods and also gave the best indication of variability on the wellsite because many measurements could be collected quickly and rapidly.

Thacker, D., Finlayson, N.M. and Johnson, R.L. 1994. Survey of Soil Compaction on Oil and Gas Leases in East-Central Alberta. Alberta Conservation and Reclamation Management Group Report RRTAC OF-8 38 p.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 51

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 52

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 53

Requesting Party: Federal Government

Reference: Volume 1, Section I.2, Page I-4

Preamble: EnCana states “the EPP applies to all Project areas including… shoo-flies

Request: GOC recommends that EnCana define and explain the term “shoo-flies”.

Response: Shoo flies are used to route traffic along the trail in circumstances where there is an open cut or excavation. It is a temporary causeway that allows the access route to continue to be used on those occasions where a pipeline or open cut has otherwise created a diversion on the route. Its objective is to negate impact.

Reference: Volume 1, Section I.3.1, Page I-6

Preamble: EnCana states that “copies of all relevant laws, codes, guidelines and policies will be collected to understand and enforce legal obligations and will be available upon request”.

Request: GOC recommends that EnCana provide a list all relevant laws, codes, guidelines and policies, and highlight the applicable sections that EnCana believes apply to this project. Response: Please see Volume 1, s. 1.3.2.1 of the EIS for a discussion of the primary legislative approvals and associated regulators. A more expansive list of legislation and guideline documents is provided below, which EnCana trusts the Panel will find of assistance. EnCana does not intend this list to, irrespective of circumstances, purport to limit any general legal obligations or specific statutory duties it might have. Similarly, EnCana does not wish to limit these or other provisions by highlighting its expectation of the applicable sections. EnCana also notes that the project will be executed pursuant to its contractual obligations under the Gas Agreement between the Government of Canada and the Province of Alberta, as discussed in s. 1.1.1 of the EIS and EnCana’s response to Information Request CEAA-EIS-001 GEN11-A. Pertinent federal legislation may include, but is not necessarily restricted to: • Canada Seeds Act, R.S.C. 1985, c. S-8, and regulations; • Canada Water Act, R.S.C., 1985, c. C-11; • Canada Wildlife Act, R.S.C., 1985, c. W-9; • Canadian Environmental Protection Act, 1999, R.S.C. 1999, c. 33, and regulations; • Fisheries Act, R.S.C., 1985, c. F-14; • Migratory Birds Convention Act, R.S.C., 1994, c. 22; • National Energy Board Act, R.S.C., 1985, c. N-7; • Navigable Waters Protection Act, R.S.C., 1985, c. N-22 ; • Species at Risk Act, R.S.C., 2002, c. 29; and • Wildlife Area Regulations, C.R.C., c. 1609.

Pertinent provincial legislation may include, but is not necessarily restricted to: • Alberta Energy and Utilities Board Act, R.S.A. 2000, c. A-17; • Alberta Weed Control Act, R.SA. 2000, c. W-5; • Energy Resources Conservation Act, R.S.A. 2000, c. E-10; EnCana Shallow Gas Infill Development in IR Due Date: the CFB Suffield National Wildlife Area CEAA File #05-07-15620 August 2nd, 2007 IR Requested By: IR No. Page Federal Government CEAA-EIS-012 1 #Terr – 55 – C

• Environmental Protection and Enhancement Act, R.S.A. 2000, c. E-12, and regulations; • Historical Resources Act, R.S.A. 2000, c. H-9, and regulations. • Oil and Gas Conservation Act, R.S.A. 2000, c. O-6, and regulations; • Pipeline Act, R.S.A. 2000, c. P-15; • Water Act, R.S.A. 2000, c. W-3; and Pertinent guidelines and standards may include, but are not necessarily restricted to: • AEUB. 1982. Preservation of Archaeological, Paleontological and Historical Resources. IL 82 – 11. • AEUB. 1996. Drilling Waste Management. Directive 050. • AEUB. 1998. Suspension, Abandonment, Decontamination, and Surface Land Reclamation of Upstream Oil and Gas Facilities. IL 98 – 02. • AEUB. 2001. Storage requirements for the Upstream Petroleum Industry. Directive 055. • AEUB. 2002. Principles for Minimizing Surface Disturbance in Native Prairie and Parkland Areas. IL 2002 – 01. • AEUB, Native Prairie Working Group. 2002. Guidelines for Minimizing Surface Disturbance, Petroleum Industry Activity in Native Prairie and Parkland Areas. • AEUB. 2004. Well Abandonment Guide. Directive 020. • AEUB. 2005. Energy Development Applications. Directive 056. • AEUB. 2006. Oilfield Waste Management Requirements for the Upstream Petroleum Industry. Directive 058. • AEUB. 2007. Noise Control. Directive 038. • Alberta Agriculture, Food and Rural Development. 2001. Native Plant Revegetation Guidelines for Alberta. Edmonton. • Alberta Environment. 1997. Conservation and Reclamation Guidelines. C&R/IL/97-1. • Alberta Environment. 1997. Burial of Material On-lease. C&R/IL/97-5. • Alberta Environment. 1998. Voluntary Shut Down Criteria for Construction Activity Operations. C&R/IL/98-4. • Alberta Environment. 1999. Surface water quality guidelines for use in Alberta. Science and Standards Branch, Alberta Environment, Edmonton, Alberta • Alberta Environment. 2000. Alberta Ambient Air Quality Objectives. Edmonton. • Alberta Environment. 2001. C&R/IL/01-04 Ploughed-In Pipelines. • Alberta Environment. 2003. Code of Practice for Pipelines and Telecommunication Lines Crossing A Water Body. Edmonton. • Alberta Environment. 2003. Code of Practice for Watercourse Crossings. Edmonton. • Alberta Environment. 2003. Focus On Wetlands. Edmonton. • Alberta Environment. 2003. Water For Life: Alberta's Strategy for Sustainability. Edmonton. EnCana Shallow Gas Infill Development in IR Due Date: the CFB Suffield National Wildlife Area CEAA File #05-07-15620 August 2nd, 2007 IR Requested By: IR No. Page Federal Government CEAA-EIS-012 1 #Terr – 55 – C

• Alberta Environment. 2003. Revegetation Using Native Plant Materials: Guidelines for Industrial Development Sites. R&R/03-03. • Alberta Environment. 2003. Weeds on Industrial Development Sites: Regulations and Guidelines. R&R/03-04. • Alberta Environment. 2003. Problem Introduced Forages on Prairie and Parkland Reclamation Sites: Guidance for Non-Cultivated Land. (Edmonton, Alberta,). R&R/03- 05. • Alberta Environment. 2003. Wellsite Construction: Guidelines for No-Strip and Reduced Disturbance. R&R/03-07. • Alberta Environment. 2004. Reclamation Criteria for Wellsites and Associated Facilities; • Alberta Environment. 2005. Assessing Drilling Waste Disposal Areas: Compliance Options for Reclamation Certification. R&R/04-1. • Archaeological Survey of Alberta. 1989. Guidelines for Archaeological Permit Holders in Alberta. Edmonton. • Canadian Wildlife Service. 1991. The Federal Policy on Wetland Conservation. Canadian Wildlife Service, Environment Canada, Ottawa. • Canadian Council for Ministers of the Environment. 2000. Canada-wide Standard for Particulate Matter and Ozone. Quebec.

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

Preamble: EnCana states that “in order to ensure that all personnel including contractors and subcontractors working during the construction phase of the Project are informed of the environmental requirements and sensitivities, a project specific environmental orientation program will be developed and implemented”.

Request: GOC recommends that EnCana provide the project specific environmental orientation program for review. Response: The environmental orientation program is currently under development. GOC will receive a copy upon completion.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 57

Requesting Party: Federal Government

Reference: Volume 1, Section I.4, Page I-16, Point 80

Preamble: EnCana states that “washing, fuelling and vehicle and equipment maintenance such as greasing, oil changes, etc. will take place at approved locations and will not be undertaken within 100m of the high water mark of any watercourse or standing waterbody”.

Request: GOC recommends EnCana clarify “approved locations” by defining where in terms of the NWA, the remainder of CFB Suffield, and outside CFB Suffield these locations are found. If within the NWA or the remainder of CFB Suffield, provide a list of approved locations. Response: All maintenance for vehicles will be completed off CFB Suffield. The only equipment with on site maintenance is the drilling rig. This is completed on location and there are storage facilities to handle all the waste on site. All waste is transferred to a licensed waste handling facility.

Reference: Volume 1, Section I.4, Page I-17, Point 97

Preamble: EnCana states that “site-specific erosion of sediment control measures will be used when ground disturbance occurs on steep slopes”.

Request: GOC recommends that EnCana define “steep slopes” by providing a classification scheme which denotes the slope gradients that apply to adjectives describing slope incline. Response: EnCana takes the position that soil loss is combination of factors that not only include slope gradient but also slope length, soil texture, and management factors such as vegetation cover and surface modification such as waterbars (Volume 1, Appendix H, Attachment H4 and H5) and rolling dips in access trails (Volume 1, Appendix I, Section I.6.1, Page I-28, Point 172).

EnCana agrees that Point 97 is worded in a manner that could cause confusion and would be more accurate if revised to state:

"site-specific erosion control measures will be used when ground disturbance could result in a potential soil loss rate after construction that exceeds the soil loss standard".

The soil loss standard is 4 tonnes per hectare per year (t/ha/yr, Volume 1, Appendix H, Section H.2.2, page H-4).

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 60

Requesting Party: Federal Government

Reference: Volume 1, Section I.5.1, Page I-18, Point 108

Preamble: EnCana states that “on native prairie the actions that may be taken to protect vegetation and/or topsoil include: removal of the thawed and wet portion of the topsoil under winter conditions”.

Request: GOC recommends that EnCana explain the feasibility and environmental impacts of “removal of the thawed and wet portion of the topsoil” when EnCana has stated that “the general directive will be to construct when soils and ground conditions are dry or frozen” (Volume 1, Section I.4, Page I-15, Point 73) and that it will “suspend construction activity when site and weather conditions are such that soil resource may be adversely affected (e.g. by compaction, rutting, remoulding, mixing, or erosion)” (Volume 1, Section 2.2.2, Page 2-17) and any modification of wet/thawed soil could cause compaction, rutting, remoulding, mixing, or erosion.

Response: Removal of the thawed and wet portion of the topsoil under winter conditions would be done under exceptional circumstances where shutdown or other acceptable work modifications are not a viable option. Otherwise the wet weather protocols detailed in Volume 1, Appendix I-5.1 of the EPP would take precedence.

Reference: Volume 1, Section I.5.5, Page I-22, Point 123

Preamble: EnCana states it “will in most cases avoid rare plants and avoid where possible rare plant communities”.

Request: GOC recommends that EnCana explain “how avoiding rare plant where possible” will help to meet the spirit of the Federal Species at Risk Act as well as the Canadian Biodiversity Strategy. Response: The spirit of the Species at Risk Act (SARA), Migratory Birds Convention Act (MBCA) and the Canadian Biodiversity Strategy (Collectively, the "Legislation") is the preservation of wildlife and biodiversity in Canada.

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

Reference: Volume 1, Section I.5.5, Page I-22, Point 128 and Volume 1, Section I.5.6, Page I- 24, Point 135 Preamble: EnCana states that “new locations for rare plant will be provided to appropriate federal and/or provincial authorities” and “all sightings of listed species will be reported to the environmental inspector(s) who will advise EnCana, who will advise SIRC, and appropriate regulatory representatives”.

Request: GOC recommends that EnCana clarify authorities and representatives by providing a list of persons/groups who will be contacted. Response: EnCana utilizes several reporting processes at CFB Suffield and in the NWA for reporting rare plant sightings and other listed species. Each reporting process is dependant upon the species in question and the activity being conducted.

Given the scope of this project, there is a potential for encountering many listed species while conducting field work (i.e., field truthing of each of the locations). Field crews could encounter listed species while doing field truthing or during travel to and from these locations (i.e., incidental sightings).

From an "immediate" notification and reporting perspective, this means the field personnel would need to call in to Range Control to report each listed species sighting. To make things more practical, currently in the NWA, DND has identified key listed species (i.e., burrowing owls and their nests, kangaroo rat burrows, tiny cryptanthe and sand verbena) that require immediate field notification by EnCana to Range Control and the DND (National Wildlife Area Coordinator). The DND NWA Coordinator will then notify EC, when warranted.

After the immediate reporting between DND and EnCana, all rare plant locations (i.e., those species that are provincially and federally designated as listed species in the EIS) are submitted to the Alberta Natural Heritage Information Centre (ANHIC). Wildlife listed species (i.e., those species that are provincially and federally designated as listed in the EIS) will continue to be reported to SRD for input into their provincial databases (ANHIC and Fisheries and Wildlife Management Information System (FWMIS)). All listed species locations are currently submitted to the DND.

Reference: Volume 1, Section I.5.9, Page I-27, Point 159

Preamble: EnCana states that “weed control will be done… [and] may include… herbicide application”.

Request: GOC recommends that EnCana detail the proposed herbicides for use, their chemical composition and the methodology for application, as well as the approval process for use on DND lands.

Response: Reference should read: Appendix I Draft Environmental Protection Plan, Section I.5.9, Page I-27, Point 159

Herbicides are currently not used in the NWA. Should the Draft Environmental Protection Plan be revised to include the use of herbicides, all approval requirements will be met.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 65

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 66

Requesting Party: Federal Government

EnCana undertakes to provide a response to the above referenced Information Request as soon as practicable.

EnCana Shallow Gas lnfill Development in ITS Due Date: the CFB Suffield National Wildlife Area CEAA File #05-07-15620 August 2"d, 2007 IR. Requested By: IR No. Page Federal Government CEAA-EIS-012 I #Terr — 67 — A

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

Preamble: EnCana states in EIS Volume 1, Section 2.1.1.3 Production, Page 2-8: "EnCana is currently developing the majority of its lands outside the NW 4 with infill drilling to 16 wps, in accordance with down spacing and co-mingling orders approved by the EUB. These orders acknowledge the need for increased well density and multi-zone co- minglingfor best recovery ofthe natural gas and conservation of the resource." Request: GOC recommends that EnCana clarify if the production from all three gas-charged units is co-mingled in the current wells and is to be co-mingled in the proposed wells, or is the current and proposed gas production from all three gas-charged units is produced and is to be produced separately. Response: The gas production from all three zones will be commingled in all the project wells. This is a consistent practice for other shallow gas areas that EnCana operates including the current wells at Suffield. EnCana Shallow Gas Infill Development in IR Due Date: the CFB Suffield National Wildlife Area CEAA File #05-07-15620 August 2nd, 2007 IR Requested By: IR No. Page Federal Government CEAA-EIS-012 1 #Terr – 68 – A

Reference: Volume 1, Section 2.2.2.3, Page 2-18

Preamble: EnCana states in EIS Volume 1, Section 2.2.2.3, Page 2-18 that: “wells will be tied into the existing or new gathering system using 50.8 mm (2 in.) I.D. HDPE pipe. The HDPE pipe is a continuous pipe that will be brought to location on a large roll.”

Request: GOC recommends that EnCana provide a map depicting existing HDPE pipeline and existing steel pipeline, along with a map of the proposed HDPE pipeline and proposed steel pipeline. Response: Attached are two maps showing existing and proposed plastic and steel pipelines. The pipelines are still only preliminary routings which will be verified in the field via PDA and in accordance with the EPP.

Reference: Volume 1, Section 2.2.2.3, Page 2-18

Preamble: EnCana states in EIS Volume 1, Section 2.2.2.3, Page 2-18, that: “In the NWA, it is anticipated that, based on operating experience, all HDPE pipelines can be buried (ditched) using low impact ploughing equipment (such as the spider plough).”

Request: Since most construction is proposed to occur during the winter, when the ground is frozen, and the use of the lower impact technique spider ploughing may be precluded by frozen soils and other soil conditions, the GOC recommends that EnCana provide details on what proportion of the pipelines is expected to be buried using spider ploughing versus chain ditcher technique.

Response: EnCana, weather and military templates aside, anticipates all the wells will have HDPE plowed in. The proposed construction season is from October 1 to April 15, and each year 400 wells are planned. The Spyder Plow can do 8-10 wells per day, so there are 50 working days required to complete the plowing of the pipe. EnCana expects there to be 50 non frozen days within the construction season.

The current anticipated ratio of Spyder plowing to chain ditching in NWA is 2.5:1.

Reference: Volume 1, Appendix I, Page I-39

Preamble: EnCana states in EIS Volume 1, Appendix I, Page I-39, 264. that “It is not anticipated that additional fill materials will be required, but in the unlikely event that such material is required, it will be sourced from an existing stockpile or pit outside the NWA.”

Request: GOC recommends that EnCana explain how the risk of weed introduction from fill materials will be minimized when sourcing from an existing stockpile or pit outside the NWA. Response: Fill material will be sourced from locations in close proximity to the development, limiting weed introduction to those species already present in the landscape. Undesirable species will be managed according to Volume 1, Section 1.5.9 of the Environmental Protection Plan (Undesirable Vegetation Control During Construction) and subject to the Environmental Effects Monitoring Program identified by points 284 and 288-291 in the Environmental Protection Plan.

Reference: Volume 1, Section 2.2.3.2, Page 2-20

Preamble: EnCana states in EIS Volume 1, Section 2.2.3.2, Page 2-20, that “Siphon strings for produced water removal may be considered for wells that have measurable water production and are in areas difficult to access.”

Request: GOC recommends that EnCana describe siphon strings in more detail. Response: Siphon string is a term used to describe tubing when it is run down the casing of a well and used to produce natural gas and water to the gathering system. Tubing diameter is a very important consideration when equipping a well with a siphon string as it is the velocity of natural gas traveling up the tubing that lifts the water to surface and into the gathering system.

Reference: Volume 1, Section 2.2.3.3, Page 2-20

Preamble: EnCana states in EIS Volume 1, Section 2.2.3.3, Page 2-20, that “…all wells equipped with a siphon string are placed on the biocide/inhibitor program.”

Request: GOC recommends that EnCana indicate what proportion and absolute number of existing wells are presently equipped with siphon strings and what proportion of new ones are expected to be equipped with siphon strings. Response: Eighty five (85) existing wells in the NWA or approximately 8% of the existing wells in the NWA are equipped with siphon strings. Based on these statistics it is estimated that 102 new wells will be equipped with siphon strings.

Reference: Volume 1, Section 2.2.3.2, Table 2-3, Page 2-21

Preamble: EnCana depicts in EIS Volume 1, Section 2.2.3.2, Table 2-3, Page 2-21, “Annual Volume Summary of the Products used in the Biocide and Inhibitor Program”

Request: Note that calculations indicate that 4450 wells are on the biocide program, but there are presently only 1145 shallow-gas wells in the NWA. GOC recommends that EnCana clarify if this volume summary is for all wells on the Suffield Military Base, or for wells in NWA. GOC recommends that EnCana provide also amounts just for NWA. If it does not apply just to the NWA, GOC requests details specifically for the NWA Response: Volumes stated in the reference above are related to the full program on the Suffield Military Base.

Table below is the annual volume summary for the NWA:

Product Volume Biocide (Nalco/Exxon EC6222A) 680 litres Corrosion Inhibitor (Brentagg T-8084) 340 litres Diesel Fuel 20 litres Water 1020 litres

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 74

Requesting Party: Federal Government

Reference: Volume 1, Section 2.2.5.5 Water Requirements, Figure 2-7

Preamble: EnCana states the location of existing water sources is shown on Figure 2-

Request: The figure is missing from Volume 1, AAFC wishes to see the figure.

Response: See response to IR #AQ-4-A.

Reference: Volume 1, Section 2.2.2.4 Post-construction and cleanup activities, Page 2-19

Preamble: EnCana discusses site cleanup and post-construction activities but does not comment on fences to be constructed for the purpose of restricting cattle access to the well heads after the wells have been completed and brought on line Request: AAFC-PFRA requests EnCana clarify the type of fence and gate that will remain around well heads after completion, and describe the average area that will be fenced off restricting cattle access. Response: EnCana plans to use a 15’ x 20’ Tex fence which is 300 ft².

Reference: Volume 1, Executive Summary, Page iii, Fourth paragraph under “environmental setting”.

Preamble: The text includes reference to two literature citations, which do not appear to be included in the “References” section in this volume (e.g., Poston et al. 1990).

Request: GOC recommends that EnCana provide full literature citations. Response: Alberta Fish and Wildlife. 1985. A policy for the management of threatened wildlife in Alberta. Alberta Fish and Wildlife, Edmonton, AB. 34 pp.

Poston, B., D. Ealey, P. Taylor and G. McKeating. 1990. Priority Migratory Bird Habitats of Canada’s Prairie Provinces. Canadian Wildlife Services, Edmonton, AB. 107 pp.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 78

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 79

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 80

Requesting Party: Federal Government

Reference: Volume 1, Section 1.4.1, Page 1-10 and 1-11

Preamble: EnCana states “the remaining gas cannot be recovered with the existing well distribution. Moreover, because of the shallow, stacked stratigraphy, directional or horizontal drilling from existing surface locations cannot effectively deplete all of the productive zones. EnCana is confident that only infill vertical drilling will enable the efficient production of the remaining natural gas resource”. Page 1-11 they state “The alternative of not proceeding with the Project was not considered viable…”

Request: GOC recommends that EnCana provide an estimate, of the percent of the gas that can be accessed by existing wells and by directional or horizontal drilling or by the combination of slant and horizontal drilling or stacked laterals from existing well areas. In addition, define “effectively” and “efficiently” and specify what forms of directional and horizontal drilling were explored.

Response: EnCana has presented a comparison of vertical, slant and horizontal wells in response to IR # Terr-11-A.

EnCana anticipates approximately 20-30% fewer reserves due to reduced contact of the reservoir and target zones. Deviated wellbores will also cause operational problems and increase abandonment pressures resulting in additional reserves being left behind.

In EnCana’s referenced statement the expression “cannot effectively deplete” means that optimal recovery of the resource cannot be achieved with directional or horizontal drilling; the expression “enable the efficient production” concerns itself with operational issues – water removal, wellbore re-entry, operating costs and the improved reserves recovery associated with higher friction losses in a deviated wellbore.

Reference: Volume 1, Section 1.4.2. Alternatives to the Project Page 1-11

Preamble: The proponent states “Delaying the project would not substantively change the environmental costs or benefits…”

Request: GOC recommends that EnCana provide information to substantiate this assertion

Response: See response to IR #Terr 41-B.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 83

Requesting Party: Federal Government

Reference: Volume 1, Section 2 Project Description, Page 2-1

Preamble: Volume 1 contains several references to the equipment used in installation, completion, and monitoring/maintenance of wells and pipelines.

Request: GOC recommends that EnCana provide a description of devices and equipment: pig launchers and receivers, meters, isolation valves, conductor rig, drilling rig, blowback tank, well logging truck, swabbing unit, and perforating unit. Clarify whether a separate cementing unit be used to cement the pipe in place.

Response: Pig Launchers and receivers are conduits for the cleaning and corrosion inhibition programs. A foam or hard rubber plug (pig) is installed in a pig launcher and gas produced from the wells causes the pig to travel along the pipeline to the receiver. Pigs are retrieved at the receivers and reused.

Meters are devices used to measure the product flowing down the pipeline.

Isolation valves are in the pipeline and are used to isolate segments of the pipeline.

A conductor rig is a small drill rig which drills the first 25-50m of the well and cements the conduit in place.

The drilling rig will be either a coiled tubing rig or a conventional single rig that drills the main hole to total depth and then runs production casing to bottom and cements in place. A separate cement bulker and pumper come out to location to cement the production casing in place.

Blowback tanks are used to recover completion fluid following hydraulic fracturing.

A well logging truck is used to run tools down the wellbore and back to surface. (These tools send reservoir information back to surface).

A swabbing unit is a 5 ton truck used to remove water from the wellbore.

Perforating units are used to deploy a perforating gun to establish a conduit from the reservoir through the well casing.

Reference: Volume 1, Section 2 Project Description, Page 2-1

Preamble: The proponent states that the drilling infill will displace other segments and overall activity levels in the area will not increase from existing activity levels.

Request: The GOC recommends that EnCana clarify whether this applies to the NWA and if so substantiate this conclusion. Response: The area referred to in this statement is CFB Suffield including the NWA. It is EnCana’s intent to keep activity levels at approximately the existing activity levels in Suffield – essentially some planned drilling activity in Suffield outside the NWA will be deferred in order to drill locations in the NWA and thereby keep annual drilling activity at the existing levels in the Suffield area.

Reference: Volume 1, Section 2.1.1.3, Page 2.7

Preamble: EnCana states “Production from the pilot project confirmed that recovery of natural gas volumes with the infill wells increasing well density to 16 wps is incremental recovery over well density of 8 wps. These conclusions are also supported by reservoir modeling and simulation, based on EnCana’s proprietary analysis methods.”

Request: In order to determine if the requirements of establishing the need for the project and examining the non-implementation option were fully explored, the GOC recommends that EnCana: 1.Explain “incremental”. 2. Discuss assumptions made in the reservoir models simulations and how were they justified. Response: 1) Incremental reserves are additional volumes of natural gas that will be recovered with increased well density (16 wps). These volumes cannot otherwise be recovered under the current depletion scheme (8 wps). Incremental reserves vary from 60-100 mmcf/well depending on the area. 2) A simulation model of the pilot area was constructed using EnCana’s best interpretation of the geology. Well log data was used to calculate to calculate gross and net pay, porosity and water saturation. Core data and pressure data were used to estimate permeabilities. The model was then calibrated against historical production history and pressures by adjusting permeability. The model showed a very good correlation against actual field production with a well density of 8 wps. Forecasts of well production in the future were then simulated with assumptions on well spacing and operating conditions. Simulated results demonstrated that increased well density at 16 wps provided incremental additional gas volumes that would not be recovered by the existing well density of 8 wps.

Reference: Volume 1, Section 2.1.1.3 Production, Page 2-7

Preamble: Total incremental volumes that will be recovered for the project over a period of 20 to 40 years is estimated at 125 bcf.

Request: The GOC recommends that EnCana clarify whether the project will shorten the lifespan of existing wells, and if so by how much. Provide substantiation. Response: Because the natural gas recovered from the Project is incremental to the volumes that will be produced from existing wells, it will not affect the performance of them.

The Project will not shorten the life of the existing wells.

Results from EnCana’s pilot areas which have been drilled to 16 wps suggest incremental reserves recovery is realized with increased well density. While, in general, the incremental gas reserves per well decrease with each successive phase of drilling, very little well interference is evident. An example of this is shown in the performance of the D6/D8 pilot below:

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 88

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 89

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 90

Requesting Party: Federal Government

Reference: Volume 1, Section 1.1.2 The Proposal, Page 1-2, Section 1.1.3, Page 1-3, Section 2, Page 2-1

Preamble: EnCana states “Existing access roads will be used; no new roads will be constructed.” (Page 1-2) but on page 1-3 states “To determine the least disruptive locations for access roads, well sites, pipelines, and associated infrastructure, EnCana uses baseline mapping …” and then (page 2-1) “no new roads (with built- up roadbeds) will be constructed”.

Request: GOC recommends that EnCana clarify whether any new roads will be built Response: No new roads with built-up roadbed will be constructed for this project. EnCana will require new access routes which will not require a built-up roadbed due to limited traffic & appropriate siting of the routes.

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

Preamble: The proponent states that backend loop lines may be required where there is insufficient capacity to transport the gas in existing laterals.

Request: GOC recommends that EnCana clarify whether this involves additional construction. If so, provide a detailed description and locations. What percentage (length replaced/ over total length) of lateral pipeline has it been necessary to replace or augment with backend loop lines in other 16 wps in the LSA and RSA. Response: The project has included a back end loop for every infill project so no additional construction will be required. The final location of the loops, where necessary will be evaluated upon final well locations. Regardless, PDA’s will be conducted for all construction activity as stated in the EIS. We have not had to replace any pipelines in other 16 wps; however, backend loops have been constructed for each battery (there are approximately 100 wells per battery).

Reference: Volume 1, Section 2.1.6 Access. Page 2-10

Preamble: The proponent states that existing access roads will be utilized whenever possible and where appropriate.

Request: GOC recommends that EnCana clarify whether access to each well site and infrastructure component (e.g. pigging stations) will be limited to one access road or trail and whether the same trail will be used for ingress and egress. At sites where there are multiple access points clarify whether these will be abandoned and reclaimed and how this will be implemented.

Response: Access will be determined in the PDA. The access route for construction and operations will be identified and placed on maps. There may be circumstances where the heavy equipment access via a different route than operations. If the access is different, the construction access will be abandoned and reclaimed when conditions are appropriate.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 94

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 95

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 96

Requesting Party: Federal Government

Reference: Volume 1, Section 2.2.2, Page 2-16

Preamble: The proponent states that if gravel is required to improve the existing road conditions and reduce rutting, clean gravel will be brought in.

Request: GOC recommends that EnCana describe under what conditions the use of gravel will be allowed. Identify under what environmental conditions that traffic will be suspended, and indicate how route selection criteria will minimize rutting and the need for gravel.

Response: On existing trails, the gravel is used to return the track to an equal grade with the surrounding area eliminating the bottoming out of service vehicles. Once the gravel has been set into the receiving soil by traffic, it acts as a soil stabilizer, reducing dust and rut development. It also gives operators an additional measure of protection from wet ground conditions when precipitation events are unpredicted. Another benefit is that it ensures a greater degree of compliance with service vehicles staying on right-of-ways.

Access route selection will seek to minimize the need for two-track gravelling by focusing on avoiding steep slopes, erosion prone soils and natural lows. In the event acceptable drilling locations can only be accessed by traversing steep slopes or erosion prone soils, two-track gravelling will be evaluated in order to minimize braiding potential associated with steep slopes and erosion prone soils. Similarly, in the event acceptable drilling locations can only be accessed by traversing natural lows, two track gravelling will be evaluated to minimize rutting potential. Accessing these areas in dry and frozen conditions will serve to minimize rut development, but over long periods of time, access taken on high use trails still can lead to the development of ruts. Through careful routing and timing activities during dry or frozen periods, EnCana expects the need for two-track gravelling to be minimal.

Gravel used will be from as local a source as possible to minimize potential undesirable vegetation introduction. All trails will fall under EnCana’s post construction monitoring plan to ensure timely management of any inadvertent introduction of undesirable vegetation.

As the gravel would be applied to areas that either are or would be reduced to bare soil, the impact to plant communities would be no greater than a two-track trail without gravel. In cases where old trails have already braided, returning the access corridor to a single reinforced track will have a lesser impact on plant communities than the existing trail. As documented in the Terrestrial Biophysical Assessment (Vol. 3, pg. 5-3), disturbance widths of less than 4 meters are insufficient to cause a fragmentation effect. The combined width of the two gravel tracks will rarely exceed 2 meters. Two-track gravelling has been used extensively outside CFB Suffield on both private and public native prairie lands.

Reference: Volume 1, Page 2-18

Preamble: A mitigation measure that is emphasized throughout the document is winter operations. However on page 2-18 of Volume 1 the proponent asserts that, “Factors which may preclude ploughing include: surface and subsurface stones, frozen soils, adverse topography, heavy clay soils and wet condition [emphasis added]”. The proponent further states that if plowing is not feasible they will utilize a chain ditcher, but further detail is not provided.

Request: In order to support EnCana’s project footprint estimate and mitigation assumptions the GOC recommends that EnCana describe pipeline length that will be constructed with a Chain ditcher (given construction is limited to winter and Spyder ploughing is precluded by frozen conditions). Discuss how this affects the footprint, mitigation assumptions regarding pipeline width and minimum soil disturbance.

Response: Evaluation of the infrastructure required for the infill program reveals that approximately 100 kms of chain ditching will be required. This data will be confirmed on completion of the PDAs prior to construction.

As measured in the 2006 fieldwork, actual physical disturbance related to trenching and plowing was found to be negligible for Spyder plowing and 2-m for chain ditchinig. Based on the 4.5 and 12-m widths, the incremental footprint of pipelines for the three-year drilling period would amount to 0.4% of the total land area of the NWA respectively.

Reference: Volume 1, Section 2,4.2, Noise Table 2-7, Page 2-36 and 2-37

Preamble: EnCana used receptors and distances appropriate for making human dwellings nearby habitable. EUB Directive 038 in several places (point of the receptor, Section 2.1.3.1 discussing special circumstances) allows for a lesser distance, than 1500m, to be used as the standard. This assumes only compressor stations are relevant.

Request: GOC recommends that EnCana describe the way that noise effects were assessed. Provide information on the sound frequency (Mhz) of the types of noise that will be produced by various activities to determine whether they overlap with song frequencies of birds.

Response: Volume 6, Section 3 describes the background, methodology and provides the conclusions for the environmental noise component for the project. The VEC identified for this section of the application was environmental noise, which is regulated under the Alberta Energy and Utilities Board, and outlined in Directive 38 – Noise Control. No other environmental noise regulations or ordinances were found to apply to this project.

Directive - 38 is receptor based and does not specify conditions regarding the industrial noise level overlap with the song frequencies of birds or other wildlife. Directive 38 states “Measuring noise levels at the dwelling allows a licensee to take maximum advantage of the normally substantial distance in rural areas between a facility and any dwellings. The only exception is for facilities in remote areas where a receptor is not present. In such cases a PSL of 40 decibels absolute energy level equivalent (dBA Leq) nighttime must be met at 1.5 kilometres (km).”

Directive 38 states “the EUB continues to examine peer-reviewed scientific literature and has concluded to date that typical industrial noise regulated under its jurisdiction does not significantly impact the physiology and habituation patterns of animals over the long term. The literature does suggest that animals might temporarily avoid an area until they become familiar with or acclimatized to industrial noise.”

Reference: Volume 1, Section 2.2.3.2. Swabbing and Well site visits. Page 2-19

Preamble: The proponent states that in the event water is produced, well site visits will average four visits per year.

Request: The GOC recommends that EnCana clarify what percentage of the existing wells on CFB Suffield require swabbing and their age, and what percent are estimated to require swabbing during their lifetime. Clarify what percentage of the new wells on the NWA are anticipated to require swabbing during their lifetime and describe how this would impact the traffic assessment.

Response: See response to IR #Terr-151-A.

Reference: Volume 1, Section 2.2.3.3. Pipeline Protection. Page 2-21

Preamble: To combat pipeline corrosion the proponent advocates the use of biocides in the wellbore and pipes. The proponent will use up to 36,400 l of biocide, 18,200 l of corrosion inhibitor, and 2,500 l of diesel fuel.

Request: GOC recommends that EnCana discuss the fate of these compounds after they are injected into pipelines and wells.

Response: Chemicals used to prevent pipeline corrosion are allowed to flow through the gathering system to the compression facilities. The chemicals are separated from the natural gas and disposed of using a licensed third party waste disposal facility or a disposal well.

Reference: Volume 1, Section 2.2.3.5, Refracturing. Page 2-21

Preamble: The proponent states that refracturing is not typically required, but may be necessary for some wells.

Request: GOC recommends that EnCana clarify what percentage of the proponent’s existing wells in CFB Suffield require refracturing and the age of the wells. Response: Approximately 50% of existing wells in the NWA are candidates for refracturing. All candidates were drilled before 1998.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 103

Requesting Party: Federal Government

Reference: Volume 1, Section 5 Concordance Table, 5-23 and 5-34

Preamble: Three items in the Terms of reference 6.2.2 (above) require consideration of grassland endemics or endemics.

Request: GOC recommends that EnCana: 1. Identify endemic species as such in each of the relevant accounts that provide habitat requirements by VEC and where their abundance and distribution are discussed or presented. 2. Address the topic of how losses or declines of endemic species could affect local and regional biodiversity. 3. Provide a description of methods for calculating biodiversity of endemics, including how species were identified as to endemic status.

Response: Endemism is based largely on context, which can vary widely depending on the observer. We are unaware of standard and/or accepted definitions of endemism in Alberta for plants or vertebrate wildlife.

1. Endemic plant and vertebrate wildlife species, because of their occurrence only in a specific region, are by definition also listed as species of concern or as listed species. All listed species (provincially and federally) were assessed as part of the EIS. 2. No losses or declines (beyond the natural range of variability) of endemic species or any listed species are anticipated as a result of this project. 3. Listed species biodiversity is rated for each mapped vegetation type in Appendix 6A of Volume 3, page 6A-5. Endemics are included in this list.

Reference: Volume 1, Section 5

Preamble: The Concordance table is vague as to where elements of the Terms of Reference are addressed. For example in Part II, Section 1.4 the Terms of Reference State “The proponent will demonstrate that its project will not interfere with the conservation of wildlife.” And the concordance table simply cites all relevant sections of Volumes of 3,4,5,6.

Request: For all elements of the concordance table which currently cite only volume numbers or “all relevant sections of”:, the GOC recommends that EnCana provide a more specific reference by listing sections and page #s Response: EnCana has provided sufficient reference information in order for the reader to confirm that the Terms of Reference have been complied with, within the EIS. Moreover, EnCana encourages and expects interested parties and all readers to become familiar with all aspects of the EIS in order to fairly and critically analyze same. EnCana's decision to refer to "all relevant sections" of the various volumes reflects this expectation. However, EnCana will undertake to circulate specific references regarding the Terms of Reference to all interested parties as soon as possible. The requested exercise will require several days. Given that EnCana has already provided the required references, and given that the Terms of Reference are presently embodied and addressed within the EIS, EnCana will provide same as soon as possible after conclusion of the IR response period.

Reference: Volume 1, Section 2.8.1 Drilling and Completion Techniques, Page 2-42.

Preamble: The proponent states that as EnCana does not construct leases (i.e. strip top soil) or lease roads, therefore the use of well pads would not result in reduced environmental footprint. The environmental footprint includes habitat fragmentation effects, but these are not discussed.

Request: GOC recommends that EnCana: 1. Clarify and justify how multiple downhole locations at one surface location would not reduce habitat fragmentation. Clarify whether these can be constructed using minimal disturbance techniques. 2. Describe how the number of flowlines and access routes would not be reduced by concentrating drill holes at one surface location.

Response: The three pre-dominant factors in the selection of wells spacing in the NWA are: a) Regulatory well spacing which governs inter-well spacing. b) Avoidance of environmentally sensitive areas. c) Operating conditions (wellhead pressures, water removal, re-completions) to achieve maximum recovery of the resource.

EnCana believes that vertical drilling will best meet each of the above criteria. While multiple well drilling can be carried out from a single pad using minimum disturbance techniques, there may be occasion where surface conditions (topography) require some construction. In addition, when drilling from a pad location, the equipment (drilling and completion) is resident on location for longer periods of time thereby increasing the risk of more disturbances to the site.

While pad drilling would decrease the length of flowlines and access routes to each location, it

is important to consider that the existing flowline diameters may be insufficient and affect the eligibility for Spyder plowing. Additionally, any assessment of total flowline length must also consider the length and placement of larger diameter loop lines. EnCana’s proposal for development is in an area where existing infrastructure will be used, resulting in a reduced requirement for loop lines.

Reference: Volume 1, Section 2.8.6.1, Page 2-49

Preamble: EnCana states in EIS Volume 1, Section 2.8.6.1, Page 2-49 that: “EnCana considered four potential alternatives for the use of vehicles for access: … Option 4 – when conditions are dry or frozen, the use of 4 x 4 trucks, and, where possible, in wet conditions, the use of smaller vehicles (i.e. quads or all terrain vehicles (ATVs)). EnCana’s preferred option is the Option 4”

Request: GOC recommends that EnCana Clarify the meaning of wet conditions, and explain why smaller vehicles are preferred in these conditions. Response: Wet conditions are conditions that occur after heavy precipitation where soil is more easily subject to compaction, remoulding, and puddling, creating a higher potential for water erosion.

Smaller vehicles have less of an access footprint, primarily through lesser weight that leads to less churning or turbation of the soils. Smaller vehicles like all terrain vehicles (ATV’s) are also less likely to lose traction in wet weather or disturbing the root mat, resulting in less soil movement and vegetation loss.

Reference: Volume 1, Section 2.8.6.1, Page 2-49

Preamble: EnCana states in EIS Volume 1, Section 2.8.6.1, Page 2-49 that: “EnCana considered four potential alternatives for the use of vehicles for access: … Option 3 – the use of four-by-four trucks with balloon tires that are used only at CFB Suffield; Option 4 – when conditions are dry or frozen, the use of 4 x 4 trucks, and, where possible, in wet conditions, the use of smaller vehicles (i.e. quads or all terrain vehicles (ATVs)). EnCana’s preferred option is the Option 4…”

Request: GOC recommends that EnCana provide the rationale why Option 3 – the use of 4 x 4 trucks that are used only at CFB Suffield is not a preferred option. Clarify enforcement of clean condition of vehicles and equipment, including an inspection plan for vehicles at point of entry, if 4 x 4 trucks and quads or all terrain vehicles are used, that are not used only at CFB Suffield.

Response: 1. The use of 4 x 4 trucks at CFB Suffield exclusively was not the preferred option because of increased cost and the absence of wash stations on the base. 2. Enforcement of clean vehicles and equipment will include. a. Washing of all equipment prior to arrival on the base b. Random inspections will be conducted by the environmental inspector(s) c. Disciplinary action for non-compliance

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 109

Requesting Party: Federal Government

Reference: Volume 1, Executive Summary, Page v, Volume 3, Section 4.9, page 4-18 Volume 3 Section 7.1 Cumulative Effects. Page 7-1

Preamble: EnCana states “The application of mitigation measures coupled with avoidance of sensitive environments, results in potential environmental effects being rated as negligible for the following disciplines: wetlands, biodiversity, groundwater, surface water, aquatic ecology, and palaeontology. For this reason, cumulative effects assessments were not undertaken.” Volume 3 Wildlife and Habitat, EnCana states “The residual environmental effects of construction, operations and decommissioning on wetlands are all assessed as negligible. Therefore, a cumulative effects assessment was not undertaken.”

Request: GOC recommends that EnCana undertake cumulative effects assessments for all disciplines.

Response: Please see section 2.4 of the EIS regarding the Project methodology for Cumulative Effects Assessments. Valued Ecological Components and Valued Socio-economic Components (“VECs” and “VSCs”) were assessed on an individual and not discipline-wide basis. The Canadian Environmental Assessment Act requires an Environmental Assessment to consider likely significant adverse effects. In accordance with good environmental assessment practice and the CEAA Practitioner’s Guide, Cumulative Effects Assessments were undertaken for potential Project effects which had the potential to interact with other past, present and future environmental effects in a significant way; i.e., those that were not “negligible.”

Negligible effects are those well within the normal range of ecological and socio-economic variability and therefore, being similar to natural conditions and thus will have no change to the existing environment. These effects therefore cannot be said to be “likely” to compound with other environmental effects in a significant way. Significance determination is discussed in section 2.3.5.3 of the EIS. Potential residual project effects were evaluated against the criteria of direction, geographic extent, duration, frequency, reversibility and recovery and magnitude to categorize the potential effect as significant, insignificant, or negligible.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 111

Requesting Party: Federal Government

Reference: Volume 3, Section 7 Cumulative Effects. Figure 7.2. Page 7-7.

Preamble: The map presented in figure 7-2 seems to contradict the preceding text in several significant ways: there appears to be a much larger disturbance footprint in Koomati than explained in the text. The disturbance footprint in the preceding text (Volume 3, Section 3) for the NWA is much lower than it appears to be on the map.

Request: GOC recommends that EnCana explain the apparent discrepancy between the map and the text. Response: Footprint measurements were conducted in an unbiased and systematic manner that was independent of the study area that was measured. Detailed methods used for the inventory of footprint are outlined in Volume 3, Appendix 3E.

Observed differences between Volume 3, Figure 7-2 and the preceding text and tables in Section 3.6.5.1 occur due to averaging. Table 3-1 displays the average disturbance over each study area. Figure 7-2 displays the relative disturbance at a hectare level. The purpose was to ensure that relative disturbance differences were visible between different study areas and even different regions within study areas. The procedure used to create these maps involved breaking the regional study area into a series of 1 hectare units. For each unit the disturbance was calculated using the digitized disturbance features. In Figure 7-2, a unit or series of units with a disturbance percent of 50%, for example, means 50% of those 1 hectare units were covered by disturbance features. It has no implications or relation to the average disturbance of a given study each except that it takes all the parts to make the whole.

Reference: Volume 3. Pg. 7.4. Section 7.3.2. Fig 7.1

Preamble: Provides past and forecasted distribution of raised gravel roads and major traits

Request: GOC recommends that EnCana provide similar information for all minor trails and RoW that exist in the same time period of NWA.

Response: This information is currently unavailable. The locations of minor trails will only be known after the PDAs are conducted, prior to construction. Disturbance Footprint from Past and Existing Cumulative Land Uses (Figure 7-2, on page 7-7 of Volume 3) captures similar information but it is not presented in specific time increments.

Reference: Volume 3. Pg. 7.4. Section 7.3.2.

Preamble: . “Total existing disturbance footprint is estimated to affect 1.3% to 2.3% of the Northern and Southern portions of NWA respectively”

Request: GOC recommends that EnCana discuss how the footprint from past shallow activities was separated from livestock grazing. Response: It was assumed that features classified as dugouts and single-track trails resulted from livestock activity. All dugouts were digitized and land areas in the NWA were calculated. For each visible single-track trail the path was digitized using orthophotos (see Volume 3, Appendix 3- E) and the trail width was stored as an attribute. The length of each path was factored with the stored width attribute to create an accurate area estimate for each trail. The areas of all single- track trails in the NWA were then summed resulting in the total land area of single track trails for the NWA. The dugout land area was added to the single track trail area and this value was divided by the total land area of the NWA giving a percentage disturbance value attributed to livestock grazing. On-screen digitizing and ground investigations found that the majority of single-track trails were observed in the vicinity of dugouts. A distinguishing factor of single- track trail was that they often originated or terminated at dugouts or visibly wet areas. A small percentage of single-track trails could also be attributed to ungulates but these were not readily distinguished from livestock trails.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 115

Requesting Party: Federal Government

Reference: Volume 3, Section 7.5.5, Page 7-14

Preamble: EnCana states that “Three dominant land actions occur in the RSA that can affect native prairie grassland integrity. These include shallow gas and oil development, military activities and cattle grazing…The main effect issues for this land action are related to the increase in weedy plant species establishment and spread.”

Request: GOC recommends that EnCana: 1. explain the methodology and underlying assumptions which were used to support the above statement; 2. specify the effects of cattle grazing on vegetation establishment after shallow gas disturbance, including the effects on soil and vegetation recovery times; 3. explain why cattle grazing effects on vegetation disturbed by the Project was not considered for newly developed (and disturbed) lease, pipeline, and access trails within the Local Study Area (NWA); 4. specify the mitigation measures required to promote vegetation recovery on pipelines, access trails, and wellsites where cattle grazing co-exists; and 5. specify historical mitigation measures to promote vegetation recovery Response: 1. This statement is based on a review of regional literature and the direct experience of vegetation and wildlife habitat specialists working on the CFB Suffield and in the NWA. 2. Cattle can preferentially select pipeline and other rights-of-way for foraging purposes especially in spring (Thacker 1989, Naeth et al. 1990). If grazing is excessive, potential impacts could include a reduction in topsoil depth, reduced litter, and increased exposed soil. 3. This impact was not considered because only seeded pipelines (loop lines) are at risk and these lines amount to less than 0.5% of grazing pasture area. 4. Working with PFRA to rotate grazing away from newly seeded pipelines is the key mitigation. In areas where problems occur or continue the use of electric fences may be considered. 5. In the past, EnCana has not utilized any specific mitigative measures regarding cattle grazing effects with the exception of fencing cattle out of some well site locations in the NWA.

Reference: Volume 3. Pg 7.15.

Preamble: The footprint associated with proposed infill drilling of 1275 wells and associated lateral and loop pipelines was also estimated for NWA S (0.39 %) and NWA N (0.41 %).

Request: GOC recommends that EnCana explain the assumption that work completed over a 20 year timeframe will produce the same impacts as this that will be created over a three year timeframe.

Response: Disturbance footprint is a quantifiable measure of cumulative impact on native prairie grasslands. The intent of this analysis was to estimate the relative magnitude of the incremental effect of shallow gas infill drilling (project footprint) on the existing footprint attributable to past land use effects. The estimated project footprint is much lower than the existing footprint because the project is limited to shallow gas infill drilling within the framework of existing (and more extensive) pipeline and access route infrastructure. Please see Volume 3, Figure 3F-2 (page 3F-8) for a visual example of the differences in density of existing and project pipelines.

The estimates used to measure cumulative impact were based on different construction methods. Construction methods have continuously improved over EnCana’s 30 year history in the NWA and it is EnCana’s intention to continue to improve its practices to reduce future impact.

Reference: Volume 3, Section 7.5.5, Page 7-12

Preamble: EnCana states that “The cumulative effects of the Project combined with past, existing and future projects on vegetation VECs…is rated as insignificant” However, EnCana also states that “There is uncertainty and concern regarding the synergistic effect of weed transmission from source areas in the MTA and cattle in the NWA…They dynamics of wind- and cattle-aided weed transmission are poorly understood in the CFB Suffield.”

Request: GOC recommends that EnCana provide the rationale and justification for the conclusion that the cumulative effects of the Project on vegetation VECs is insignificant given that there are concerns about weed transmission by cattle.

Response: The reasons for concluding that the Project when combined with past, existing and future projects on vegetation VECs is rated as insignificant are listed in Volume 3, Section 7.5.8, pages 7-22 and 7-23. The most heavily weighted of these reasons were: 1) the small project footprint; and 2) the results of 2006 vegetation surveys (Appendix 3C), which show that in-fill drilling from 8 to 16 wells did not significantly increase introduced and weedy plant species abundance. It is important to note that these results reflect a less comprehensive approach to post-construction reclamation than will be conducted for the proposed project. Cattle grazing has occurred in the NWA since the 1970s and associated impacts were taken into account via the vegetation triangle field program (Appendix 3C). Cattle grazing at the stocking levels currently applied did not result in landscape-level weed issues (see Appendix 3C).

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 119

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 120

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 121

Requesting Party: Federal Government

Reference:

Volume 1, Appendix H ‘Conceptual Reclamation Plan’, Section H.1, Page H-3 to H-4

Preamble:

Request: GOC recommends that EnCana describe, as from the Terms of Reference, 3.2 “Include rationale for selection based on the need for the development of self- sustaining biologically diverse ecosystems consistent with the appropriate sub-region of the Prairie Natural Region with reference to the use of native vegetation species; re- establishment of self-sustaining topography, drainage and surface watercourses and vegetation communities representative of the surrounding area.” and from 5.2 “preservation of biodiversity; sensitivity of the component to disturbances or pollution; importance of the component’s ecological role;”. Response: EnCana takes the position that the project will not create a landscape level of disturbance requiring the restoration of drainages, watercourses, and vegetation communities. The minimum disturbance construction techniques proposed for the Project (e.g., dormant season construction, shallow gas drilling and plowing lateral lines) all combine to create a low level of disturbance on a small footprint over a short time period.

Reference: Volume 1, Appendix H ‘Conceptual Reclamation Plan’, Section H.3, Table H-1, Page H-5

Preamble: Table of typical density values lists many “fair-poor” ranges, but does not provide values for the full range of expected values from good to poor. This makes it difficult to evaluate what might be “good” conditions, or expected conditions, against which to measure reclamation success.

Request: GOC recommends that EnCana provide the full range of possible bulk density values for native grasslands (not cultivated soils) in sandy, loamy, and clayey soil types at topsoil and subsoil depths. Response: EnCana provides the following figure that relates soil texture with bulk density values that represent thresholds at which root penetration is restricted. The threshold isodensity lines should be regarded as approximate because plants are often able to penetrate a soil restriction layer.

Daddow, R.L. and Warrington, G.E. 1983. Growth-limiting bulk densities as influenced by soil texture. USDA Forest Service, Watershed Systems Development Group, Fort Collins CO. Report WSDG-TN-00005. 21 p.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 124

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 125

Requesting Party: Federal Government

Reference: Volume 1, Appendix H ‘Conceptual Reclamation Plan’, Section H.3.4.1, Page H-7

Preamble: The proponent states “Reclamation work that has as its goal, the re-establishment of a natural ecosystem, may benefit from locally collected seed that has a large genetic diversity.”

Request: GOC recommends that EnCana clarify whether this is a specific “goal” and “objective” of the reclamation plan. Response: The reclamation goals and objectives for the Project are to reclaim the Project area to a viable ecosystem or to a state which will provide equivalent land capability, compatible with the surrounding environment. The reclaimed areas will provide a range of land uses including those currently active on the landscape, military, grazing and environmental research.

Reference: Volume 1, Appendix H ‘Conceptual Reclamation Plan’, Section H.3.9, Table H-2, Page H-11

Preamble:

Request: GOC recommends that EnCana update and revise the seed mix table to more appropriately reflect the goals of the reclamation plan (e.g. “with consideration to the unique features and valued components of the NWA” Volume 1 Page H-3). Justify any non-native species retained on the list.

Response: EnCana will provide a revised and updated seed mix table with consideration of unique features and valued components of the NWA upon completion of site-specific inventory and assessment.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 128

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 129

Requesting Party: Federal Government

Reference: Volume 1. Appendix H. I-26 Sec 162.

Preamble: Access will avoid known and discovered weed infestation by using alternative pathways on and off of the right- access and must be approved by EnCana.

Request: GOC recommends that EnCana provide details of how this will impact biodiversity, species at risk and the overall foot print of the project. Response: This mitigation will occur only in the instances of restricted and noxious weeds listed under the Alberta Weed Act. By minimizing the spread of such weeds by vehicles, this will protect biodiversity and the habitat of listed species.

Reference: Volume 1. Appendix H. I-26. Sec 168.

Preamble: One time access used by large equipment under frozen condition may not be used by general traffic under thawed conditions.

Request: GOC recommends that EnCana discuss the potential surface impact of these vehicles as well as the potential increase in surface disturbance/project footprint.

Response: Large equipment will be accessing during dry, dormant or frozen conditions which will reduce the potential for disturbance. Any compaction identified in these circumstances will be remediated.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 132

Requesting Party: Federal Government

Reference: Volume 3. Conceptual Protection Pan Vol. 1 App H.

Preamble:

Request: GOC recommends that EnCana discuss how the saline solids are to be reclaimed.

Response: EnCana does not anticipate activities in areas where saline soils would be encountered. Construction in saline wetlands and saline grasslands.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 134

Requesting Party: Federal Government

Reference: Volume 1, Appendix I. Draft Environmental Protection Plan. Section I.3. Page I-5

Preamble: The proponent states, "Environmental compliance will be achieved through sharing of information, providing orientations and training, hiring qualified staff and providing on-site inspection of activities through proactive and adaptive inspection programs.”

Request: GOC recommends that EnCana: 1. Clarify how proposed practices will improve upon existing practices. 2. Clarify whether independent third party auditing is a consideration.

Response: 1. The proposed practices will improve upon existing practices by increased training and the hiring of an environmental inspector(s). Training provided and environmental inspection will be fit for purpose pertaining to the issues identified for the project and unique to the special environmental conditions that exist in the NWA. 2. Third party auditing will be considered for the program.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 136

Requesting Party: Federal Government

Reference: Volume 1, Appendix I. Draft Environmental Protection Plan. Page I-27

Preamble: The proponent states that “EnCana will plan access on a holistic basis. The needs of the system development will be considered over individual sites and ROWs.”.

Request: GOC recommends that EnCana clarify how planning access on a holistic basis will rationalize itself with species at risk locations and setbacks which must be considered on a site specific basis. Response: Identification of listed species are identified for the PDA team to verify in the field. The team understands that sometimes, by prioritizing a single species or landscape element, you may do so at the expense of other important elements. That said, locations supported for development(s) are chosen with consideration for a host of different variables (e.g., wetlands, vegetation, wildlife, topography, existing disturbance, safety, regulatory framework, economics, construction capabilities).

While some locations may not appear optimal when considering isolated components, they are often supported based on a number of features of the local landscape. It is expected that if an undue amount of negative impacts may be incurred as a result of a proposed development, it is mitigated for or cancelled. Variables that are defined by law however, are not compromised (e.g. destroying a burrowing owl burrow).

Reference: Volume 1, Appendix I ‘Environmental Protection Plan’, Section I.6.11, Page I-42

Preamble: The proponent states “EnCana will implement undesirable vegetation control on its ROWs whenever the cause of the infestation is the result of company activities”.

Request: GOC recommends that EnCana describe what constitutes infestations as a result of company activities, and describe the methodology to determine this.

Response: Determining root causes of infestations will be based primarily on right-of-way versus off right-of-way densities of undesirable vegetation. Pre-development assessments will also be reviewed to understand the pre-existing conditions. If through evaluation it becomes apparent that other land uses are fully or partially responsible for infestations, EnCana will work collaboratively with other land users to remedy.

Reference: Volume 1, Appendix I. Draft Environmental Protection Plan. Page I-51

Preamble: A figure on page I-51 in the EPP describes the procedure of ploughing snow and brush to clear a work area for gas well installation.

Request: The GOC recommends that EnCana: 1. Discuss the environmental impacts of the above activity. 2. Include expected effects on small mammal and shrub associated bird populations and the recovery rate of brush in your discussion. 3. Clarify the fate of the windrows created from the clearing of snow and brush. 4. Provide total the area that will be cleared of snow and brush and on the number of wells that will be affected.

Response: 1. Plowing snow and brush may result in scalping. 2. Effects will be captured in the PDA. Since the construction window occurs in the dormant or frozen seasons, effects are expected to be insignificant. 3. Snow windrows will melt and any brush will be removed from site. 4. Number and total area will be determined by a PDA and the EPP.

Reference: Volume 3 and Volume 1 Appendix I EPP

Preamble: It is frequently cited throughout Volume 3 and in the Environmental Protection Plan (EPP) that mitigation measures will be followed ‘wherever possible’ ‘where possible’ ‘whenever possible’. However, it is not clear what economic, logistic, other circumstances would result in these mitigation measures not being followed.

Request: GOC recommends that EnCana elaborate on mitigation and the EPP and provide the threshold values that would constrain the implementation of mitigation measures. Describe threshold values implied by the statements ‘whe--- possible’.

Response: The context has environmental and to a lesser extent economic measures. EnCana’s approach is to complete a Pre-disturbance Assessment (PDA) in the area and evaluate the potential environmental impact on the landscape and ecosystems. There may be circumstances where a setback is encroached to protect another VEC.

EnCana has proposed a holistic approach to the PDA process and will not commit to a rigid threshold since they could vary area by area and are issue dependent. Any conflicting issues will be based on weighing all issues and concerns with the objective of minimizing overall environmental footprint. In rare occasions, the field investigation may result in a route or a location that may impinge upon buffers. These instances will occur only when in the judgment of the team, it is determined that greater ecological damage would be caused adhering to the buffers (e.g., greater damage to sensitive upland resources than the wetland). This approach results in responsible and effective environmental practices rather than focusing on established, and potentially arbitrary (depending on the context) policies regarding setbacks.

Reference: Volume 2, Section 3-3, Temporal Scope of Assessment, Page 3-6

Preamble: The Terms of Reference suggest that a reasonable temporal framework for the assessment would begin in 1975 and that with regard to Cumulative effects they will generally be larger than project effects and indicate rationale for boundaries should be provided.

Request: GOC recommends that EnCana describe and provide justification for the temporal boundaries used for each discipline.

Response: Cumulative effects assessment for the Terrestrial Biophysical disciplines was conducted for selected VECs pertaining to soils, vegetation and wildlife. Volume 3, Section 7.2.2 (pages 7-2 and 7-3) outline the temporal assessment periods for these disciplines. The time period 1975 – start of oil and gas activities in the NWA – was used as the beginning point of the CEA. Footprint inventory and empirical studies in 2006 (vegetation triangle program, paired pipeline vegetation sampling, small mammal inventory, antelope surveys, breeding songbird surveys, amphibian surveys all reflect the long-term effects of oil and gas development since approximately 1975.

For the Historical Resources (Volume 5, Section 2.9), Air Quality (Volume 6 , Section 2.9), Human Health (Volume 6, Section 6.9), the rationale for temporal boundaries is noted in these sections.

Cumulative effects on all other VECs whose project effects were negligible were not analyzed and therefore the delineation of temporal boundaries was not necessary.

Reference: Volume 2, Section 3.4 Spatial Context of the Assessment, Page 3-6 Volume 3, Section 5.4.2 Wildlife, Page 5-5

Preamble: EnCana identifies (Volume 3, Section 5, for each species) that declines in the Burrowing Owl, Ferruginous Hawk, Loggerhead Shrike, Bairds Sparrow, Grasshopper Sparrow, Badger, small mammals, Plains Spadefoot Toad, and Western Hognose Snake, are partly attributable to the conversion of native prairie to crops and cultivation, EnCana acknowledges (Volume 3 page 5- 5) that “The main pressures on prairie wildlife populations and habitat in southeast Alberta include: • agricultural conversions and intensifications: cultivation, irrigation, intensive • livestock operations and increased grazing stocking rates • urban and country residential expansion • development of energy resources including wind, coal and oil and natural gas • military training • construction and increased use of roads and other infrastructure

Request: The GOC recommends that EnCana undertake a comprehensive cumulative effects analysis that includes an assessment of these effects on the project.

Response: The regional (SE Alberta) issues listed above have over the last century exerted cumulative effects resulting in population declines for some species. The cumulative effects of the proposed project on the above and other wildlife species will arise from a much smaller sub-set of land uses than identified above. For example, no agriculture cultivation or irrigation, urban or country residential development, wind energy projects, or coal development projects will occur in the future in the RSA identified for wildlife CEA (Volume 3, Section 7.6). The only additive land use that will occur in the NWA over the next 20 years is the project. Cattle grazing levels are assumed to remain the same. Military training will continue to occur in the MTA west of the NWA at somewhat higher levels than historical ones (i.e. formation level training). Section 7.0 of Volume 3 identifies the future land uses and interactions that have potential to result in significant cumulative effects on listed wildlife species and habitat in the NWA. The comprehensive CEA recommended by the GOC, while potentially useful for regional planning, is outside of the scope of a Project-specific CEA.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 143

Requesting Party: Federal Government

Reference: Volume 2, Section 3.5.4 and 3.5.5, Determination of Significance. Page 3-11

Preamble:

Request: GOC recommends that EnCana: 1. Provide further detail to outline conceptually and quantitatively what the thresholds will be for environmental impacts in terms of inferential statistics and variables measured. 2. Provide a detailed assessment of environmental impacts (including cumulative effects) for all VECs from a zero wells per section perspective, to compare with 8 and then 16 wps.

Response: 1. Assessment of significance of effects was not based solely on the results of inferential statistics. As per Volume 2, Section 3.5.4 (line 1 first paragraph) determination of significance took into account multiple factors. Thresholds were not established or used for rating significance. 2. Insufficient quantitative information was available to determine the status of VECs as of the early 1970s when no wells were present in the NWA. For that reason, quantitative comparisons of from 4 to 8 and 8 to 16 wells per section were applied. The current status of VECs reflects past shallow gas (and other impacts) in the NWA.

Reference: Volume 3, Sections 3, 5, 6, 7

Preamble: The Terms of Reference specify (II 6.1 General Points) The proponent shall consider both the direct and indirect effect, reversible, and irreversible, short- and long- term and cumulative effects of the project.

Request: GOC recommends that EnCana: 1. Conduct surveys perpendicular to trails of all classes (DND study class 5, 4, 3, 2), wells, and pipelines of various ages categories. 2. Transects should be on both sides of the pipeline because of the role of wind in moving seed. Samples should occur in all major ecosections. 3. Use average distance to edge of crested wheat effect by direction/ecosection for the 1980-89 time period to estimate the size of the indirect project footprint and incorporate this into project, residual, and cumulative effects estimation.

Response: EnCana does not agree with the suggestion that surveys of past disturbances in the 1980-1989 time period will yield additional, useful information for estimating project residual and cumulative effects.

Construction and reclamation practices proposed by EnCana are substantially more reliable and effective at minimizing ground disturbance and achieving reclamation goals. Land use practices (military training, cattle grazing, resource extraction) since the 1970's have changed a great deal but the impacts extended into the 1980's and many remain today. Furthermore, the results of any such surveys that are suggested above, will not be consistent in terms of demonstrating stepwise improvements in practice or recovery of the prairie over time because ongoing research in this rather new and evolving field of land reclamation has resulted in advances but also "dead-ends" in terms of progress.

Reference: Volume 3, Appendix 3C Vegetation Triangle Sampling Program, multiple locations Volume 3, Appendix 5J Breeding Bird Survey, multiple locations Volume 3, Section 6.8.2 relies on results of effects assessment for plants and wildlife.

Preamble:

Request: GOC recommends that EnCana: 1. Describe and provide as part of the methods how “existing wells/section” (Appendix 5J) and “wells per section” (Appendix 3C) were determined and assigned. 2. Specifically address whether the density was determined by whether the individual bird point count/vegetation triangle fell within an experimental block (Koomati or D6/D8 designated 16 wps, for example) or whether it was based on the number of wells in a square mile window centred on the point count or triangle.

Response: 1. The number of existing wells occurring in a given section of land was enumerated by GIS overlay of wells onto a section grid. Unique conditions classified as 4 wells/section included quarter sections within sections with 4 or 5 wells/section. Unique conditions classified as 8 wells/section included quarter sections within sections with 7, 8 or 9 wells/section. For the vegetation program, unique conditions classified as 16 wells/section included quarter sections within sections with 15, 16 and 17 wells/section. This is described as a footnote to Table 3C-2 of Appendix 3C. For the bird program 15 and 16 wells/section were used classified as 16 wells/section, and 7 and 8 wells per section were classified as 8 wells/section, 4 for 4 wells/section.

2. Density was determined based on whether the grouping of 4 bird point counts (within a quarter section) or the vegetation triangle fell within a quarter section that supported a density of 4, 8 or 16 wells per section based on the discussion in point #1 above.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 147

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 148

Requesting Party: Federal Government

Reference: Volume 3, Section 7, page 7-15, 7-25 Section 1.2.1, page 1-2 Volume 3, Section 3, Table 3-1, page 3-19,

Preamble: In Section 7 EnCana asserts that Project footprint will be less than 0.5 % (page 7-25) and will be 0.39 for South NWA and 0.41 for North NWA (page 7-15).

Request: GOC recommends that EnCana provide details on how these percentages were calculated for the project footprint.

Response: Please refer to Volume 3, Section 3.7.2.1, pages 3-22 and 3-23 and Volume 3, Appendix 3L for detailed discussion of the methods and results of project footprint assessment. Appendix 3L (page 3L-6) provides assumptions associated with assigned Project feature widths.

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

Preamble: A vehicle management and access plan is proposed as one of the mitigation measures for this project.

Request: GOC recommends that EnCana provide details on the vehicle management and access plan and describe how this will provide mitigative measures for the Project.

Response: The vehicle management and access plan starts with the PDA. Once completed, an access map is generated to facilitate traffic. All personnel will be trained about environmental concerns, each site will have supervision and the Environmental Inspector will monitor and coach personnel.

Reference: Volume 1, Section 2.1.1.1. Geology. Page 2-2

Preamble: The proponent states, “The reservoir is rich in clay, and has high water saturation and low permeability.”

Request: GOC recommends that EnCana clarify how much water will be produced from these wells given the attributes of the underlying formation. Estimate the cubic metres of water production per well and provide empirical support from similar operations. Stipulate whether this produced water will be disposed of in sumps or other locations. Clarify whether the high water content has been accounted for on estimating the number of swabbing events.

Response: Water production and swab event estimates for the proposed new wells were established using data collected from existing wells within the NWA. Data from existing wells within the NWA was used because it is believed it provides the best insight on how new wells are likely to perform. Currently 46% of existing wells require 2 to 3 swab events per year. Each swab event removes 0.5 to 0.7 cubic metres of water from the well bore. Based on these statistics, annual water production of a swab well averages between 1.0 and 2.1 cubic metres. These statistics support estimates described in Volume 1, Section 2.2.3.2. Swabbing and Well Site Visits. Page 2-19. Water swabbed out of the wells will be contained in a tank truck and transported to an existing produced water treatment facility. From the produced water treatment facility, water will be transported to a licensed disposal well for injection and solids will be transported be to a licensed 3rd Party waste disposal facility.

Reference: Volume 1, Concordance Table, Page 5-19; and Volume 3 Section 2 Pages 2-1 to 2-41; Volume 4, Sections 3 and 4 Pages 3-1 to 4-18; Volume 1 Section 2.1 Pages 2.1 to 2.15; and Volume 4 Section 2.7, Pages 2-6 to 2-24

Preamble:

Request: GOC recommends that EnCana provide a useful discussion or classification exercise on slope gradient and provide a detailed slope description/classification. The use of publicly available SRTM imagery and/or commercial LiDAR data may be required to provide the required detail on slope gradients.

Response: Pre-disturbance assessments are considered appropriate to evaluate slope gradient and provide detailed slope classification. All locations will be field validated prior to construction to ensure that slope gradient is assessed as per the Environmental Protection Plan and Project Description.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 153

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 154

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 155

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 156

Requesting Party: Federal Government

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

Preamble:

Request: GOC recommends that EnCana provide fracture/fault maps and a fracture/fault characterization for the two development areas (north and NWA south, as depicted in Figures 2.1 and 2.2), since the report specifically mentions that fractures are known to be important in the currently productive fields and this might significantly affect production and leakage. GOC recommends that EnCana explain if the fractures enhance the proposed production, and how the proposed drilling pattern maximizes the effect of these conduits.

Response: The description in Volume 1, Section 2.1.1.1 refers to the gas bearing units of the Second White Speckled Shales, the Medicine Hat and the Milk River formations in the regional sense. These fields extend over a large portion of SE Alberta and SW Saskatchewan as indicated in Section 2.1.1.1. In some areas within these fields there are natural fractures and they are deemed to enhance production. However in Suffield, including the Project Area within the NWA, there is very little evidence of natural fractures. Rock thin sections taken from core samples in Suffield show very few small cemented fractures. An FMI (Formation Micro Imager) log run on a cored well within the NWA 102/ 01-01-016-06W4 shows no obvious fractures.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 158

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 159

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 160

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 161

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 162

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 163

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 164

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 165

Requesting Party: Federal Government

Reference: Volume 1, Section 2.2.2.3, Page 2-19

Preamble: EnCana states “Working space for pipeline installation typically will be 15 m, and up to 30 m where required (e.g., curves)”.

Volume 3, Section 2.8.2.1, page 2-27, EnCana suggests that working space is a range of values between 2 and 12 m.

Request: GOC recommends that EnCana clarify what the working space and disturbance footprint will be for pipelines in all situations.

Response: The precise size of the disturbance cannot be determined at this time. Site specific PDA’s will be completed and disturbance will be minimized using appropriate mitigation. EnCana must follow Occupational Health & Safety guidelines for worker safety; therefore, larger disturbances will be required where hole stability and worker safety could be compromised.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 167

Requesting Party: Federal Government

Reference: Volume 3, Section 2.7.2, Table 2-1 & Table 2-2, Page 2-20, Section 2.8.2.1, Page 2-27, Section 2.8.2.2, Page 2-30

Preamble: EnCana suggest that 45.9 % of the NWA is rated as extremely sensitive to wind erosion and 9.2 % of the NWA is rated as extremely sensitive to water erosion. Furthermore, EnCana states that “Pipeline and well site construction, and traffic on access routes during construction could cause exposure of bare ground and reduction of protective vegetative cover, resulting in loss of topsoil or underlying soil material due to wind erosion. Such effects would be most severe in areas with coarse-textured soils (sands, gravels), dunes with variable slopes and aspects, and steeper slopes facing west, southwest, and northwest.” Finally, EnCana states that “compaction caused by excess traffic can increase overland flow, which can promote water erosion in channels or gullies. The risk of water erosion of soils is highest when construction occurs in areas with long or steep slopes…high clay content, and low vegetative cover.”

Request: GOC recommends that as 55.1% of the NWA is rated at extreme risk of soil erosion, in addition to identifying mitigation to minimize soil erosion during construction and operation, EnCana identify specific mitigation measures to directly control soil erosion resulting from the Project, especially during drought conditions. GOC recommends that EnCana indicate how such mitigation measures will be used to address the particular problem, and how the mitigation will be considered in the context of a protected area. For example, the use of two- strip gravel may reduce erosion potential for vehicle access, but may have negative impacts on vegetation and wildlife.

Response: Mitigation measures have been developed for access in areas rated with high risk of wind erosion and can be reviewed in Volume 1, Section I.5.3, page I-20 (the Wind Erosion Control section). All mitigation prepared for the project has been prepared in the context of a National Wildlife Area. It is important to note that <0.57% of soils with extreme risk to erosion are estimated to be directly effected by the Project.

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

Preamble: EnCana states that “[key mitigation measures include] placement of access trails to avoid ground disturbed by pipeline construction.”

Request: GOC recommends that EnCana clarify the intent of this statement—whether the intent is to identify two distinct corridors—one for access and one for the pipeline.

Response: There may more than one corridor depending on the site specific conditions. To allow reclamation of the pipeline disturbance areas, EnCana will not create an access route overtop of the pipeline disturbance area.

Reference: Volume 3, Section 2.8.2.1, Page 2-28, Volume 1, Section 2.1.1.2, Figure 2-1 & Figure 2-2, Page 2-3/2-5

Preamble: EnCana states that “[key mitigation measures include] avoidance of construction in Gravely Sand Plains, Gravel Plains, or Inclined Fans and Terraces Soil Landscape Features of the South Saskatchewan River Valley”. However, Figures 2-1/2-2 (Proposed and Existing Infrastructure Within the NWA South/North) depict proposed wells in those areas.

Request: GOC recommends that EnCana confirm whether these areas will be avoided during construction.

Response: EnCana will maintain a setback distance of 100m from the slope break of the South Saskatchewan River Valley. EnCana is not proposing and will not be drilling wells in such areas.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 171

Requesting Party: Federal Government

Reference: Volume 3, Section 2.8.2.2, Table 2-6 & 2-7, Page 2-27/28

Preamble: In the Tables, EnCana considers Construction, Operations, and Decommissioning in assessing environmental effects.

Request: GOC recommends that EnCana consider all other phases of development, including maintenance activities, re-swabbing, re-fracturing, water disposal for wells producing water, and reclamation, in assessing effects on soils sensitive to erosion.

Response: See the response to Terrestrial 211.

Reference: Volume 3. Section 2.8.3. Pg 2.37

Preamble: EnCana states “large sand plains: project activities will avoid site-specific locations where slopes exceed 15% as per EPP and therefore insignificant effects. BUT, will EPP states (EPP Sec 171)…. the project will avoid sandy soils or steep gradient slopes with erosion potential (>15%). Where slopes cannot be avoided, site-specific plans will be created.”

Request: GOC recommends that EnCana provide details on if and where sloped areas exceeding 15% will be impacted as well as the cumulative impacts and follow-up to ensure that the areas are returned to a pre-established state.

Response: Please see Volume 1, Appendix I, page I-28, points 171 and 172 for mitigation measures on steep slopes. Mitigation success will monitored. Details of the monitoring program will be developed as a part of the Environmental Effects Monitoring Program.

Reference: Volume 3. Section 2.8.2. Pg. 2.38

Preamble: Encana states “Buffers around wetlands may not protect wetland water quality if soil materials contaminated outside the buffer zone follow pathways to the wetlands or if contaminated overland flow enters the wetland”

Request: Given the above statement, GOC recommends that EnCana provide justification that the impacts are insignificant for contamination.

Response: Spills or malfunctions are a highly unlikely event and EnCana currently uses on site vacuum trucks. EnCana proposes to continue to use this mitigative measure. Therefore, subsurface contamination is rated as insignificant.

Reference: Volume 3, Section 2.8.3, Page 2-38, Page 2-29

Preamble: EnCana states that “Landscapes in this Soil Landscape Feature [Rolling and/or Inclined Ridges] are presently showing numerous reclamation problems caused by existing traffic use. Therefore, traffic must be minimized and controlled to prevent problems in this Soil Landscape Feature. The residual environmental effects for the SLF are rated as insignificant.”

Request: GOC recommends that EnCana detail how traffic will be both minimized and controlled. Secondly, GOC recommends that EnCana further explain the rationale, with evidence, along with assumptions required, to support the statement that residual environmental effects are rated as insignificant, when EnCana states that “Severe winds are relatively common in this climatic region. Therefore, there is a potential for soil material exposed during construction activities to be affected by wind erosion before mitigation is completed.”

Response: Traffic control is an important factor in reducing the effects on soils. EnCana’s Traffic Control Protocols are detailed within the Environmental Protection Plan (Volume 1, Appendix I, Section I.5.2, pg I-19 to I-20).

When one compares the location of the specific soil landscape feature “Rolling and/or Inclined Ridges” within the NWA (Vol. 3, figure 2-1, pg 2-12) with the areas of extreme and high ratings for soils sensitive to wind erosion in the NWA (Vol. 3, fig 2-2, pg 2-18), it is evident that the specific Soil Landscape Feature (SLF) has a very low level of overlap with areas rated at risk of wind erosion. Volume 3, Table 2-1 quantifies this overlap, resulting in only 1.7% of the area of the NWA. When one further compares the disturbances planned in the areas of overlap (see Volume 1, Figure 2-2, pg 2-5) it becomes evident that only the minimum disturbance widths are planned for the areas of overlap. The insignificant rating is a function of the extremely small area of occupation of disturbances within the SLF and the mitigating factors proposed in Volume 3, Section 2.8.2.1, pg 2-27.

Long steep slopes prone to compaction, water erosion and possible channeling have the potential to lead to soil loss and reclamation problems. EnCana proposes to minimize these potential problems through Pre-disturbance Assessments that reflect the access location and preparation provisions presented in Volume 1, Appendix I, Section I.6.1 of the Environmental Protection Plan.

Reference: Volume 3, Section 2.8.3, Page 2-38, Volume 1, Section I.3.1, Page I-6

Preamble: Encana states “EnCana proposes to conduct Project-related activities within 100 m of wetlands only where it is unavoidable (e.g., if staying outside the 100 m setback would cause significant disturbance to upland ecosites.” Secondly, EnCana states “Copies of all relevant laws, codes, guidelines, and policies will be collected to understand and enforce legal obligations and will be available upon request.”

Request: GOC recommends that EnCana identify the number of locations and situations where activities would occur within buffers.

Given that the Federal Policy on Wetlands applies to the NWA, and that the policy was created to preserve wetland function and integrity, GOC recommends that EnCana explain how wetland function will not be impacted where Project-related activities occur within wetland buffers. Response: EnCana is committed to meeting the objectives of the Federal Policy on Wetlands. The Federal Policy on Wetlands specifies no net loss of wetlands. It is important to note, however, that the Federal Policy on Wetlands document makes no reference to wetland buffers or to any specific scientifically-defensible wetland buffer widths. No development will occur within wetlands.

Reference: Volume 3, Section 2.9, Page 2-40

Preamble: EnCana states “Given the footprint measurements over-estimate soils effects, the magnitude of cumulative effects on sensitive soils is negligible to minor.”

Request: GOC recommends that EnCana explain the assumptions and rationale required to make the statement.

Response: The magnitude of effects of the Project on sensitive soils was estimated by overlaying projected pipeline layout onto maps of sensitive soils. This process allowed a calculation of the percentage effect of available supply (land area) of different soil sensitivity classes to be measured. Buffer widths of 4.5 meters for tie-ins and 12 meters for laterals were applied. These widths take into account working space and trails and overestimate the actual direct disturbance of soils from plowing and trenching.

Reference: Volume 3, Section 2.9, Page 2-40

Preamble: EnCana states that “Dillon (2006) did not consider cumulative effects of increased formation level training to be significant.”

Request: GOC recommends that EnCana explain the relevance of this statement to the EIS, and how the study referenced supports the conclusion that the cumulative effects of the Project are insignificant.

Response: The above point was one of several points providing rationale for rating cumulative effects on soils as insignificant. Dillon (2006) conducted an environmental assessment of formation level military training and associated infrastructure. Section 7 of that report addressed cumulative effects assessment. On page 227 of Dillon (2006) it is noted that environmental effects of other activities that are likely to be implemented including oil and gas development were considered. Section 7.3 of Dillon (2006) listed four points relating to oil and gas effects. Soil effects are not prominent in this section and there is no mention of any significant cumulative effects on soils. The projected drilling of oil and gas wells presented in Table 29 implies that cumulative effects of combined military oil and gas activity was minor or insignificant.

EnCana has analyzed the effects of the project on the four soils VECs. Table 7-1 in section 7-4- 6, Volume 3, summarizes the existing and projected footprint on four soils VECs in the NWA and in the LSA.

The cumulative effects of the Project combined with past, existing and future projects on soils VECs are rated as insignificant. The following points support this conclusion: • Given that footprint measurements overestimate soils effects, the magnitude of cumulative effects on sensitive soils is negligible to minor. • Effects on soils in the MTA do not contribute to soils effects in the NWA (and vice versa). • DND did not consider cumulative effects of increased formation level training to be significant. • The EnCana estimate using digitizing of high resolution air photos is approximately 6 – 12% of land with >25% industrial bare ground.

Reference: Volume 3, Section 2.9, Page 2-40

Preamble: EnCana states that “The cumulative bare ground footprint after shallow gas infill-drilling (inside and outside of the NWA) is far less than critical thresholds identified by Dillon (2006).”

Request: GOC recommends that EnCana explain the relevance of this statement to the EIS, and how the study referenced supports the conclusions derived from it.

Response: Dillon (2006) conducted an environmental assessment of formation level military training and associated infrastructure. Annex B of that report is an appraisal of the carrying capacity of lands in the MTA of CFB Suffield to sustain military training. Dillon (2006) proposed indicators and candidate thresholds for assessing and monitoring effects over time. One of these indicators was ‘percent industrial bare ground’. They proposed candidate thresholds as follows:

• Cautionary/Restrictive: 20-25% of MTA exceed 25% [industrial] bare ground • Target: 25-30% of MTA exceeds 25% [industrial] bare ground • Critical: More than 30% of areas in MTA exceed 25% [industrial] bare ground

Based on footprint mapping for the EnCana shallow gas in-fill EIS the amount of bare ground attributable to combined military, oil and gas, livestock grazing activity as of 2005 that exceeds 25% ranges from 0.14% to 2.6% depending on location (see Volume 3, Section 2.9, Page 2- 40). These values are far less than the cautionary/restrictive threshold of 20-25% suggested by Dillon (2006). It is assumed that the thresholds proposed by Dillon (2006) are accurate and will inform cumulative effects management. As such it is noted that EnCana’s approach to estimating bare ‘industrial’ bare ground percentage are well under cautionary thresholds and are less likely to be breached by future land use activities.

Reference: Volume 3, Section 2.9, Page 2-40

Preamble: EnCana states that “Dillon (2006) identified over 20 mitigation measures intended to reduce the effects of increased formation level training on soils in the CFB Suffield. These measures were designed to minimize soil disturbance, compaction and contamination associated with military training activities”.

Request: GOC recommends that EnCana explain the relevance of this statement to the EIS, and how the study referenced supports the conclusion derived from it.

Response: Future cumulative effects on soils in the MTA portion of the Local Study Area will result from a combination of military and oil/gas activities (and livestock grazing). It is assumed that the DND will implement the 20 mitigation measures recommended by Dillon (2006) outlined to minimize impacts to soils. This, in combination with the mitigation measures proposed by EnCana to minimize shallow gas impacts on soils in the NWA (Section 2.8.1) will lessen the likelihood of cumulative effects on soils.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 181

Requesting Party: Federal Government

Reference: Volume 1, Appendix I, Page I-18

Preamble: EnCana states in EIS Volume 1, Appendix I, Page I-18 that: “on native prairie the actions that may be taken to protect vegetation and / or top soil include: … Removal of the thawed and wet portion of the topsoil under winter conditions,”.

Request: GOC recommends that EnCana explain how removal of thawed and wet portion of the topsoil under winter conditions will protect vegetation and/or topsoil.

Response: Removal of wet and thawed topsoil under winter conditions will assist in protecting the topsoil from admixing with subsoil. This would be a very infrequent occurrence and it is likely that EnCana would not construct /operate under these conditions. For wet and thawed conditions, EnCana has developed mitigation measures which are included in the Environmental Protection Plan, Appendix I, Section I 5.1.

Reference: Volume 1, Appendix I, Page I-18

Preamble: EnCana states in EIS Volume 1, Appendix I, Page I-18 that “on native prairie the actions that may be taken to protect vegetation and / or top soil include: … Ploughing snow over the thawed access trail or lease area under winter conditions to refreeze the area.”

Request: GOC recommends that EnCana clarify if snow will be ploughed onto, or ploughed off the thawed access trail or lease area under winter conditions. GOC recommends that EnCana explain, if snow is ploughed onto the thawed area, how this will refreeze the area, as snow typically acts to insulate the ground from heat loss, and therefore such an action would not typically increase refreezing of the subsurface.

Response: In situations where snow has been deposited in significant quantity such that access is restricted, it will be plowed off right-of-ways to allow work to continue.

In situations where snow is to be used to improve access conditions, it may be plowed onto right-of-ways to create a temporary ice cap of the area. By moving snow onto right-of-ways and subjecting it to heavy traffic, the snow is compressed, creating a hard ice layer. Snow will be used primarily as a temporary ice cap as opposed to an attempt to refreeze the ground.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 184

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 185

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 186

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 187

Requesting Party: Federal Government

Reference: Volume 3, Section 2.7.3, Page 2-25, Table 2-5

Preamble: EnCana shows in EIS Volume 3, Section 2.7.3, Table 2-5, Page 2-25, “Existing Surface Disturbance by Soil Landscape Feature in the National Wildlife Area.”

Request: GOC recommends that EnCana provide an estimate of the additional proposed land area to be disturbed by soil landscape feature in the National Wildlife Area, and include this in the Project Environmental Effects Assessment (EIS Volume 3, Section 2.8).

Response: EnCana estimated the additional proposed land area to be disturbed a by soil landscape feature are in Table 1 and Table 2 below:

Table 1 Proposed Disturbance by Soil Landscape Feature in the National Wildlife Area (Narrow*) Total Land Area Land Disturbed Percent Proposed Soil Landscape Feature Area (ha) (ha) Disturbance in NWA

Choppy Sandhills 13,705.53 24.22 0.18%

Gravel Plains 19.62 0.01 0.07%

Gravelly Sand Plains 376.88 0.35 0.09%

Inclined Fans and Terraces 1,660.08 1.03 0.06%

Majority of Other Soil Landscapes 5,815.01 9.12 0.16%

Rolling and/or Inclined Ridges 3,928.27 5.77 0.15%

Sand Plains 13,992.72 25.44 0.18%

Sands with Wetlands and Salinity 151.82 0.45 0.30%

Sands with Wetlands and Subirrigated 294.78 0.33 0.11%

Sloping Till with Channels 618.85 1.60 0.26%

Steep Slopes with Gullies and Channels 4,506.01 3.90 0.09%

Till or Lacustrine with Wetlands 811.15 1.93 0.24%

Wetlands 150.18 0.19 0.13%

Table 2 Proposed Disturbance by Soil Landscape Feature in the National Wildlife Area (Wide*) Total Land Area Percent Proposed Land Disturbed Disturbance in Soil Landscape Feature Area (ha) (ha) NWA

Choppy Sandhills 13,705.53 61.10 0.45%

Gravel Plains 19.62 0.03 0.16%

Gravelly Sand Plains 376.88 0.90 0.24%

Inclined Fans and Terraces 1,660.08 2.38 0.14%

Majority of Other Soil Landscapes 5,815.01 21.79 0.37%

Rolling and/or Inclined Ridges 3,928.27 14.69 0.37%

Sand Plains 13,992.72 62.33 0.45%

Sands with Wetlands and Salinity 151.82 1.29 0.85%

Sands with Wetlands and Subirrigated 294.78 0.78 0.26%

Sloping Till with Channels 618.85 3.94 0.64%

Steep Slopes with Gullies and Channels 4,506.01 9.96 0.22%

Till or Lacustrine with Wetlands 811.15 5.23 0.64%

Wetlands 150.18 0.43 0.29%

* Narrow based on 4m wide loop lines, 2m wide tie-ins and 10m2 wells. Wide based on 12m wide loop lines, 4.5m wide tie-ins and 10m2 wells.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 189a

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 189b

Requesting Party: Federal Government

Reference: Volume 3, Section 3.1, Page 3-2

Preamble: EnCana states that “The disturbance footprint associated with the Project when added to the existing footprint from past land actions in the NWA is cumulatively less than 5% for all but two cover types in the NWA.”

Request: GOC recommends that EnCana detail the methodology and underlying assumptions used to create the projected footprint estimate, including how it assessed short-term (immediately after construction), medium-term (during operations), and long-term (including abandonment).

Response: The detailed methodology for calculating project footprint on vegetation is described in general on Section 3.7.2.1, page 3-22 of Volume 3 and in detail (including assumptions) in Appendix 3L (pages 3L-3 to 3L-7). The impacts assessed were based on a worst-case scenario which is 100% loss of vegetation integrity for short, medium and long time frames. This is clearly not the case based on vegetation recovery observed during the paired pipeline sampling program (Appendix 3D, Volume 3).

Reference: Volume 3, Section 3.1, Page 3-2

Preamble: EnCana states that “The two cover types will be avoided as much as possible during the pre- planning phase of the Project (Pre-disturbance Assessment [PDAs]).”

Request: GOC recommends that EnCana define the phrase “as much as possible” as it relates to the above statement, and what criteria will be used to assess the possibility of avoidance.

Response: This sentence should be revised to read…..”When the presence of the two cover types (unclassified wetland and saline grassland) are identified by baseline mapping and confirmed with pre-disturbance field site assessments, they will be avoided”.

Reference: Volume 3, Section 3.1, Page 3-2

Preamble: EnCana states that “Emprirical studies done in 2006 showed that in-fill drilling from 8 to 16 wells per section did not notably increase introduced and weedy plant species abundance. These same studies showed no substantive changes in native plant community composition or dominant plant species”.

Request: GOC recommends that EnCana define the terms “notably” and “substantive” as they relate to the above statements, with respect to statistical analysis and hypothesis testing.

Response: The terms notably and substantive reflect mixed results regarding differences in values between 8 and 16 wells per section. Appendix 3C in Volume 3 provides a detailed information on the differences in mean values of introduced, weedy/invasive and native species richness, and cover sampled in quarter sections with 8 versus 16 wells per section. These results are summarized in point form in pages 3C-33 to 3C-35. Three of the four unique conditions sampled had higher numbers of native species in 8 versus 16 wells per section. One of these sampling conditions was statistically significant. None of the unique conditions sampled showed statistically significant differences in native plant species cover between 8 and 16 wells per section. One of four unique conditions sampled showed a statistically significant difference in mean percent cover of weeds (in 100m2 belt transects) between 8 and 16 wells per section. This quarter section was located outside of the NWA. Two of the four unique conditions sampled had [statistically] significantly higher numbers of introduced plants (in 1m2 plots) in 16 wells per section than in 8 wells per section. Both were located outside of the NWA.

Reference: Volume 3, Section 3.4.1, Page 3-3

Preamble: EnCana states that “the above land uses [agricultural conversions and intensifications… urban and country residential expansion, development of energy resources…construction and use of roads; invasive plant species establishment and spread; and intensive cattle grazing], if poorly planned and managed, have potential to result in native vegetation fragmentation resulting in a reduction of native grassland integrity through changes in structure, composition and/or function, loss of uncommon vegetation cover types and rare ecological communities and plant species.”

Request: GOC recommends that EnCana describe; 1. the current levels of fragmentation and subsequent effects on native grassland integrity; 2. the projected levels of fragmentation and subsequent effects on native grassland integrity, including structural, compositional, and functional changes, and loss or alteration of uncommon and rare ecological communities and plant species, as they relate to reproductive potential, population viability and recruitment for regional populations; and 3. the potential introduction and spread of non-native plant species, and invasive species on native species composition and any changes to plant and animal communities that may result.

Response: Past and projected potential fragmentation effects in the NWA are primarily from a single land use (shallow gas development) and result in a dispersed distribution of primarily narrow and linear development features. The distribution of linear and point features is relatively consistent per quarter section because of well spacing requirements associated with shallow gas development.

1. Current levels of fragmentation in different areas within the RSA and LSA and in different sampled quarter sections were estimated using footprint digitizing procedures. This approach provided the relative degree of existing footprint by linear and polygonal feature type. The pattern of disturbance feature distribution in the NWA is very similar because of the spacing requirements of shallow gas drilling. The vegetation triangle sampling program directly measured past and current effects (on vegetation parameters) of habitat fragmentation of in-fill drilling. The breeding songbird sampling program also directly measured the effects of fragmentation effects of 8 versus 16 well per section drilling. 2. Projected levels of fragmentation related to the Project were estimated using a preliminary project layout derived from baseline mapping. Please refer to Volume 3, Section 3.7.2.1, pages 3-22 and 3-23 and Volume 3, Appendix 3L for detailed discussion of the methods and results of project footprint assessment. Appendix 3L (page 3L-6) provides assumptions associated with assigned Project feature widths. The effects of projected levels of fragmentation resulting from in-fill drilling were EnCana Shallow Gas Infill Development in IR Due Date: the CFB Suffield National Wildlife Area CEAA File #05-07-15620 August 2nd, 2007 IR Requested By: IR No. Page Federal Government CEAA-EIS-012 2 #Terr - 193 - A

estimated using empirical studies as described in Point #1 above (i.e. vegetation triangle sampling/breeding songbird surveys stratified by well density). 3. The magnitude of effects of fragmentation associated with in-fill drilling from 8 to 16 wells per section were predicted using empirical approaches for native prairie integrity and breeding songbird VECs as described in Point #2 above. For more details of these programs please refer to Volume 3, Appendices 3C and 5J.

Reference: Volume 3, Section 3.6.1, Page 3-9

Preamble: With respect to existing conditions, EnCana does not discuss the presence or degree of invasion of non-native agronomic species from sumps, well sites, pipelines, and access trails.

Request: GOC recommends that EnCana quantify the presence and degree of invasion of non-native agronomic species.

Response: Presence and percent cover of invasive and weed species, which includes non-native agronomic species, on well-sites and pipelines was addressed as part of the paired pipeline vegetation program. Section 3D.3.4 of Volume 3 presents the results from invasive/weed belt transects for the paired pipeline vegetation program. Table 3D–5 in Volume 3 summarizes the number and percent cover of invasive and weed species encountered on well-pipeline and control transects by topographic habitat unit and pipeline age class.

Section 3C.4.8 presents the results from invasive/weed belt transects for the effects of well density as part of the triangle vegetation program. Table 3C-9 In Volume 3 presents the most frequently found invasive and weed species for quarter sections with 8 and 16 wps for the four unique conditions analyzed.

Reference: Volume 3, Section 3.6.2.1, Page 3-10

Preamble: EnCana states that “[a summary of results of the vegetation triangle sampling program for the 8 wps versus 16 wps program are provided]…Average bare ground in quarter sections with 8 wps ranged from 2.5% to 14.7% and with 16 wps from 6.2 to 12.5%”.

Request: Given that 15 m2 out of 640000 m2 ( .002%) was assessed for each of the samples (representing a quarter section), GOC recommends that EnCana explain the detectability and representation of disturbance features caused by shallow gas development, relative to undisturbed native prairie reflected in the sampling methodology.

Response: The purpose of the vegetation triangle sampling program was to randomly and quantitatively assess the differences in native vegetation parameters at the landscape-level. The paired pipeline sampling program quantified effects in the immediate vicinity of pipelines and leases. The footprint digitizing program measured the degree of past and existing effect for different broad jurisdictional areas (i.e. NWA-North, NWA-South, LSA/MTA and RSA/MTAS and Koomati. This multi-scale approach provided sufficient information to predict project impacts on various aspects of native prairie grassland integrity-including bare ground percentages.

Reference: Volume 3, Section 3C.1

Preamble: EnCana states that “The specific objectives of this field-sampling program were: to measure the effects of different well densities ( 8 vs. 16 wells per section) on multiple indicators of native range integrity; to compare the magnitude of well density effects to effects of fire frequency, grazing intensity and soil/landform type on indicators of native range integrity”

Request: GOC recommends that EnCana: 1. state the assumptions inherent in its sampling design to achieve said goals; 2. compare and contrast the predictive ability of experimental vs. observational studies; and 3. explain why control sites (i.e. well density=0) were not used in field sampling.

Response: 1. Some of the key assumptions associated with the vegetation triangle sampling program were: • Confounding effects of topographic and soils conditions were sufficiently controlled by topographic/habitat unit mapping • Confounding effects of fire frequency were sufficiently controlled by the fire frequency mapping obtained from DND. • Confounding effects of livestock grazing were sufficiently controlled by the cattle stocking rate data provided by the PFRA. • Sampling intensity was sufficient to reflect effects at the quarter-section level.

2. In experimental studies the investigator assigns exposure and measures outcome. In an observational study the investigator measures exposure and measures outcome. The vegetation triangle program is an observational study with a stratified random sampling design that attempts to control confounding environmental variables. This is the only practical method for Environmental Impact Assessment since experimental studies would require long time frames to await the results of treatments. 3. There were no quarter sections in the study area with no wells.

Reference: Volume 3, Section 3C.2.1, page 3C-4

Preamble: EnCana states that “Grazing intensity was described using data obtained from the PFRA. This data provided the number of Animal Unit Months (AUM) of grazing for each of the pastures delineated in the NWA and Koomati for the period 1990 to 2005. Taking into account the land area of each of the pastures, grazing intensity was expressed as the number of acres per animal unit month. These values were rank-ordered bracketed and assigned values of low, moderate and high.”

Request: GOC recommends that EnCana specify the assumptions required (and the validity of those assumptions), to rank grazing intensity by pasture. GOC further recommends that EnCana compare and contrast spatial measures of cattle grazing intensity within individual, and across pastures. Finally, GOC recommends that EnCana provide rationale for the selection of grazing intensity categories.

Response: Long-term cattle stocking rates were obtained from the PFRA. Mean values were obtained for each pasture and these were ranked according to their long-term stocking rates. It was assumed that mean values of 15 years of cattle grazing were sufficient to represent and separate the effects of grazing at the pasture level. Given that there are no internal fences within pastures and that sampling was conducted randomly at the quarter section level, EnCana considers this assumption as valid.

Reference: Volume 3, Section 3C.3.1, Figure 3C-2, Page 3C-8

Preamble: EnCana indicates the sample sizes for each treatment, outlined in the Figure above.

Request: GOC recommends that EnCana discuss the sample sizes collected, hypotheses that underlie the analysis, the quality of the data and the degree of certainty of the predictions obtained, and the ability to detect differences between treatments, relative to accepted practices for sample sizes. GOC requests that EnCana specify how cumulative effects were assessed for the Project, given that high intensity grazing treatments were never included in the sampling effort for the vegetation triangle sampling program.

Response: The sample unit used for the statistical analysis was the plot, hence the minimum sample size per treatment was 45 plots (n=45). That sample size is sufficient to perform the non-parametric test.

The hypotheses used for each test was: Ho: There is no significant difference between the ranked mean values of the treatments Hi: There is a significant difference between the ranked mean values of the treatments The test was run at a 95% of confidence (alpha=0.05)

According to the results presented in Table 3C-3, it is evident that the sampling methodology used provided data that allowed detecting differences between treatments. Thus, for grazing intensity comparisons 6 out of the 9 variables statistically analyzed show significant differences; for fire intensity comparisons 9 out of the 9 variables statistically analyzed show significant differences; for soil type comparisons 8 out of the 9 variables statistically analyzed showed significant differences; for well density comparisons 3, 3, 5, and 4 out of the 9 variables statistically analyzed show significant differences for unique conditions SD2/low/moderate, UF2/low/na, UF3/low/moderate, and UF3/moderate/na, respectively.

Based on data obtained on long-term stocking rates, high intensity cattle grazing occurs in three pastures located along immediately adjacent to the South Saskatchewan River. These areas comprise a very small portion of the NWA. They did not support sufficiently similar topography and vegetation cover to use as sites for the triangle sampling program. Cattle grazing levels for the vast majority of the NWA occur at ecologically sustainable levels based on stocking rate criteria from Adams et al. (2005).

Adams, B.W., L. Poulin-Klein, D. Moisey and R.L. McNeil. 2005. Rangeland Plant Communities and Range Health Assessment Guidelines for the Dry Mixedgrass Natural Subregion of Alberta. Rangeland Management Branch, Public Lands Division, Alberta Sustainable Resource Development, Lethbridge, Pub. No. T/040. 106 pp.

Reference: Volume 3, Section 3.6.6.2, page 3-16

Preamble: EnCana states that “Pipelines constructed from 1990-99 and 2000-05 showed intermediate levels of differences in native integrity measures between treatment and control samples although, as expected, recovery toward a native condition was more advanced on pipelines constructed between 1990 and 1999…Statistically significant differences between paired treatment and control samples were observed for 7 of 16 measured attributes for the 1990-99 age-class; and for pipelines constructed from 2000-05 there were statistically significant differences between paired treatment and control samples for 18 of 23 attributes measured…Since approximately 1980 there appears to be a gradient in the level of recovery toward a more native condition with increasing similarity in measured attributes between control and treatment plots with increasing time since construction”.

Request: GOC recommends that EnCana: 1. discuss the how this information was used in the identification of short, medium, and long-term impacts and determination of their reversibility; 2. discuss the hypotheses that underlie, and the quality of the data used to support the statement that since 1980 there appears to be a gradient in the level of recovery toward a more native condition; and 3. discuss how this information was used in the development of projected footprint modelling, in terms of extent and duration (short, medium and long-term) of effects of the Project on vegetation VECs.

Response: 1. The results of the paired pipeline sampling program showed that recovery to a more native vegetation condition occurred over time. For pipelines constructed in the 1980s no statistically significant differences between well/pipeline and control values for 17 of 22 attributes reflecting native integrity were observed. As noted in the above preamble, more recent pipelines showed lesser levels of recovery. These findings influenced ratings of reversibility and duration (i.e. reversible in long-term).

2. The hypothesis used for each test per attribute and age-class was: Ho: there is no significant difference between the ranked mean values of treatment and control. Hi: there is significant difference between the ranked mean values of treatment and control. The test was run at 95% of confidence (alpha=0.05)

The ‘quality’ of data was sufficient to draw conclusions regarding Project impacts.

3. In terms of magnitude of effect, projected footprint modeling assumed full disturbance of 4.5-m wide strip for tie-ins and 12-m for loop lines. See comments regarding duration in Point #2 above.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 200

Requesting Party: Federal Government

Reference: Volume 3, Section 3.7.2.1, page 3-22

Preamble: EnCana states that “Past effects at the site level show that native prairie integrity on pipelines and leases is less than in control areas, with improvements occurring over time.”

Request: GOC recommends that EnCana provide a specific definition of improvement, and rationale to support the above statement. Secondly, GOC recommends that EnCana specify a schedule for the return of habitat capability to areas impacted by the Project.

Response: Results of the paired pipeline sampling program showed that pipelines constructed in the 1980s showed greater similarity for several measures of native prairie grassland integrity on pipelines than on adjacent control sites. The measures included: • Less bare ground as measured by percent cover • More litter as measured by percent cover • Less number of introduced plant species • Greater ratio of native to introduced species • Less introduced plant species cover • Greater cover of native forb species The above points were measured relative to pipelines constructed in the 1990s and the 2000s and they represent improvements in terms of these measures of native prairie grassland integrity.

Improvement means that attributes indicating native integrity become closer to baseline native conditions over time.

For the purposes of this EIS we assumed a return to near-native conditions in from 20 to 25 years. Conditions prior to that time frame will steadily improve and would still maintain varying levels of utility to different wildlife species.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 202

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 203

Requesting Party: Federal Government

Reference: Volume 3 Section 3.7.2 Pg 3.24

Preamble: EnCana states that “Empirical measurement from past pipelines and wells in NWA indicate that recovery towards a near native condition was achieved in approx 20 years as long as crested wheatgrass was not used”. This contradicts Pg. 3.16 “Results show that pipeline construction and reclamation practices conducted in the 1970s were not conductive to the recovery of native habitat recovery, even after 30 years”.

Request: GOC recommends that EnCana explain the apparent contradiction between the two statements,

Response: Most pipeline reclamation in the 1970s involved the use of Crested Wheatgrass. Crested Wheatgrass cover along these 25 to 35 year old pipelines persisted. In the 1980s the use of Crested Wheatgrass was largely curtailed. The 1980s pipelines that did not use Crested Wheatgrass have recovered almost fully to a near native state.

Reference: Volume 3. Section 3.7.2. Pg 3.28

Preamble: EnCana states that “Herbicides will not be used near plants”.

Request: GOC recommends that EnCana clarify the term “near”.

Response: See the response to Terrestrial 212

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

Preamble: EnCana states that it “will utilize above-ground well sites which will result in a disturbance footprint of approximately 30 m2 per well.”

Request: GOC recommends that EnCana: 1. define the term disturbance, including measurement factors and criteria; 2. specify how the estimate of 30 m2 per well was produced, indicating underlying assumptions and hypotheses; 3. specify how access trails were included in the projected footprint estimate; and 4. specify how the footprint effects change over time, including estimates of short-term, medium-term, and long-term estimates of vegetative cover, composition, and subsequent effects on soils and wildlife VECs.

Response: 1. The 30 m2 amount for above-ground well disturbance was determined based on existing construction procedures. The area was calculated to be the area of disturbed soil associated with the bell hole required to tie-in pipelined to wells. 2. This area was based on typical bell hole dimensions associated with standard construction procedures. 3. The 30 m2 bell hole does not include the access trail. 4. With respect to native vegetation integrity, the magnitude of disturbance footprint will diminish over time assuming appropriate reclamation. The effects on soil and wildlife VECs are considered in the assessment of those VECs.

Reference: Volume 3, Section 3.7.2.1, page 3-24

Preamble: EnCana states that “Mitigation measures include: Standardization of access routes for specified vehicles according to wheel-width and restriction of access to specified vehicles”.

Request: GOC recommends that EnCana define what specified vehicles are, what rationale and selection criteria will be used to standardize access routes. GOC recommends that EnCana define how access restriction will be implemented, the types of restrictions to be imposed, and the rationale for the selection of specified vehicle access restrictions.

Response: The specified vehicles are construction and operations vehicles which will access the well during its producing life. These vehicles range from tractor trailer and tandem axle units to 4 X 4 pick up trucks. These vehicles are capable of using a single trail with the widest footprint being a dual tired tractor.

Standardized access routes will be determined during the PDA, which will indicate an alternative route for operations as appropriate based on site specific conditions. The terrain will be considered for optimum placement, including the effects upon any local plants and wildlife communities.

As stated in Volume 1 Section 2.2.1.3 of the EIS, construction will take place in dry or frozen conditions. Hence, vehicles will not be allowed access during wet conditions and 4 X 4 all terrain vehicles may be used by operations to reduce the footprint.

Reference: Volume 3, Section 3.7.2.1, page 3-24

Preamble: EnCana states that “empirical measurement from past pipelines and wells in the NWA indicates that recovery toward a near native condition was achieved in approximately 20 years as long as crested wheatgrass was not used as a reclamation species.”

Request: GOC recommends that EnCana clarify the term “near native condition” and what methodology and criteria were used to support this statement.

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

Reference: Volume 3, Section 3.7.2.1, page 3-24

Preamble: EnCana states that “Mitigation measures include…Elimination of “short-cut” routes and use only of established routes”.

Request: GOC recommends that EnCana specify the procedures that will be used to eliminate short-cut routes, what mitigation and reclamation will be carried out for those short-cut routes which will be eliminated. GOC recommends that EnCana specify how it will identify and ensure use of established routes.

Response: Once the PDA has been completed, an access trail map will be developed for the area. All personnel entering the area will be given a copy of the access map. The use of access maps, their importance, and associated non-compliance consequences will be communicated to all personnel who require access.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 210

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 211

Requesting Party: Federal Government

Reference: Volume 3, Section 3.7.2.3, Page 3-28

Preamble: EnCana states that “Herbicides will not be used near rare plant species or rare ecological communities. Contractors or employees controlling vegetation by mechanical means or herbicides will be issued maps and GPS coordinates with locations of rare plant species and rare ecological communities in the vicinity of construction areas.”

Request: GOC recommends that EnCana: • describe the specific types of vegetation which will be controlled by herbicide and the residual effects of herbicide application on vegetation, soils, groundwater and surface water, and wildlife VECs; • define the threshold distance in which herbicides will not be used; and • describe how rare plant species, rare ecological communities, and species at risk will be identified and mapped.

Response: Weeds identified by the Alberta Weed Control Act as either Restricted or Noxious may be controlled through the use of herbicides. Herbicide application will only be conducted by registered pesticide applicators. Herbicides will be used according to manufacturer specifications thereby minimizing the effect on non-target vegetation, soils, water and wildlife.

Threshold distances can only be established upon site specific evaluations and the products chosen to control specific plants.

Rare plants and listed species will be inventoried and mapped by professionals as part of the pre-development assessments, and avoided during any herbicide application.

Reference: Table 3D-6 (Volume 3, Section 3D-4, Pg 3D-36) pair.

Preamble:

Request: GOC recommends that EnCana describe how negative values are reported in the Table and explain the use of the formula to determine the difference between the pipeline/well and control. GOC recommends that EnCana explain the statement “All project effects were rated as insignificant or negligible assuming adherence to the mitigation and follow-up measures proposed in this report. Empirical measurements from past pipelines and wells in the NWA indicate that recovery toward near native conditions has been achieved in approximately 30 years as long as crested wheat grass is not used as a reclamation species and prescriptive, site specific construction planning is done” (Page 3.1, Section 3.1, Volume 3), given that there were often only two transects compared for many of the calculations.

Response: Negative values occur when the measured mean values for the treatment were more favorable from a native grassland integrity perspective than were the paired control values. Please refer for example to mean litter depth values for 1980-89 and the UF-3 habitat class. It was assumed that deeper litter was more favorable for native grassland integrity than shorter litter. The -1.33 value means that litter was 33% higher for measurements on the pipeline than on the adjacent control.

The analysis was not done at the transect level but at the plot level, therefore the minimum sample size for pair pipeline sampling was ten not two.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 214

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 215

Requesting Party: Federal Government

Reference: Volume 3. Appendix 3E

Preamble: The orthophotos used were from 2005 and were primarily from the NWA.

Request: GOC recommends that EnCana provide the justification and supporting information that the examination of past well development in the NWA accurately portrays the future predicted disturbance level of the 1275 wells being developed within 3 years.

Response: The orthophotos used for footprint inventory were the same (fall of 2005) for the entire study area (NWA, LSA and RSA).

Footprint inventory was used as a quantifiable means of measuring the magnitude of footprint associated with past shallow gas (and livestock grazing) development since the mid-1970s. This technique, while not 100% accurate, captures the majority of pipelines, trails, roads, well sites, dugouts and other evidence of past land use in the NWA. Because the in-fill shallow gas drilling activities are similar (taking into account evolving environmental mitigation and construction improvements such as spider-plowing) in nature to past activities the comparison of past to present footprint allows a quantification of the incremental footprint to the existing footprint. This comparison is a fundamental first step in cumulative effects assessment.

Footprint inventory was not the only data used to rate project impact magnitude and significance. Empirical studies that linked past/existing footprint to vegetation integrity and breeding songbird abundance were just as important.

Reference: Volume 3. Appendix E

Preamble:

Request: GOC recommends that EnCana provide the methodology and assumptions used in the evaluation of the disturbance footprint for wells within the NWA.

Response: The procedure for identifying well features via onscreen digitizing is described in Volume 3, Appendix 3, Table 3E-2. The visible boundaries (normally separating bare soil from vegetation) surrounding the lease were delineated for each well. The footprint of each digitized well was therefore known to within the same degree of accuracy as the other digitized features described in Appendix 3-E and the sum of all of these went into the existing disturbance footprint calculations. For the projected footprint scenarios wells were assumed to have a footprint of 30m2.

Reference: Volume 3. Appendix E. Section 3E pg 21 and 30

Preamble: Mean bare soil control sites for leases was 10.9 %; whereas mean bare soil for pipeline control sites was 40.8 %.

Request: GOC recommends that EnCana explain why the control bare ground means are so different.

Response: The mean percent cover of pipeline control sites was 16.1% (Table 3E-4, page 3E-30). We are not sure where the reference mentioned above (40.8%) comes from. Mean bare soil at control sites for leases was 11% (Table 3E-3, page 3E-30). We are also not sure where the reference to 10.9% comes from.

Reference: Volume 3, Appendix 3D, Table 3D-1, Page 3D-8

Preamble: EnCana indicates that non-native species including Bromus tectorum (downy brome) were observed in Table 3D-1.

Request: GOC recommends that EnCana describe the nature of these observations and how monitoring and control of such non-native invasive species has been carried out in the NWA, and advise on the success of the control efforts.

Response: The plant species listed in Table 3D-1 were those recorded on sampling plots and belt transects associated with paired pipeline sampling transects.

EnCana has not conducted any Downy Brome control in the NWA.

Reference: Volume 3, Section 3.1, Executive Summary, Pages 3-1 to 3-2.

Preamble: EnCana states that “the cumulative effect on native prairie grassland integrity is insignificant , in part because of empirical studies done in 2006” (3rd bullet, top of page 3-2).

Request: GOC recommends that EnCana undertake a cumulative effects assessment on native prairie grassland.

Response: The cumulative effects of the Project on the Valued Ecosystem Component – Native Prairie Grassland Integrity - was completed. The results and discussion are found in Volume 3, Section 7.5, pg. 7-14.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 221

Requesting Party: Federal Government

Reference: Volume 3, Section 3.6.2.2, pages 3-16 and 3-17 Sorensen Index as a measure of integrity

Preamble: EnCana states The Sorensen Index was used as a measure of the degree of similarity in species composition between sites on and off of pipelines.

Request: GOC requests EnCana: 1. Specify how the Index was calculated. Specify whether it included percent cover similarity or simply species presence. 2. Provide justification that supports the threshold of 75% similarity as a measure of recovery of integrity.

Response: AXYS Environmental Consulting Ltd. was contracted by EnCana to conduct a post construction vegetation assessment in the fall of 2004. The assessment was conducted in areas that had been infill drilled to 16 wps in 2001.

As stated in Section 3.1, page 7, of the AXYS report, the Sorenson Index was used as a measure of diversity between paired sites based on species composition as measured using the Daubenmire cover classes.

As stated in Section 3.1, page 8, of the AXYS report a Sorenson Index of >0.75 indicates a large percentage of the sites have a very similar species diversity.

Please refer to Section 2 Methods and Section 3 of the AXYS report for further information.

AXYS Environmental Consulting Ltd., 2005. Post-construction vegetation assessment of EnCana’s 16 wells per section pilot project and the Suffield 2001 shallow gas infill drilling program within the Riverbank and Middle Sandhill Zones of the National Wildlife Area. Prep. For EnCana Corporation. 60 pp.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 223

Requesting Party: Federal Government

Reference: Volume 3, Section 3.7.2.1, Native Prairie Grassland Integrity, page 3-22

Preamble: EnCana states with regard to native prairie integrity: “The mean value for bareground for all 16 wps samples was 10.4%, which is within the range of natural variability for the Dry Mixedgrass subregion (Adams et al. 2005).”

Request: GOC recommends that EnCana provide what proportion of the 16 wps samples fell within the range of natural variability for bare ground expressed in Adams et al. 2005 for the relevant Ecological Range Site.

Response: 85.7 % of mean bare ground values for 16 wps samples on sandy range sites fell within the natural range of variability for this range site type. The other 14.3% of samples registered a value below the natural range of variability.

53.3 % of mean bare ground values for 16 wps samples on loamy range sites fell within the natural range of variability for this range site type. 26.6 % of the samples registered a value above the natural range of variability, and the other 20.1 % of samples register a value below the natural range of variability for this range site type.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 225

Requesting Party: Federal Government

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

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

Request: GOC recommends that EnCana discuss the use of exotic invasive species such as crested wheatgrass in past reclamation.

Response: EnCana is not proposing to use Crested Wheatgrass for native prairie reclamation.

This species was previously utilized because it prevents bare ground and potentially other uses such as livestock forage.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 227

Requesting Party: Federal Government

Reference: Volume 3, Appendix 3C, Vegetation Triangle Sampling Program. Section 3C.2.1 Page 3C-3 to 3C-4

Preamble: One objective stated is to compare the magnitude of well density effects to effects of fire frequency, grazing intensity, and soil landform type on indicators of native range integrity. The design attempts to stratify (assign factor combinations) to evaluate this objective, but does not sufficiently replicate the design to allow a factorial analysis (i.e. only 130 sites sampled, but for a 2 well density X 9 soil type X 3 fire interval X 4 grazing intensity design there are not enough degrees of freedom to test for interactions and the unbalanced replication (N varies from 3 to 12 depending upon the combination) negates any opportunity for a variance components analysis.

Request: The GOC recommends that EnCana provide justification how the study design was sufficiently replicated to allow a factorial analysis.

Response: Factorial analysis was not used nor planned for. The primary purpose of the triangle sampling program was to assess the influence of well density on various attributes of native integrity. This was done by selecting replicate quarter sections at two different well densities while controlling other potentially influential variables (i.e. cattle grazing levels, fire frequency and habitat). Comparison of well density effects to those of other factors was not a primary focus of the program but was indicated by more descriptive statistics.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 229

Requesting Party: Federal Government

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

Preamble: EnCana states in the methods of Vegetation Triangle Sampling, with regard to fire, that “From these yearly records the total fires over the data period was calculated for each polygon. The fire period (23 years) divided by the total number of fires for each polygon equals the return frequency….Fire frequency classes were classified as high, moderate or low as presented in Table 3C-1. Values generated by this technique are not decimals.

EnCana also states “For the purposes of rating habitat suitability for wildlife VECs (Section 5.8) in the RSA, fire frequency and livestock grazing modifiers were attached to potential vegetation cover types to form habitat units…”. The modifiers provided are discontinuous and the range of values in classes varies (1.8, 2.9, 12.6)

Request: GOC recommends that EnCana: 1. Provide a justification or reference for using fire frequency alone to classify fire categories. 2. Provide a description for how fire return categories were determined. 3. Justify the break points used for fire return categories. 4. Provide a map of the fire interval designations.

Response: 1. Fire return interval (fire frequency) is a standard measure used to assess fire effects on vegetation. Data regarding fire intensity was not readily available for this EIS. 2. Categories were determined using the Natural Breaks (Jenks) method to split values into a three category, low, medium, and high system based on there fire return interval. The Natural Breaks (Jenks) method was chosen to best group similar values and maximize the differences between classes. 3. The Natural Breaks (Jenks) method was appropriate for classification of fire frequency. With a mean fire return interval of 5.7 and a standard deviation of 4.5 had an equal interval approach been used almost all the data within 1 standard deviation either way of the mean would have been placed in the low return interval class (which would have been from 1.8-9.2). This classification method would obviously not capture the variance in the data with the majority of values within a standard deviation of either side of the mean being placed in the same category. A standard deviation based classification could have also been chosen but it would have created 4 classes rather than the desired low, medium, and high classes. Had it been used the breaks would have looked like Table 1 below. The standard deviation based method provides similar values to the Jenks classification as both are designed to maximize the differences between classes.

Table 1: Alternate Classification Based on the Standard Deviation Method. Range (category) Std Deviation Range 1.77-3.5 < -0.50 Std. Dev. 3.51-7.97 -0.50 - 0.50 Std. Dev. 7.98-12.44 0.50 - 1.5 Std. Dev. 12.45-24.00 > 1.5 Std. Dev.

4. Please see figure below.

Reference: Volume 3, Appendix 3C, Section 3C.2.2, Vegetation Triangle Sampling, Pages 3C-5

Preamble:

Request: To substantiate the assertion (page 3-2), the GOC recommends that EnCana provide a justification of the selected sampling design and specifically provide detailed rationale why this sampling arrangement was chosen.

Response: EnCana is not clear what assertion on page 3-2 that GOC is referring to. Nonetheless, the vegetation triangle sampling design was chosen as a practical means of collecting baseline inventory data on vegetation parameters at the quarter-section (landscape) level of detail. It was designed to be used in conjunction with site-specific information from the paired pipeline vegetation sampling and the study-area-wide information gained from disturbance footprint digitizing.

Reference: Volume 3, Appendix 3C, Section 3C.2.3, Vegetation Triangle Sampling, Page 3C-7

Preamble: The native integrity measure of Native/Introduced Plant Species Ratio does not reflect how the presence of a single persistent invasive perennial exotic species can be a worse situation than a recently disturbed site with 20 exotic annual species that will not persist. This also doesn’t account for industrially disturbed bare ground, or naturally occurring bare ground on eroded slopes and sand dunes.

Request: GOC recommends that EnCana remove the N/I ratio as an indicator of native integrity.

Response: Native/introduced plant species ratio was one of 10 measures of native prairie grassland integrity. This measurement is at the landscape level and the intent was to compare this measure between different well densities, fire frequencies, cattle grazing levels and habitat types. This is a useful and objective comparison between alternative conditions. The paired pipeline sampling program directly investigates the issues associated with single persistent invasive species such as crested wheatgrass. EnCana respectfully does not agree with removing this measure for the reasons outlined by GOC above.

Reference: Volume 3, Appendix 3C, Effects of NWA, Section 3C.4.6 page 3C-25 Volume 3, Section 1.2.1, page 1-2

Preamble: EnCana states: “The purpose of this analysis was to compare native integrity measures inside and outside of the National Wildlife Area. As such, all quarter sections sampled outside the NWA formed one set of samples (excluding Koomati area) and all plots located inside the NWA the other. Results are presented in Table 3C–15.”

Elsewhere (page 1-2) EnCana states “The eastern boundary of the Local Study Area is the South Saskatchewan River with the exception of the addition of the Koomati area south of the River. This block of land was added because of its unique position between the northern and southern portions of the NWA.”

Request: GOC recommends that EnCana: 1. Justify the exclusion of Koomati, which is a portion of the LSA and RSA outside the National Wildlife Area, given EnCana’s assertion that Koomati with similar activities and soils and 16 wps is an opportunity to conduct comparisons to the National Wildlife Area. 2. Include Koomati in the absence of justification sufficient to override the assertion as to the suitability of Koomati for such purposes.

Response: 1. Sampling in Koomati was excluded because of the lack of fire frequency data in the area precluded stratification in comparison to other areas. 2. Sufficient samples from the NWA (D6/D8 area) were available to provide the information necessary to determine effects of shallow gas in-fill drilling on native vegetation integrity utilizing the stratification methodology developed for this assessment.

Reference: Appendix 3D, Section 3D-2, page 3D-3 to 3D5, Figure 3D -1, 3D-2 Paired Pipeline.

Preamble: This is the methods section describing the collection and analysis of paired pipeline data for assessing the Vegetation VEC.

Request: To substantiate its conclusions from the paired pipeline study, the GOC recommends that EnCana 1. Provide the plot number of each sampling point displayed and provide a table or tables, that provides information on the sampling effort and distribution of plots with reference to Topographic Habitat Unit, Fire and Grazing Categories and Age Class. 2. Describe and justify how the degree of disturbance in the area influenced where the distance controls were placed from the pipeline/lease. 3. Clarify the description for measurement of pipeline width and lease area. 4. Provide a description of the direction from well lease and pipeline where the control was placed. 5. Describe if pipelines with access trails on top of pipeline or adjacent to pipeline were included in the samples. 6. Describe if trunk lines and loop lines were included.

Response: 1. Sampling effort for paired pipeline program:

THU Fire Grazing Date Number of paired Number of paired frequency intensity plots (0.5 x 2 m) plots (2 x 50 m) UF-3 low moderate 73-79 10 10 UF-3 low moderate 80-89 10 10 UF-3 low moderate 90-99 20 20 UF-3 low moderate 00-05 20 20 SD-1 low n/a 73-79 20 20 SD-1 low n/a 80-89 20 20 SD-1 low n/a 00-05 38 38 SD-2 low moderate 73-79 10 10 SD-2 low moderate 80-89 10 10 SD-2 low moderate 90-99 15 15 SD-2 low moderate 00-05 20 20

2. The effect of construction and reclamation of pipelines was readily observable visually as weedy species stood out on the landscape based on structural and height differences. 10 meters was a sufficient distance to isolate control areas from experimental areas.

3. Pipeline width was estimated at the starting point of each sampling plot by walking the EnCana Shallow Gas Infill Development in IR Due Date: the CFB Suffield National Wildlife Area CEAA File #05-07-15620 August 2nd, 2007 IR Requested By: IR No. Page Federal Government CEAA-EIS-012 2 #Terr – 234-B

areas and defining the edges. Edges were visually detected by noticing changes in bare soil cover and/or vegetation composition. The lease area was estimated by walking the area and defining the edges as described above before taking measurements.

4. All control transects were placed 10 m outside of the visible construction effect. Their position in relation to the pipeline was selected in a manner that maintained as similar conditions as possible to the pipeline; which includes landform element, slope and aspect.

5. Yes both pipelines with access trails on top of pipeline or adjacent to pipeline were included. Notes were recorded at each sampling site. Most pipelines had an access trail adjacent to them.

6. Trunk lines and loop lines were also included. The trunk lines mainly represented the 1970-1979 age period.

Reference: Volume 3, Appendix 3D, Section 3D.3, Paired Pipeline Sampling, Pages 3D-5

Preamble: It appears there was unbalanced replication in this analysis, varying from n = 2 to 8, with relatively more replication of more recently constructed pipelines, and frequently only 2 replicates of the oldest pipelines. Unbalanced replication can be handled by pooling variance, but the relative lack of replication for older pipelines presents a serious risk of Type 2 errors (basically concluding no effect when one actually exists).

Request: To substantiate its conclusions related to the Paired Pipeline Sampling throughout Volume 3 and its Appendices, the GOC recommends that EnCana complete a power analysis, calculate minimum sample size, present minimum sample size to detect a change of 1% in all results tables, and include discussion of minimum sample size when discussing results and drawing conclusions.

Response: The sample unit used for the statistical analysis was the plot, hence the minimum sample size per age class was 10 paired plots. That size is sufficient to perform the non-parametric test used. Comparisons were done between well/pipeline and the corresponding control not between different age classes; therefore the same number of replicates was used for comparison.

The two age classes, with 10 paired plots for comparisons between well-pipeline and control were, 1973-1979 and 1980-1989 for THU UF-3 and SD-2. As presented in the results in Volume 3, Appendix 3D, the oldest age class (1973-1979) for both THUs (UF-3 and SD-2) show statistically significant differences between well-pipeline and control sites for six and seven attributes of the eight attributes analyzed, respectively. These results show that type 2 error was not the case since for most of the attributes the conclusion was that an effect actually exists and suggest that the sample size was big enough to detect differences between the well- pipeline and the control (adjacent native prairie).

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 237

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 237

Requesting Party: Federal Government

Reference: Volume 6, Section 2.5.1, page 2-10

Preamble: The terms of reference require EnCana to describe the potential effects of any increased road dust levels on potentially-affected communities, wildlife and vegetation. EnCana states in the concordance table in Volume 1 that the issue is addressed in Volume 6, Section 2.8, however, the only statement by EnCana with regard to road dust and human health was found in Section 2.5.1, and it states “Particulate matter resulting from the re-entrainment of road dust from vehicles on roads was not considered as the construction and operations work will be carried out directly on the Prairie grass and no new roads are to be constructed.”

Request: The GOC requests EnCana address the topic of increased road dust with respect to Vegetation and Wildlife.

Response: We could not locate published literature specifically pertaining to the effects of dust from informal, irregularly used trails on grassland vegetation or wildlife. The majority of literature on the subject of dust effects on vegetation is related to permanent [gravel] roads, fire frequency, drought, cultivation and intensive grazing. Because of the minimal footprint associated with informal trails and the fact that no permanent roads would be constructed for the project we did not address this effect in the EIS. It was assumed that there would be no significant increase in road dust in the future from new roads for the construction and operation of the Project. In addition, EnCana will minimize road dust as outlined, for example, in Section 1.5.2 Traffic Control of the EPP described in Volume 1, Appendix I.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 239

Requesting Party: Federal Government

Reference: Volume 3, Section 3J.1.2, Page 3J-4

Preamble: EnCana should be made aware that the Tiny cryptanthe and small-flowered sand verbena are declared endangered and threatened, respectively, buy the Province of Alberta.

Request:

Response: EnCana is aware that the above plants are listed by the Alberta and the Federal Government under SARA.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 241

Requesting Party: Federal Government

Reference: Volume 3, Section 5.1, Page 5-1

Preamble: EnCana suggests that the Canadian Wildlife Service (CWS) inventory conducted in 1994/95 is suitable for baseline purposes.

Request: GOC recommends that EnCana justify this statement, and provide rationale as to why 1975 is not a more suitable baseline for comparing effects on wildlife.

Response: The primary intent of the EIS is to assess the significance of in-fill drilling impacts on valued ecosystem components in the NWA. The 1994/95 CWS inventory is the highest quality and quantitative baseline against which changes in the landscape resulting from past shallow gas operations could be compared. This information was used as a source of comparison for some VECs (e.g. breeding birds), but not all. Other VECs used a wide variety of assessment methods as outlined in Volume 2, Section 3.

Reference: Volume 3, Section 5.1, Page 5-3, Volume 3, Section 5.7.1.1, Page 5-23

Preamble: EnCana states that “Habitat supply was quantified for all VECs in the NWA…For each VEC, CWS vegetation cover types and habitat units were rated as high, moderate or low”. EnCana further states “With reference to literature, first-hand knowledge of each habitat gained during field surveys, and the authors’ knowledge of wildlife-habitat relationships in the RSA, suitability of CWS vegetation cover types (Section 5.5.3) and habitat units (Section 5.6.3) were rated for each VEC”.

Request: GOC recommends that EnCana: 1. specify the accuracy and validity of the vegetation cover types used as predictors of habitat suitability and supply, given that they are over 10 years old; 2. state the assumptions required to rank habitat suitability; 3. provide the specific habitat requirements by species and discuss how habitat requirements specifically relate to vegetation cover types and habitat units in identifying habitat for each species; 4. explain how suitability was considered and assessed for each species, such that the results presented can be re-produced; 5. explain how the habitat suitability predictions were tested for accuracy; and 6. explain how the suitability and supply models considered and assessed site- specific critical and important habitat requirements of the VECs, including breeding locations, leks, dens, and burrows.

Response: 1. Vegetation cover type mapping in the NWA conducted in the mid-1990s is still valid for assessment at this time. Very little fire activity has occurred in the NWA since that time. Grazing levels have remained similar. The degree of differentiation between mapped habitat types is based largely on major vegetation physiognomic (structural) and moisture gradients. These gradients still exist today and were used to subjectively rate habitat suitability.

2. The methodology used to rank habitat suitability is provided in Section 5.7.1.1 of the EIS.

3. Section 5.7.2 of the EIS provides habitat preferences and status and abundance of wildlife VECs within the NWA and RSA. This information combined with knowledge of wildlife-habitat relationships in the RSA and knowledge of habitat gained during field surveys was used to rate vegetation cover types and habitat units for each VEC.

4. Habitat ratings were incorporated into a GIS as presented in Appendix 5F and EnCana Shallow Gas Infill Development in IR Due Date: the CFB Suffield National Wildlife Area CEAA File #05-07-15620 August 2nd, 2007 IR Requested By: IR No. Page Federal Government CEAA-EIS-012 2 #Terr - 243 - B

attached to vegetation cover types and habitat unit layers. Habitat was then quantified by overlaying the rated vegetation cover types and habitat units on disturbance mapping for both baseline and project conditions for the NWA, LSA and RSA. Moderate and high habitat supply is presented in Appendix 5G.

5. The habitat suitability predictions were reviewed for reasonableness in the context of the landscape scale distribution of each VEC.

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

Reference: Volume 3, Section 5.1, Page 5-3

Preamble: EnCana states that “Fragmentation was not assessed for project effects as the anticipated surface disturbance for all pipelines will be less than 4 m, widths insufficient to cause a habitat fragmentation effect. Little potential exists for impairment of wildlife movement due to the Project as no new roads or other potential barriers will be constructed…The magnitude of potential project effects on each wildlife VEC was determined on the basis of greatest effect within any of the five conservation biology areas. For most species, the magnitude was dictated by habitat loss and alteration.”

Request: GOC recommends that EnCana: 1. provide rationale and assumptions underlying the statement that surface disturbance is insufficient to cause habitat fragmentation effects; 2. provide rationale and assumptions underlying the statement that little potential exists for impairment of wildlife movement due to the Project; 3. specify how vehicles traversing access trails do not pose barriers to wildlife movement; and 4. provide rationale and assumptions underlying the statement that the magnitude of Project-related effects was dictated by habitat loss and alteration.

Response: 1. & 2. We are not aware of literature or field evidence that linear disturbances of the magnitude and type contemplated for the project (pipeline widths of <2-m and <4-m, access trails) will result in fragmentation effects or the impairment of wildlife for wildlife VECs.

3. Vehicles traversing access trails do not pose a barrier to wildlife movement when the activity is ephemeral and most vehicular activity (including all construction activity) will occur during the period 1 October to 15 April when many if not most VECs will be inactive or not present.

4. For most species the magnitude was dictated by habitat loss when the magnitude was minor (0 to 1 percent) and other potential effects were considered to be negligible.

Please note that in section 5.6.2 the definition of habitat loss magnitude is incorrect. The definition should be “…0 percent change – negligible; 0 to 1 percent – low; 1 to 10 percent - moderate: and greater than 10 percent – high.”

Reference: Volume 3, Section 5.1, Page 5-3, Volume 3, Section 5.6.1, Page 5-9

Preamble: EnCana suggests that mitigation measures are well known and established, as they relate to the Project. However, EnCana also states that “Few scientific studies have empirically assessed the effects of infill drilling and well density on wildlife species and assemblages in this particular ecological setting (i.e., Dry Mixedgrass prairie)….Fortunately, infill drilling had taken place within the NWA and immediate environs in the recent past (since 1973). This provided an opportunity to empirically investigate, to some extent, the magnitude of infill drilling effects during field investigations.”

Request: GOC recommends that EnCana document studies carried out to assess the success of mitigation measures in similar projects, and the results of such studies. GOC recommends that EnCana document the assumptions and limitations of the field investigations, and compare and contrast the predictive power of observational and experimental field studies.

Response: There are 1145 wells within the NWA that were drilled between 1975 and 2005. EnCana has been continuously updated and improved its practices to minimize effects on the native prairie. In fact, EnCana has worked closely with CWS and the Base to create the NWA.

The mitigation measures are well known and established. However, EnCana knows of no studies conducted on infill drilling or any studies that assess the success of mitigation measures in similar projects in Dry Mixed grass prairie.

A comprehensive literature search was conducted for each wildlife VEC. Key findings with respect to VEC susceptibility to potential impacts of the project and proposed mitigation have been provided in Section 5.8.3. Assumptions and limitations of field investigations are discussed within Section 5.6.5 and associated appendices.

For comments regarding predictive power of experimental and observational studies please refer to the response to Terrestrial 196.

Reference: Volume 3, Section 5.6.5.2, Page 5-14

Preamble: EnCana states that “The Dillon Consulting Ltd. (1998, 2006) PC dataset is in the highly (relative to the NWA) disturbed MTA. In spite of the high percentage of digitized disturbance in many of the 100-m survey radii, statistically significant decreases in bird density were not found with one exception. Sprague’s Pipit showed a statistically significant decrease in density in ecological range site “Lo” based on digitized disturbance of 30.9 percent which is a very high level of disturbance.”

Request: GOC recommends that EnCana: 1. specify the relevance of the findings in assessing Project-related effects; 2. specify how disturbance was identified and mapped in the Military Training Area (MTA), and discuss the comparability of the mapping product to the products created for the EIS; and 3. compare and contrast land-use effects between military training and oil and gas development, as they relate to wildlife VECs, considering fragmentation, habitat loss, reversibility, frequency, and magnitude of effects.

Response:

1. The Dillon Consulting Ltd. (1998, 2006) PC dataset provided information on the response of birds to higher levels of disturbance than was possible using data from in and adjacent to the NWA notwithstanding the disturbance was a composite of oil and gas and military activity.

2. Footprint identification and mapping conducted in the MTA portion of the LSA was identical to that done in the NWA. The approach to conducting footprint mapping is outlined in Appendix 3E.

3. EnCana has assessed cumulative effects by examining the interactions between all of the land uses in the LSA and RSA and the VEC. It was not relevant to consider the similarities and differences in environmental effects of the military and oil and gas activities in determining whether there would be a cumulative effect and the significance of the cumulative effects.

Reference: Volume 3, Section 5.6.5.2, Page 5-17, Volume 3, Section 5.6.5.2, Page 5-19

Preamble: EnCana states “The data collected in the 2006 field season are limited and may not represent the true distributions and abundances of anuran species within the NWA.” However, EnCana also states that “it would be difficult to argue that any land use has resulted in amphibian population declines within the NWA.”

Request: GOC recommends that EnCana explain the apparent contradiction between the two statements, and further explain the conclusion that it would be difficult to argue that any land use has resulted in amphibian population declines, in respect of the precautionary principle.

Response: There is no contradiction between these two statements. The data yielded by the sampling methods followed, and the acceptance levels used for statistical tests, did not result in many certainties concerning anuran distributions and abundances, and thus EnCana was conservative in assigning any biological significances to observed differences between sampling periods except at a low α. This did not attribute any apparent declines to land use patterns within the NWA over the past fifteen years. Land use patterns and intensities may have affected anuran abundances and distributions within the study area over the past two decades, but the data available to EnCana do not allow attribution of the patterns to this cause.

Reference: Volume 3, Section 5.6.5.2, Page 5-19

Preamble: EnCana states that ”The greatest numbers of large choruses of both boreal chorus frogs and great plains toads are to be found within the areas of the NWA which have been, and continue to be, subject to the greatest human disturbance.”

Request: GOC recommends that EnCana specify how it has assessed human disturbance, including criteria and rationale. GOC recommends that EnCana specify how it has assessed human disturbance in relation to boreal chorus frog and great plains toad habitat across the NWA, including considerations of breeding habitat, and how anuran habitat is distributed across human disturbance categories (i.e., how much anuran habitat falls within high, medium, and low human disturbance categories).

Response: EnCana did not classify boreal chorus frog (BCFG) and Great Plains toad (GPTD) breeding chorus distributions in terms of a formal scheme of human disturbance categories. Breeding habitat was assessed on the basis of the intensity of breeding activity during the 2006 sampling period, and from the CWS data. The preamble cited was based upon subjective assessments of the disturbances observed in different blocks of the NWA during the 2006 field season. Within the NWA the Falcon, Casa Berardi, and southern Fish Creek blocks had the highest concentration of roads and wells, as compared to Ypres and Mons. The BCFG & GPTD displayed the highest concentrations of large choruses for both species of the areas surveyed in 2006.

Reference: Volume 3, Section 5.6.5.5, Page 5-20

Preamble: EnCana states that “The primary target species of the ungulate aerial survey was pronghorn antelope (Antilocapra americana). Secondary survey targets include mule deer (Odocoileus hemionus), white-tailed deer (Odocoileus virginianus) and elk (Cervus elaphus). The purpose of the ungulate survey was three-fold. First the data were used to perform a summer habitat resource selection function (RSF) for pronghorn antelope to assess pronghorn antelope landscape use in the study areas.”

Request: GOC recommends that EnCana discuss the applicability of the survey data to Winter conditions for ungulates in the NWA. GOC recommends that EnCana specify how critical winter ungulate range identified by Alberta Sustainable Resource Development, Fish & Wildlife, will be protected.

Response: The summer survey data is not applicable for modeling winter conditions for ungulates in the NWA. Seasonal use of range by pronghorn varies markedly between seasons. Work by Barrett and Vriend in 1980 identified areas in the south-eastern portion of the base as pronghorn winter habitat extending over portions of the Mons, Ypres, Ortona, Casa Berardi, Falcon, and Hawk training areas (Barrett and Vriend 1980). Summer distribution is ubiquitous across the base.

EnCana will protect critical winter ungulate range by utilizing minimal disturbance techniques including mitigation measures discussed in section 5.8.2 of Volume 3. The predicted disturbance footprint associated with the Project combined with the existing footprint in the NWA is cumulatively less than 5% for all but two cover types and the average cumulative footprint is predicted to be 2.4%. Based on these projections, the Project is anticipated to have a low effect on critical winter ungulate range.

Barrett, M. W. and H. Vriend (1980). Management implications of the seasonal distribution of pronghorns and land use practices in Alberta. Proc. Bienn. Pronghorn Antelope Workshop.

Reference: Volume 3, Section 5.8.1, Page 5-42

Preamble: EnCana states that “Fragmentation was quantified for baseline conditions using the habitat suitability mapping and evaluation…Minor pipelines (individual well tie-in line, loop lines) and access trails were not considered to contribute to fragmentation.”

Request: GOC recommends that EnCana specify the assumptions and rationale to support this conclusion. GOC recommends that EnCana specify the effects of fragmentation, including effects on home range, reproductive ability, predation, and habitat loss by invasive non-native species, and how these factors may impact each wildlife VEC.

Response: EnCana is not aware of literature or field evidence that linear disturbances of the magnitude and type contemplated for the project (pipeline widths of <2-m and <4-m, access trails) will result in fragmentation effects for wildlife VECs. As EnCana is not aware of a rationale to consider the effects of fragmentation, the analysis recommended by the GOC is not necessary.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 251

Requesting Party: Federal Government

Reference: Volume 3, Section 5.8.1, Page 5-45

Preamble: EnCana states that “Little potential exists for impairment of wildlife movement due to the Project as no new roads or other potential barriers will be constructed…Disturbance from pipelining will be less than 2 m for well tie-ins and less than 4 m for loop lines; widths insufficient to be barriers to movement.”

Request: GOC recommends that EnCana specify how wildlife movement impairment was considered for access trails. GOC recommends that EnCana provide rationale and scientific evidence to support the statement that pipeline widths are insufficient to be barriers to wildlife movement.

Response: The proponent is not aware of literature or field evidence that linear disturbances of the magnitude and type contemplated for the project (pipeline widths of <2-m and <4-m, access trails) will result in impairment of wildlife VEC movement.

Small mammals, (mice, voles, shrews) because of their small size and terrestrial locomotion, would be the wildlife group with the greatest chance of movement being affected by pipelines and access trails. The small mammal trapping program completed in 2006 in the NWA (Volume 3, Appendix 5P) observed that small mammal diversity and abundance was equal for traps set on and off of pipelines. Access trails ran adjacent to most if not all of these sites. As such, it is unlikely that the movement of small mammals (or any larger mammals) are affected by pipelines or access trails.

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

Preamble: EnCana states that “Between 15 April and 15 October within the high risk snake area (east of Bingville and Fox roads), the following measures will be taken:…grading of roads to be undertaken only with an environmental inspector accompanying; vehicles working E of Bingville or Fox Rd will use E-W access as much as possible”.

Request: GOC recommends that EnCana identify the extent and frequency of road maintenance proposed for the NWA. GOC recommends that EnCana provide the criteria and thresholds to be used in identifying the possibility of using East-West access roads/trails.

Response: With the exception of Sapper Road, the military do all road maintenance in the NWA. Sapper Road maintenance is coordinated through Suffield Industry Range Control (SIRC). Maintenance on Sapper Road is done 2 times per year, once between spring break-up and 15 April and once between 15 October and fall freeze-up. If, for exceptional reasons, road maintenance is required on Sapper Road between 15 April and 15 October, grading of this road will be undertaken only with an environmental inspector accompanying.

Because snakes on CFB Suffield generally migrate from East to West in the spring and West to East in the fall, use of East-West access roads/trails to the greatest extent possible will reduce the number of snakes encountered crossing roads.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 254a

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 254b

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 255

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 256

Requesting Party: Federal Government

Reference: Volume 3, Section 5.8.2, Page 5-106, Volume 3, Appendix 5D, Pages 5D-5-5D-16

Preamble: EnCana states that “Resource Selection Function analysis of aerial survey data (August 1 to 3, 2006)…indicated that pronghorn antelope reacted minimally to anthropogenic features in the Suffield area. Natural landscape variables such as ecological range site, greenness and terrain ruggedness exerted a much greater effect on antelope use of landscape than well density.” However, EnCana suggests that the number of wells per quarter section is ranked second to ecological range site in describing antelope presence/absence. EnCana also states that “the results of the analysis and net loss of habitat from well pads, pipelines, roads and the introduction of exotic species by human traffic could be factors affecting pronghorn use of this landscape…Studies by Joel Berger and the Wildlife Conservation Society in the Upper Green River Basin, Wyoming are exploring the relationship between habitat fragmentation by oil and gas development and pronghorn occurrence (Berger et al., 2006). Their preliminary results suggest fragmentation of previously undisturbed lands are resulting in reduced foraging and abandonment by pronghorn…in light of work by Berger et al. (2006), the effect of habitat fragmentation by oil and gas infrastructure and other anthropogenic features should be assessed to determine impacts and possible mitigation measures. Pronghorn net winter habitat and food loss resulting from the cumulative effect of human disturbance should be analysed when assessing impacts of development on pronghorn since winter survival is particularly dependant on forage availability and movement corridors…At the time of this study, all roads and trails to wellheads were not digitally mapped for Suffield…Roads and trails contribute directly and indirectly to habitat loss through habitat fragmentation, traffic, and introduction of exotic species…These features should be mapped and a road density index (length/km2) could be created and analyzed to quantify the potential effect on pronghorn in Suffield.”

Request: GOC recommends that EnCana: 1. explain the conclusion that natural landscape variables exerted a much greater effect on antelope presence than well density (number of wells/quarter section), which appears to contradict the Resource Selection Function analysis; 2. specify how well density as a predictor of antelope presence/absence (derived from the Resource Selection Function analysis) was used in determining Project effects-related magnitude, reversibility, duration, significance, and level of confidence; and 3. specify how the conclusions and recommendations from the Pronghorn Resource Selection Function Study were included in the assessment of Project-related effects including mitigation, magnitude, reversibility, duration, significance, and level of confidence.

Response: 1. Comparison of the Wald statistic for ecological range site and well density provides a relative comparison of each of the coefficients (variables) in the model. The Wald statistic is used to test the significance of individual logistic regression coefficients (Menard 1995). The greater the Wald statistic the greater the significance of the EnCana Shallow Gas Infill Development in IR Due Date: the CFB Suffield National Wildlife Area CEAA File #05-07-15620 August 2nd, 2007 IR Requested By: IR No. Page Federal Government CEAA-EIS-012 2 #Terr - 257 - A

independent variable in the model. In the RSF model, ecological range site (Wald: 52.42) exhibits significance three times greater than well density (Wald: 15.66). As such, it was concluded that ecological range type exerted a much greater effect on antelope presence than well density. Ecological range type represents an integrated unit of landscape factors including moisture, soils, and terrain.

2. The RSF and well density was just one source of information used to assess the effects of shallow gas in-fill drilling on antelope. Others included long-term population trends and persistence in CFB Suffield, road survey results, and scientific/technical literature..

3. See #2 above.

Menard, S. (1995). Applied Logistic Regression Analysis, Sage Publications.

Reference: Volume 3, Section 5. Wildlife and Habitat

Preamble: Ungulate surveys were conducted only during the summer months.

Request: GOC recommends that EnCana discuss the regional distribution, wintering and movement patterns of antelope and other ungulates and provide rationalization on the use of location data used to assess habitat use by antelope.

Response: Pronghorn are found throughout the Grassland Natural Region of Alberta. Seasonal density of pronghorn in an area is directly related to the amount and availability of good forage (O’Gara and Yoakum 2004). CFB Suffield, characterized by large tracts of native grassland relative to surrounding agricultural areas, provides good seasonal forage. The 2006 Provincial antelope census counted 2,144 pronghorn on Suffield (of the 15,528 pronghorn estimated in Alberta).

Ubiquitous throughout CFB Suffield in the summer, pronghorn concentrate in certain areas of the base in winter. Work by Barrett and Vriend in 1980 identified areas in the south-eastern portion of the base as pronghorn winter habitat extending over portions of the Mons, Ypres, Ortona, Casa Berardi, Falcon, and Hawk training areas (Barrett and Vriend 1980).

Location data used to assess habitat use by pronghorn was obtained using an aerial survey in accord with current statistical design and analysis techniques established by Manly (Manly, McDonald et al. 2002). The summer season was selected for analysis to increase the confidence in the data set relating to measuring the relative influence of natural and human- induced factors on pronghorn distribution. Pronghorn are most easily surveyed from the air in summer when sightability is greater and when the pronghorn have not formed large groups that may impair accuracy of the survey.

Barrett, M.W. and H. Vriend (1980). Management implications of the seasonal distribution of pronghorns and land use practices in Alberta. Proc. Bienn. Pronghorn Antelope Workshop.

Jones, P.F., M. Grue, et al. (2007). Resource selection by pronghorn antelope in the Grassland Natural Region of Alberta; Progress Report #3. A.C. Association: 33.

Manly, B.F., L.L. McDonald, et al. (2002). Resource selection by animals: statistical design and analysis for field studies. Boston, Kluwer Academic Publishers.

O’Gara, B. and J. Yoakum (2004). Pronghorn ecology and management, The University Press of Colorado.

Reference: Volume 3 Section 5.1 Wildlife and Habitat. Page 5-3.

Preamble: The proponent states that “as there are no major facilities associated with the Project and no major facilities located within the NWA sensory disturbance and effective habitat loss was not quantified in the NWA”.

Request: GOC recommends that EnCana discuss this assertion by providing field data and provide citations showing that sensory disturbance and effective habitat loss are not associated with minor facilities or roads, trails, pipelines and other infrastructure.

Response: Sensory disturbance effects are most deleterious to wildlife during breeding and fledging season (Bromley 1985). Construction will take place in the fall and winter outside of breeding season. Operations will consist of very irregular and infrequent trips of single vehicles. The latter is unlikely to result in sensory disturbance and effective habitat loss, even during the breeding season.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 260

Requesting Party: Federal Government

Reference: Volume 3 Section 5.1 Wildlife and Habitat. Page 5-3.

Preamble: The proponent references ‘major facilities’ in various sections of Volume 3 and suggests that ‘major facilities’ will not be constructed.

Request: GOC recommends that EnCana describe ‘major facilities’.

Response: For the purposes of this project ‘major facilities’ refers to non-exempt facilities requiring a licence as per AEUB Directive 056 (Table 5.1, September 2005 version) as well as dehydrators, line heaters and group separators.

Reference: Volume 3, Section 5.6.2, Evaluating Effects Significance , Page 5-9 Volume 3, Section 5.8, Environmental Effects on VECs, Tables 5-6 to 5-53 Volume 3, Section 5.9, page 5-125

Preamble: EnCana states: “For habitat loss the following guideline was adopted to assign effect magnitude: less than 1 percent change – negligible; 1 to 10 percent – low; 10 to 20 percent – moderate; and greater than 20 percent – high. Where quantification was not available (direct mortality, sensory disturbance, barriers to movement) the rating was based on the assessors’ experience and expertise, applicability of field surveys and scientific literature.”

Tables citing % loss occurs in Appendix 5G but it is not referenced in Section 5 or its Appendices and the method by which habitat loss was calculated is not provided in Section 5 or any of its appendices. Methods to calculate footprint for Vegetation are partially described in Section 3 and Appendix 3L but are not referred to in Section 5 or its Appendices.

Cumulative effects are rated as insignificant for wildlife VECS ) section 5.9, page 5-125) and a reason cited is that the project will have a small disturbance footprint. In order to assess estimates of project footprint, project effects by VEC and assignment of magnitude for residual and later cumulative effects, a number of elements in the Guideline require further explanation, including clarification between criteria, methods and criteria used to determine effects, both direct and indirect.

Request: GOC recommends that EnCana: 1. Provide justification for why qualitative criteria (i.e. negligible) were used in Section 5.6.2 and describe habitat loss categories. 2. Provide a detailed description of how loss by VEC was calculated.

Response: 1. EnCana has chosen a qualitative approach in determining significance ratings as this approach allowed an analysis of the five different areas of conservation biology. The five areas considered are: • Direct habitat loss and alteration • Sensory disturbance and effective habitat • Habitat fragmentation • Direct mortality • Barriers to movement

Where it was effective to evaluate on the basis of quantitative metrics, EnCana has utilized that methodology. For example, habitat loss was evaluated on the basis of predicted disturbance footprint in terms of the loss of high suitability habitat. 2. The habitat loss ratings in S. 5.6.2 are a misprint. The ratings utilized for the EnCana Shallow Gas Infill Development in IR Due Date: the CFB Suffield National Wildlife Area CEAA File #05-07-15620 August 2nd, 2007 IR Requested By: IR No. Page Federal Government CEAA-EIS-012 2 #Terr - 262 - A

assessment of wildlife are: • 0% change – negligible • 0 to 1% change – low • 1 to 10% change – moderate • > 10% change - high

Reference: Volume 3, Section 5.6.3, Habitat Mapping, Page 5-9 to 5-10 Volume 3, Section 5.7.1.1, Habitat Suitability and Supply, Page 5-23 Volume 3, Section 5.6.5.1, Sampling Stratification Methodology, page 5-12

Preamble: EnCana states (section 5.6.3): “Three habitat mapping products were used to stratify and analyze field data – CWS vegetation cover types (Section 5.5.3); ecological range sites and potential vegetation cover (Section 5.5.4); and CWS ecosites (Section 5.5.6). For the purposes of rating habitat suitability for wildlife VECs (Section 5.8) in the RSA, fire frequency and livestock grazing modifiers were attached to potential vegetation cover types to form habitat units.” Section 5.7.1 again refers to sections 5.5.3. There are no sections 5.5.3, 5.5.5 or 5.5.6 in Volume 3 or in the Appendices to Volume 3.

In Section 5.6.5.1 EnCana uses Topographic Habitat Units (THU) and modifies them with fire and grazing as in 5.6.3. It is possible that THU and potential vegetation cover and habitat units are the same but it is not stated and the two have separate abbreviations in the glossary.

Request: GOC recommends that EnCana: 1. Clarify whether the THU and the Vegetation cover units are the same. 2. Provide a clarification on mapping products used to stratify effects sampling. 3. Provide maps of location for all 5 habitat / soil classification.

Response: 1. Topographic Habitat Units (THUs) are different from Potential Vegetation Cover units. The former were used for stratifying breeding bird and vegetation triangle surveys and the latter were used for the purpose of habitat suitability assessment. 2. THUs were groupings of soil landscape models into broader combinations of surficial material and topography. Detailed descriptions of THUs are found in Volume 3, Appendix 3C , page 3C-3 and 3C-4. 3. Please refer to the file ‘Terr 263.pdf’

[NTD: Attach PDF]

Reference: Volume 3, Section 5.6 4, Page 5-10

Preamble: EnCana provides definitions for common, uncommon, scarce and rare.

Request: GOC recommends that EnCana clarify what information was used to assess expected abundance of all endangered, threatened, and special concerns as per Schedule 1 of SARA.

Response: In developing this Project, EnCana has taken an expansive approach to considering potential impacts to ensure that the cumulative effects of full development are known, understood, and mitigated. Moreover, EnCana has the benefit of 30+ years of knowledge of and experience in the area, having drilled over 1100 wells in the NWA between 1975-2005 and having worked within and adjacent to the CFB Suffield and the NWA during that time. EnCana has continually updated and improved its practices over the years in order to minimize impacts on the native prairie. This knowledge and experience, acquired over 30 years, has assisted EnCana in conducting expected abundance.

In addition, secondary sources used to assess expected abundance include: • Alberta Environmental Protection’s general status of Alberta wild species (AEP 2006; AEP 2001); • ASRD Fish and Wildlife Division’s Report of Alberta’s Endangered Species Conservation Committee (FWD 2004, 2005); • Alberta Sustainable Resource Development’s General Status of Alberta Wild Species (ASRD 2006a,b); • Committee on the Status of Endangered Wildlife in Canada’s Canadian species at risk (COSEWIC 2006); • Species at Risk Act, 2006.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 265

Requesting Party: Federal Government

Reference: Volume 3, Section 7.5.6 Analysis of Cumulative Effects. Table 7.2. Page 7-18

Preamble: In the section “Existing footprint by CWS Vegetation Cover Type” it is explained that in the southern portion of the NWA there is a current footprint of 12.80% in unclassified wetlands and a further 8.13% of saline grasslands are impacted by industrial development.

Request: GOC recommends that EnCana describe how these wetland and saline grasslands have been impacted by industrial development.

Response: Unclassified wetlands have been impacted by double track trails (0.1%), pipelines (2.2%), single track trails (0.7%), and dugout (9.7%). Single track trails are very likely due to cattle.

Saline grasslands have been impacted by double track trails (0.04%), dugouts (0.7%), raised gravel roads (4%), single track trails (2%), and pipelines (1.4%). Single track trails are very likely due to cattle.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 267

Requesting Party: Federal Government

Reference: Volume 3, Section 7.6.6, Page 7.27

Preamble: EnCana states “Amphibians do not appear to be negatively affected by existing levels of disturbance either (Section 5.6.5). The greatest numbers of large choruses of both boreal chorus frogs and Great Plains toads are to be found within the areas of the NWA which have been, and continue to be, subject to the greatest human disturbance - Falcon/southern Casa Berardi/southern Fish Creek area.”

Request: GOC recommends that EnCana justify and rationalize the conclusions, given limitations of the survey approach and results, that amphibians do not appear to be negatively affected by existing levels of disturbance.

Response: EnCana’s analysis was conservative, due to the constraints imposed by the field methodology, the contingencies of the 2006 field season, and the nature of northern Great Plains breeding anuran phenology. Due to these factors, EnCana can only determine that boreal chorus frog and Great Plains toad populations did not appear to be negatively affected by existing levels of disturbance. This was not intended to be interpreted as stating definitively that these species had not been so affected, but that any such statement could not be made based upon EnCana’s findings.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 269

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 270

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 271

Requesting Party: Federal Government

Reference: Volume 3. Section 4.7.2 Existing Foot Print by Wetland Type.

Preamble: The EIS states that “Disturbance was detected in 8 of the 12 wetland types mapped by CWS in the NWA.” And that “It is important to note that the percentage of existing footprint does not necessarily represent a 100 percent effect on habitat structure or composition within the buffered footprint”.

Request: GOC recommends that EnCana discuss impacts to the wetlands (per wetland), and wetland buffer areas, as well as the timeline for which each of the impacts likely occurred.

Response: See Section 4 of Volume 3 for Project effects assessment. EnCana has not assessed by wetland, as not all wetlands are mapped. The timeline is set out in Section 2.5 of Volume 1.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 273

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 274

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 275

Requesting Party: Federal Government

Reference: Appendix 5F, Habitat Suitability Ratings, Tables 5F-1 and 5F-2, pages 5F-3 to 5F-13

Preamble: The tables are lacking in documentation or explanation of habitat units. Abbreviations are used without explanation or reference to where an explanation can be found.

Request: For Tables 5F-1 and 5F-2 part 1 and 2, the GOC recommends that EnCana provide: 1. Definitions of abbreviations used in headings (for vegetation cover types and habitat units and a reference where in Volume 3 or its appendices they are described and the derivation provided. 2. Definitions of the Abbreviations H, M, and L and a reference to the location in Volume 3 or its appendices where a description of the derivation and manner of assignment is provided.

Response: 1. The habitat unit codes shown on the X-axis of Tables 5F-2 and 5F-3 are comprised of three sources of information. The first part of the code (e.g. Gu/M/L) is the vegetation cover type. These codes correspond to the Potential Vegetation Cover Units listed in Table 3H-3, page 3H- 8 of Appendix 3H. Below are the linkages:

AN – Anthropogenic DG – Disturbed Grassland G-Ls – Grassland-mid/low shrubs dominated GLs-LSg-Gm – Grassland-mid/low shrubs dominated or co-dominated with Mid/low shrubs- Grassland and/or Moist Grassland Gm-Gs – Moist Grassland and/or Saline Grassland GrLs – Riparian Grassland-Mid/low shrub dominated Gts-Gt – Tall shrubs-grassland and/or Shrubs-trees-grassland dominated or co-dominated with other upland types G-GLs – Upland grassland and Grassland-mid/low shrubs co-dominated Gu-W – Upland grassland and Wetland co-dominated Gu – Upland grassland W – Wetland dominated

2. Definitions of habitat suitability and the methodology for generating habitat supply are presented in Section 5.7.1.1 and in the following table:

Low The habitat type may be used by the wildlife species in question, however, use is limited to travel, resting, loafing or opportunistic feeding and breeding. The habitat type contributes minimally to population viability of the species. Moderate The habitat type is used by the species for feeding and breeding, but is of EnCana Shallow Gas Infill Development in IR Due Date: the CFB Suffield National Wildlife Area CEAA File #05-07-15620 August 2nd, 2007 IR Requested By: IR No. Page Federal Government CEAA-EIS-012 2 #Terr - 276 - A

suboptimal quality relative to other habitats. The habitat type may contribute significantly to population viability of the species but only during periods of low environmental stress. High The habitat type is an important habitat of the species for feeding and breeding. The habitat type contributes significantly to population viability.

Reference: Appendix 5G, Habitat Suitability, Table 5G -1 and 5G-2, pages 5G-3 to 5G-6 Appendix 5H, Baseline Habitat Supply, page 5H-3 to 5H-49

Preamble: The tables in Appendix 5G are lacking cross referencing and definition of terms. The figures in Appendix 5H are not labelled other than with a species name. The Terms of reference state “The environmental impact statement shall provide all of the information required to understand or interpret the data (II 5.3, page 18).

Request: For Figures in Appendix H the GOC recommends that EnCana provide on each Figure: 1. A Figure number. 2. Describe the Habitat Ratings For Table 5G-1 and 5G-2, the GOC recommends that EnCana provide: 3. Describe Habitat Supply (High Suitability) and Habitat Supply (Moderate Suitability) 4. Describe each column heading

Response: 1. Baseline Habitat Map For

Figure 1 Sharp-tailed Grouse Figure 2 Pied Billed Grebe Figure 3 Horned Grebe Figure 4 American White Pelican Figure 5 American Bittern Figure 6 Great Blue Heron Figure 7 Black Crowned Night Heron Figure 8 Northern Harrier Figure 9 Swainson's Hawk Figure 10 Ferruginous Hawk Figure 11 Golden Eagle Figure 12 Prairie Falcon Figure 13 Upland Sandpiper Figure 14 Long-billed Curlew Figure 15 Caspian Tern Figure 16 Black Tern Figure 17 Forster's Tern Figure 18 Burrowing Owl Figure 19 Short-eared Owl Figure 20 Common Nighthawk Figure 21 Pileated Woodpecker Figure 22 Eastern Phoebe Figure 23 Loggerhead Shrike Figure 24 Sprague's Pipit EnCana Shallow Gas Infill Development in IR Due Date: the CFB Suffield National Wildlife Area CEAA File #05-07-15620 August 2nd, 2007 IR Requested By: IR No. Page Federal Government CEAA-EIS-012 2 #Terr - 277 - A

Figure 25 Common Yellowthroat Figure 26 Brewer's Sparrow Figure 27 Lark Bunting Figure 28 Grasshopper Sparrow Figure 29 Baird's Sparrow Figure 30 McCown's Longspur Figure 31 Western Small-footed Bat Figure 32 Olive-backed Pocket Mouse Figure 33 Long-tailed Weasel Figure 34 American Badger Figure 35 Bobcat Figure 36 Pronghorn - Summer Figure 37 Pronghorn - Winter Figure 38 Richardson Ground Squirrel Figure 39 Small Mammal Prey Figure 40 Plains Spadefoot Figure 41 Great Plains Toad Figure 42 Northern Leopard Frog Figure 43 Western Hognose Snake Figure 44 Bullsnake Figure 45 Wandering Garter Snake Figure 46 Plains Garter Snake Figure 47 Prairie Rattlesnake

2. Habitat ratings are described in 5.7.1.1.

3. High suitability and moderate suitability habitat is that rated H and M respectively as described in 5.7.1.1

4. Column headings

• “Baseline” refers to baseline supply of high and moderate suitability habitat respectively • “%of NWA” refers to the percentage of the entire NWA represented by the high suitability habitat for that species • “Project” refers to the habitat predicted to be disturbed by the project • “% change from Baseline” refers to the habitat predicted to be disturbed by the project as a percentage of the NWA

The rest of the columns should be interpreted similarly except in the context of the LSA and RSA respectively.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 278

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 279

Requesting Party: Federal Government

Reference: Volume 3, Section 5.5 Table 5-1 Pages 5-5 to 5-7

Preamble: EnCana provides abundance for snake species, however there is no indication of how these were derived. Indications of federal listing status are incomplete.

Request: GOC recommends that EnCana indicate how the abundance values for each species were derived, including assumptions and justifications for those assumptions, and discuss recovery implications to the prairie rattlesnake and western hognose snake which are currently under review by COSEWIC due to concerns regarding their status.

Response: EnCana used all available information but relied most heavily on the CWS 1994-1996 work. EnCana also utilized highly qualified environmental experts such as Ursus Ecosystem Management Ltd. Ursus’ experience working within and adjacent to the CFB Suffield and NWA is extensive and unique. Assessment of potential impacts on snakes is presented in sections 5.8.3.44 to 5.8.3.48. EnCana’s findings that potential impacts to Western Hognose Snake and Prairie Rattlesnake are insignificant indicates that the project will have an insignificant impact on the population, and therefore on the recovery of these species.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 281

Requesting Party: Federal Government

Reference: Volume 3, Section 5.6.2, Evaluating Effects Significance, Page 5-9 Volume 3, Appendix 5J, Breeding Bird Survey, Tables 5J-4 to 5J5 and Volume 3, Appendix 5K, Breeding Bird Survey and Disturbance Analysis, Table 5K-1- 5K-21

Preamble: EnCana states “Established criteria or scientific thresholds were not available for wildlife assessment. Rather a detectable change in biological parameters was relied upon based on assessors’ experience and expertise along with consideration of potential effects on population viability. In general, the overall rating was driven by the most important individual rating.”

Request: GOC recommends that EnCana: 1. Define and describe the criteria by which assessor’s expertise or experience was deemed sufficient and appropriate and justification for those criteria. 2. Provide justification for limiting the statistical consideration to statistically significant effects.

Response: 1. The assessor is a professional biologist and professional engineer who has specialized in birds throughout his career and has extensive impact assessment experience.

2. Sampling for birds was intended to test for changes in species abundance and distribution over the study area between the 2006 sampling period and the CWS sampling periods and within 2006 (birds only). EnCana took a scientific approach which included a priori imposing accepted levels of statistical probability before accepting apparent differences. EnCana chose to err on the side of caution, using an analytical approach that would lower the probability of identifying an effect when it was not real. Given the nature of the data and the possible sources of sampling error, we adjusted the α for any set of tests sufficiently low so as to lower the probability of a Type I error due to the number of simultaneous tests. Since the sample size remained constant, this would result in an increase in β, and thus a decrease in power; however, not performing this Bonferroni adjustment would have been statistically unacceptable. The analysis was thus conservative; the differences in distribution and abundance would have to be marked in order for the analysis to detect them. Against this must be considered the large amount of noise in data of this type, especially considering year-to-year variation shown by breeding birds. On the other hand, sample sizes were relatively large, which decreases β and thus tends to offset the loss of power inherent in a tight control of α. These constraints were considered in the analysis and discussion of the results.

Reference: Volume 3, Section 5.7.1.1 Page 5-19 and Appendix 5-F

Preamble: EnCana states “With reference to literature, first-hand knowledge of each habitat gained during the field surveys, and the authors’ knowledge of wildlife–habitat relationships in the RSA, the suitability of CWS vegetation cover types (Section 5.5.3) and habitat units (Section 5.6.3) were rated for each VEC using the following 3-class rating system”. . There is no presentation of how each habitat unit rating was derived using available data and/or the literature.

Request: GOC recommends that EnCana: 1. For each snake species provide a clear description of the sources of information from the literature, from available CWS assessment data and from sources of expertise, used to determine habitat requirements, movement patterns, local abundance, habitat suitability ratings, and threats (most notably traffic and persecution of individuals. 2. For each snake species utilize existing CWS data describing distribution and dispersal probabilities of snakes to provide a depiction of potential use of habitat units at varying distances from hibernacula along the South Saskatchewan River.

Response: 1. A comprehensive literature search was conducted for each wildlife VEC. Key findings with respect to snake VEC status, habitat associations, potential impacts of the project and proposed mitigation have been provided in Sections 5.7.2.44 to 5.7.2.48 and 5.8.3.44 to 5.8.3.48.

2. CWS data was considered as part of the comprehensive literature search referenced above. Limits were put on medium and high suitability habitat based on distance from the South Saskatchewan and Red Deer Rivers for Wandering Garter Snake, Bullsnake and Prairie Rattlesnake. Probabilities of occurrence as a function of distance from the South Saskatchewan River were not developed and in Encana’s view would not be helpful in assessing impacts.

Reference: Volume 3, 5.7.1.2 Page 5-24 to 5-25

Preamble: EnCana indicates the prairie rattlesnake was one Valued Ecological Component known to be affected by habitat fragmentation.

Request: GOC recommends that EnCana provide clarification of what criteria and information was used to select the prairie rattlesnake for assessing fragmentation effects.

Response: The project is not predicted to result in fragmentation effects. However baseline fragmentation was calculated (see 5.7.1.2, Appendix 5I) for a suite of species known or suspected to be sensitive to fragmentation. Prairie Rattlesnake was included as a native prairie associated species that likely suffers when agriculture and major linear features dissect prairie landscapes.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 285

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 286

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 287

Requesting Party: Federal Government

Reference: Volume 3, Section 5.8.2, Page 5-45

Preamble: EnCana states “Vehicle speeds will be restricted to 70 kph.”

Request: GOC recommends that EnCana provide the justification and rationale for choosing a speed limit of 70 kph to reduce snake mortality.

Response: In Volume 3 Section 5.8.2 (Mitigation) page 5-46, EnCana states that between April 15 and October 15, that within the high risk snake area vehicles speed will be restricted to 50 km/h. This is the period of snake migration where there is the highest risk of snake mortality. EnCana’s experience suggests that this speed limit is sufficient to address snake mortality risks caused by vehicles.

For the remainder of the year 70 km/h is the speed limit.

Reference: Volume 3, Section 5.8.2 , Page 5-45

Preamble: EnCana states “Brush or vegetation mowing will not occur during the migratory bird breeding period (approximately April 15 to August 1); where mowing is required as an undesirable vegetation control measure the mowing area will be checked by a qualified representative to ensure that no nesting birds or other wildlife are present.”

Request: GOC recommends that EnCana clarify how EnCana will apply restrictions to mowing of vegetation within the NWA and adjacent LSA to the April 15 to October 15 to remove risk of additive mortality of snakes.

Response: As presented in section 5.8.2 if mowing is required between 1 Aug and 15 October the mowing area will be checked by a qualified representative to ensure that no snakes or other wildlife are present.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 290

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 291

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 292

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 293

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 294

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 295

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 296

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 297

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 298

Requesting Party: Federal Government

Reference: Volume 3, Section 5.8.3.46 Pages 5-120 to 5-121

Preamble: EnCana states Page 5-120 that “This species is the most vulnerable garter snake due to its low reproductive rate, small population size and it’s more restricted and localized distribution (Cottonwood Consultants Ltd. 1986).”

Request: GOC recommends EnCana provide justification and rationalization for this statement.

Response: This is a literature citation and as such stands on its own merit.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 300

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 301

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 302

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 303

Requesting Party: Federal Government

Reference: Volume 3, Section 5.8.3.34, Ord’s Kangaroo Rat, Table 5-39, Page 5-101.

Preamble: Encana states, “Residual environmental effects of the Project on Ord’s Kangaroo Rat are rated as insignificant assuming successful implementation of mitigative measures as outlined above.”

Request: GOC recommends that EnCana provide a detailed description of how residual environmental effects were assessed and provide the detailed analysis on how the insignificant rating was determined based on that assessment and analyses, for the: Ord’s kangaroo rat, Western small- footed bat, Olive-backed Pocket mouse, Long-tailed weasel, American Badger, Bobcat, Richardson’s ground squirrel, and the Small Mammal Prey VEC.

Response: A detailed description of the environmental impact strategy and methodology is presented in Volume II, Section 3 (page 3-1).

The approach to the assessment and determination of significance is described in Volume II, Section 3.5 (pages 3-9 to 3-11). The current level of and approach was sufficient to assess the significance of residual Project impacts for these species.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 305

Requesting Party: Federal Government

Reference: Volume 3, Section 5.7, Page 5-23.

Preamble: EnCana indicates that habitat supply approach was not suitable for the Ord’s kangaroo rat.

Request: The GOC recommends EnCana provide justification and rationalization on how the habitat supply approach was not suitable for the Ord’s kangaroo rat, and detail how this affects the impact predictions and mitigation measures.

Response: Ord’s kangaroo rat select for micro-habitat environments at a very fine scale. It was not effective to utilize the habitat supply approach to evaluate the potential impact to this species for two reasons. First, because of this fine scale habitat selection. As described in Section 5.7.2.34 (page 5-35), kangaroo rats require open, sparsely vegetated sandy habitats. These characteristics are associated with sand dune habitats and stet arid grasslands. Kangaroo rats will also inhabit anthropogenic features such as roads and trails. These characteristics describe many localized regions within the NWA and are not limited to specific habitat types. Second, as described in Section 5.8.3.34 (page 5-99), mitigation and avoidance strategies have proven effective.

As a result of the implementation of these site specific mitigation measures, EnCana believes that the habitat supply approach to impact assessment is not required and considers the impact predictions put forth in the EIS to be adequate and correct.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 307

Requesting Party: Federal Government

Reference: Volume 3, Section 5.5, Valued Ecological Components, Table 5-1, Pages 5-5 – 5-8.

Preamble: Encana states, “All species, listed either by Alberta Sustainable Resource Development and the Committee on the Status of Endangered Wildlife in Canada, resident (that is not occurring only as a spring and fall migrant) during some portion of the year in the RSA and expected to occur (assigned an abundance status of C, U, or S – see Section 5.6.4) were selected as wildlife VECs (Table 5-1).”.

The Western Harvest Mouse (WHM) (Prairie population) – Reithrodontomys megalotis dychei was designated by COSEWIC as endangered (April 2007).

Request: GOC recommends that EnCana add WHM as a VEC and perform appropriate environmental assessment of impacts.

Response: Western harvest mouse was listed as Data Deficient at the time the EIS was prepared, thus, EnCana did not treat the WHM as a VEC (see Appendix 5A).

EnCana recognizes the change in status of the following other species: • Common nighthawk is designated as threatened; • Red knot is designated as endangered; and • Peregrine falcon is designated as a species of special concern.

Western Harvest Mouse

The western harvest mouse is widely distributed across North America but the Suffield area of Alberta likely represents the northern extent of its range (Reynolds et al 1999; Smith 1993). The western harvest mouse prefers flat and upland grasslands with mixtures of grasslands and shrubs that provide adequate cover (Reynolds et al 1999). This species was distributed widely across the NWA (Reynolds et al. 1999). The CWS (1999) surveys reported that western harvest mice were the second most abundant small mammal caught in 1994 and third most abundant in 1995. Reynolds et al (1999) also indicate that the harvest mouse was caught over a range of habitats. The small mammal survey conducted by EnCana (2006) recorded a single western harvest mouse capture (see Appendix 5P). No western harvest mice were caught by Dillon (1998).

Construction Phase

Project construction activities may result in effects associated with three of the five potential issues described in Section 5.8.1 (Volume III): • direct habitat loss EnCana Shallow Gas Infill Development in IR Due Date: the CFB Suffield National Wildlife Area CEAA File #05-07-15620 August 2nd, 2007 IR Requested By: IR No. Page Federal Government CEAA-EIS-012 2 #Terr - 308 - A

• sensory disturbance and effective habitat loss • direct mortality

Very little information is available to describe how this species might interact with reclaimed habitats. However, Navo and Flaharty (1983) cited in Reynolds et al (1999) indicate that western harvest mice will utilize agricultural fields as long as herbaceous cover is present. Mitigation presented in Section 5.8.2 will be implemented to minimize environmental effects on this VEC.

Based on habitat suitability mapping for other microtines, the western harvest mouse is predicted to lose 0.2 percent of its high suitability habitat in the NWA and 0.1 percent of its high suitability in the LSA.

Operations Phase

Effects associated with the operation phases are mainly related to sensory disturbance and effective habitat loss, and direct mortality (e.g., as a result of vehicle collisions). Mitigation presented in s.5.8.2 will be implemented as applicable, to minimize environmental effects on this VEC.

Decommissioning Phase

Project decommissioning and abandonment could result in the same effects experienced during the construction and operation phases. Mitigation presented s.5.8.2 will be implemented.

Summary of Residual Environmental Effects

The predicted residual environmental effects on the western harvest mouse are characterized using the criteria defined in the methodology (Volume 2) in the following table.

Rating Criteria Construction Operations Decommissioning Direction Negative Negative Negative Geographic Extent Local Project Local Duration Medium-term Long-term Medium-term Frequency Regular Regular Regular Reversibility In long-term In short-term In short-term Magnitude Negligible Negligible Negligible EnCana Shallow Gas Infill Development in IR Due Date: the CFB Suffield National Wildlife Area CEAA File #05-07-15620 August 2nd, 2007 IR Requested By: IR No. Page Federal Government CEAA-EIS-012 3 #Terr - 308 - A

Level of Confidence High High High Significance Negligible Negligible Negligible

Residual environmental effects of the project on the western harvest mouse are rated as negligible assuming successful implementation of mitigation measures.

Literature Cited

Navo, K.W. and E.D. Flaharty 1983. Small mammals of winter wheat and grain sorghum croplands in west-central Kansas. Prairie Nat. 15(4):159-172.

Reference: Volume 3, Appendix 5B, Incidental Observations of Listed and Other species.

Preamble: No raptors surveys took place during the field studies. Only incidental sightings were recorded (Vol. 3, Appendix 5B). However, seven raptor species were chosen as “valued ecological components” (Vol. 3, Table 5-1, Page 5-6). Nesting, foraging and migration passage raptor usage of the NWA is missing.

Request: The GOC recommends that EnCana provide the information necessary to comply with Guidelines for the EIS Part II Section 5.3.2 #24.

Response: EnCana relied on existing information, particularly the CWS work done during 1994-1996 which was extraordinary in both its scope and comprehensiveness, and the author’s knowledge of raptor ecology in the Suffield area. Field investigations during 2006 focused on evaluating potential effects of shallow gas activity on VECs. A comprehensive literature search was conducted for each wildlife VEC including raptors. Key findings with respect to raptor VEC status and habitat associations have been provided in Section 5.7.2.9 to 5.7.2.13 and 5.7.2.19 to 5.7.2.20.

Reference: Volume 3, Section 5.6.1, Overall Assessment Approach, page 5-9

Preamble: EnCana states: “The Project specifically involves infill drilling (up to 16 wps) of natural gas wells in predominantly native prairie. Few scientific studies have empirically assessed the effects of infill drilling and well density on wildlife species and assemblages in this particular ecological setting (i.e., Dry Mixedgrass prairie). Given the limited empirical measures relevant to the study area we avoided modelling which by its very nature demands empirically derived inputs.”

Request: GOC recommends that EnCana substantiate the conclusion that there were insufficient empirically derived inputs to attempt modeling approaches for bird VECs.

Response: EnCana is not aware of any modeling approaches that would serve to answer the question of impacts of shallow gas infill drilling on breeding birds as directly and thoroughly as the empirical field approaches that were used during the 2006 surveys.

Reference: Volume 3, Section 5.6.5.2, page 5-13 , Appendix 5J and Appendix 5K Volume 3, Appendix 3E, page 3E-3 Volume 3, Section 7.4.6, page 7-11 to 7-12

Preamble: EnCana states that it recapitalized 376 sites surveyed in 2004 outside the National Wildlife Area from Dillon (2006). EnCana also states that it measured existing disturbance footprint inventory by digitizing features on November 2005 0.5 color ortho-photos. EnCana states “Digitizing occurred on all quarter sections contained with (sic) the NWA and randomly selected quarter sections outside the NWA.” Section 7, EnCana states “Dillon (2006) used Landsat image analysis and ground-truthing to calculate the amount of bare ground attributable to industrial (oil and gas + military) activity.”

Request: GOC recommends that EnCana: 1. Confirm that the estimate of disturbance assigned to each of the 2004 bird point counts was based on the 2005 ortho-photo analysis described in Appendix 3E. 2. Explain how the point count radius and the disturbance layer were accurately overlapped given shifts between GPS and photos described in Appendix 3E.

Response: 1. Yes this is the case. 2. The shift between bird plots and air photos was taken into account and corrected (in the GIS) when completing these overlays.

Reference: Volume 3, Appendix 3C, Vegetation Triangle Sampling Program. Table 3C-4 through 3C-8, 3C-10 through 3C-20, Page 3C-13 through 3C-16, 3C-18 through 3C-31 Volume 3, Appendix 3D, Paired Pipeline Sampling, Table 3D-2 through 3D-7, page 3D-11 through 3D-44 Volume 3, Appendix 5J, Breeding Bird Survey, Table 5J-1 through 5J-5, page 5J-11 through 5J-15 Volume 3, Appendix 5K, Breeding Bird Survey Disturbance Analysis, Table 5K-1 through 5K-21, page 5K-3 through 5K-23

Preamble: EnCana appears (most tables lack unit labelling) to have provided only total detections or means by treatment in the above named tables. The Terms of Reference (I 4.1) state: ensure that baseline information collected in each terrestrial and aquatic community is accompanied by sufficient plots in each soil-landscape phase to provide statistically sound data using a suitable sampling method. And, all conclusions regarding the receiving environment and predictions as well as an assessment of environmental effects shall be substantiated. And I 4.1 refers to clarifying text with tables.

The above named tables do not consistently include an explanation of what they provide, definitions of variables / headings, or a cross-reference to the text description of the hypotheses they address, the analyses from which they are derived, or where their contents are discussed as results. Request: GOC recommends that EnCana: 1. The mean, a measure of variance, and a measure of statistical power for each variable 2. Description of all variables and headings and the units of presentation including mean, variance, significance and power, where the description and justification for their derivation and calculation can be found, and a reference to the location of text where hypotheses were stated and results described. Response: Tables specified in Appendices 3C and 3D of Volume 3 provide mean values and sample sizes compared between experimental and treatment samples. The statistical test to detect significant differences in mean values between treatment and control is outlined in the methodology section in 3C.2.3 page 3C-7. Power analysis is not a fundamental requirement for the non-parametric statistical analysis used.

Tables 5J-1 to 5J-3 and 5K-1 to 5K-21 in Volume 3 present the total numbers detected by species. Means can be calculated using the sample size given in the title. Tables 5J-4 and 5J-5 present the mean value by species based on the sample size in the title. Variance was considered in the application of the t-tests (see Volume 3, Section 5J.2).

Sampling for birds was intended to test for changes in species abundance and distribution over the study area between the 2006 sampling period and the CWS sampling periods and within 2006. Some sampling schedules for birds were imposed EnCana Shallow Gas Infill Development in IR Due Date: the CFB Suffield National Wildlife Area CEAA File #05-07-15620 August 2nd, 2007 IR Requested By: IR No. Page Federal Government CEAA-EIS-012 2 #Terr - 312 - A

upon us by the CWS field design, and were further constrained by exigencies of weather, restrictions upon accessibility of the sampling sites during the desired 2006 sampling periods, and availability of personnel. The incomplete control over possible factors affecting species distribution and abundance, and the necessarily patchy nature of the inventory process itself, makes a formal calculation of the statistical power of the analysis unfeasible, and of doubtful value. We chose to err on the side of caution, using an analytical approach which would lower the probability of identifying an effect when it was not real. Given the nature of the data and the possible sources of sampling error, we adjusted the α for any set of tests sufficiently low so as to lower the probability of a Type I error due to the number of simultaneous tests. Since the sample size remained constant, this would result in an increase in β, and thus a decrease in power; however, not performing this Bonferroni adjustment would have been statistically unacceptable. Our analysis was thus conservative; the differences in distribution and abundance would have to be marked in order for our analysis to detect them. Against this must be considered the large amount of noise in data of these sorts, especially considering the year-to-year variation shown by breeding birds. These constraints were considered in the analysis and discussion of our results. On the other hand, sample sizes were relatively large, which decreases β and thus tends to offset the loss of power inherent in a tight control of α.

The objectives, methodology and discussion of results of the breeding bird surveys and analysis is provided in detail in Volume 3, Appendix 5J and briefly summarized in section 5.6.5.2. of Volume 3.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 313

Requesting Party: Federal Government

Reference: Appendix 5J, Breeding Bird Survey, Section 5J2, Page 5J3 Appendix 3C, Vegetation Triangle Sampling, Section 3C.2.3, page 3C7, Volume 3, Section 5.9, page 5-125 Cumulative Effects, Volume 3, Section 6.8.2, Biodiversity ratings depend on results from sections 3 and 5.

Preamble: EnCana states: “Breeding songbirds are resilient to the current cumulative effects (disturbance footprint) of land use in the MTA. However, EnCana was inconsistent in their choice of significance level for testing effects in various disciplines. In Appendix 3C they utilize 0.05 to test vegetation effects.

In Appendix 5J EnCana uses <0.01 and state their justification as: “The acceptance level was set at P<0.01 to reflect the use of the less conservative 1-tailed results and that, with many simultaneous tests conducted, the likelihood of a Type I error increases.”

Request: To substantiate EnCana’s statement in Section 5.9, the GOC recommends that EnCana: 1. Explain and substantiate why it was chosen (Appendix 5J) to decrease Type I error and consequently increase the chance of a Type II error by selecting a substantially higher threshold of significance than that used for vegetation in Appendix 5C.

Response: Please see response to Terrestrial 282, paragraph 2.

Reference: Volume 3, Appendix 5J Breeding Bird Survey and Appendix 5K Breeding Bird Survey Disturbance Analysis, all Tables, Page 5J-3 to 5K-23, Section 5J.4, page 5J-15 Volume 3, Appendix 5J, Section 5J2, Page 5J-3 to 4 Volume 3, Section 5.6.5.1, Page 5-12 Volume 3, Section 5.6.5.2, Page 5-13 Volume 3, Section 5.9, page 5-125

Preamble: EnCana provides a map of all point count sites sampled by EnCana or CWS but does not label sites with numbers (on the same map or in the section) or information about soils, well densities, or grazing or fire categories. Well density maps are at a different scale. EnCana states “A total of 410 100-m limited radius PC sites were established and surveyed from 17-28 June 2006 in both the northern and southern portions of the NWA by EnCana ( Figure 5J-2).” (page 5J-4). However Figure 5J-2 shows additional sites in the LSA (Koomati and portions of Falcon outside the NWA). A variety of analyses are described without indicating, by treatment, the locations of samples used and the proportion of samples conducted by each observer (Surveyor). EnCana states with regard to bird surveys (Volume 3, page 5-12): “Where appropriate, field investigations were stratified using three landscape-level variables, i.e., topographic habitat units (THUs), grazing intensity and fire frequency.” The Terms of reference state “The environmental impact statement shall provide all of the information required to understand or interpret the data (methods, survey dates and times, weather conditions, location of sampling stations, etc.)” (II 5.3, page 18). It is not apparent that the methods on bird survey methodology in Volume 3 and in Appendix 5J meet this requirement To substantiate assertions stated by EnCana [namely The results from the replication of the 1994-1995 CWS PC survey sites does not suggest that oil and gas activity during the intervening period has had a significant effect on the species surveyed(Appendix 5J, page 5J- 15). In addition. breeding songbirds are resilient to the current cumulative effects (disturbance footprint) of land use in the MTA. (Section 5.9)] requires considerable clarification and addition of details to the underlying methods.

Request: GOC recommends that EnCana specify, for each analysis, whether sample stratification and selection and methods controlled for soil, grazing, fire, observer and previous 12 month precipitation levels, when making between year comparisons and disturbance level comparisons.

Response: CWS sample sites were established and simply replicated. All of the EnCana sites were established based on unique conditions as described in Table 5-3. These unique conditions were a function of topographic habitat unit (approximating landform), fire frequency and grazing intensity. The EnCana and Dillon sites were controlled for observer. The Dillon sites when selected were controlled for soil.

Analyses were based on several different ecological mapping approaches, as listed below, along with whether they incorporate (control for) soil, fire and/or grazing (N=No, Y=Yes).

Soil Grazing Fire CWS cover type N N N CWS ecosites Y N N Ecological range site Y N N Habitat type Y Y Y Potential vegetation cover N N N

None of the analyses were controlled for previous 12 month precipitation levels.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 316

Requesting Party: Federal Government

Reference: Volume 3, Section 5.7.2.24, Page 5-25 Appendices 5G, 5H, 5I

Preamble: EnCana states “It (Loggerhead Shrike) is an uncommon summer resident and breeder in the NWA.”

Request: GOC recommends that EnCana use appropriate sources of information, including relevant literature and sources of expertise to be found within the national recovery team, to provide a clear description of habitat requirements and to provide a regional context for describing the abundance and trends of the loggerhead shrike.

Response: A comprehensive literature search was conducted for each wildlife VEC including the Loggerhead Shrike. Key findings with respect to Loggerhead Shrike status and habitat associations have been provided in Section 5.7.2.24.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 318

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 319

Requesting Party: Federal Government

Reference: Volume 3, Section 5.8.3.24, Page 5-82

Preamble: EnCana states “Based on habitat suitability mapping, the Loggerhead Shrike is predicted to lose 0.1 percent of its H suitability habitat in the NWA and 0.1 percent of its H suitability habitat in the LSA (Appendix 5G).”

Request: GOC recommends that EnCana clarify how available CWS assessment data was utilized to develop meaningful habitat suitability ratings.

Response: A comprehensive literature search including CWS work conducted in 1994-1996 was conducted for each wildlife VEC. Key findings with respect to Loggerhead Shrike status and habitat associations have been provided in Section 5.7.2.24. The methodology for habitat suitability and supply assessment is presented in section 5.7.1.1.

Reference: Volume 3 Section 5.6.5.5 and Section 5.6.5.6

Preamble: Using the following example, data collected during the ungulate air survey and the ungulate road-trail survey was collected during a very short period. Several conclusions are drawn from the analysis of this data. With respect to pronghorn antelope statistical power analysis has not been conducted for any of the results presented.

Request: GOC recommends that EnCana: 1. Provide a discussion on sample size, power analysis, and sample duration for pronghorn antelope. 2. For the results related to antelope response to vehicles (Section 5.8.3.38) provide a statistical power analysis, and discussion of significance. 3. For each of the statistical analyses presented in the EIS provide a statistical power analysis for each along with a textual explanation of statistical power and the results presented.

Response: 1. Sample size can be considered in the context of the purpose of the study, the size of the population being studied and allowable sampling error. A larger sample size generally results in parameter estimates with smaller variances. The survey resulted in 400 observations representing 867 pronghorn in the study area. To put that number in context, there were ~2144 pronghorn estimated to be in CFB Suffield following the 2006 Provincial antelope census, so the survey counted just under half the total population. As such, the sample size for this study was determined to be adequate.

Power analysis determines the ability of a model to determine an effect, given the effect exists. In resource selection modeling, based on use-availability data logistic regression is used to estimate resource selection, not for statistical inference (Boyce, Vernier et al. 2002). Power analysis was not conducted for the RSF. If statistical inference is required, K-fold cross validation is recommended to evaluate model predictions based on use-availability data (Boyce, Vernier et al. 2002).

Three days were required to sample the local study area for the resource selection analysis. Multiple sampling periods throughout a season are not a usual component of RSF analysis.

2. Statistics (other than descriptive) were not used for the assessment of antelope response to vehicular disturbance. The purpose of this program was to understand more fully the reaction of antelope to vehicles. This allowed a more ‘fact-based’ assessment of impacts of construction and operations. Quantitative data of this nature did not exist in the literature for pronghorn. Power analysis was not necessary to meet the objectives of this survey.

3. Please see responses to Terrestrial 235 and 236 for answers concerning the lack of EnCana Shallow Gas Infill Development in IR Due Date: the CFB Suffield National Wildlife Area CEAA File #05-07-15620 August 2nd, 2007 IR Requested By: IR No. Page Federal Government CEAA-EIS-012 2 #Terr - 321 - A

requirement for Power Analysis for various aspects of the EIS.

Boyce, M., P. Vernier, et al. (2002). "Evaluating resource selection functions." Ecological Modelling 157: 281-300.

EnCana Shallow Gas Infill Development in IR Due Date: the CFB Suffield National Wildlife Area CEAA File #05-07-15620 August 2nd, 2007 IR Requested By: Federal Government IR No. Page CEAA-EIS-012 1 #Terr - 322 - A

Reference: Volume 3, Section 5.7.1.1, Habitat Suitability and Supply, Page 5-23

Preamble: EnCana identifies (Section 5.7.1.1) with reference to literature, first-hand knowledge of each habitat gained during the field surveys, and the authors’ knowledge of wildlife– habitat relationships in the RSA, the suitability of CWS vegetation cover types (Section 5.5.3) and habitat units (Section 5.6.3) were rated for each VEC using the following 3- class rating system. It was necessary to use habitat units because the CWS vegetation cover type mapping does not cover the entire RSA.

Low: The habitat type may be used by the wildlife species in question, however, use is limited to travel, resting, loafing or opportunistic feeding and breeding. The habitat type contributes minimally to population viability of the species.

Moderate: The habitat type is used by the species for feeding and breeding, but is of suboptimal quality relative to other habitats. The habitat type may contribute significantly to population viability of the species but only during periods of low environmental stress.

High: The habitat type is an important habitat of the species for feeding and breeding. The habitat type contributes significantly to population viability.”

Request: For each VEC, the GOC recommends that EnCana provide: 1. A justification for the use of qualitative measure of habitat suitability. 2. A description of how categories were determined. 3. Clarity with regard to indicating that moderate habitat types may only be important during periods of low environmental stress. 4. Describe the Habitat Suitability rating accuracy.

Response: 1. Habitat suitability rating was chosen as the method to assess habitat supply as quantitative habitat attributes are not available for the NWA. EnCana’s experience is that assessing habitat supply using a habitat suitability rating approach is no less informative than building habitat suitability models which, in many cases, end up being very simple due to the lack of habitat attribute data compounded by a weak understanding of VEC/habitat attribute relationships. Habitat models also comprise a large element of subjective ratings but at the individual attribute rather than final output levels. It is the strongly held view of EnCana’s environmental consultants (Ursus) that even with considerable habitat attribute data, expert-based subjective ratings are as accurate as Habitat Suitability Index models when the latter are bracketed into three or EnCana Shallow Gas Infill Development in IR Due Date: the CFB Suffield National Wildlife Area CEAA File #05-07-15620 August 2nd, 2007 IR Requested By: Federal Government IR No. Page CEAA-EIS-012 2 #Terr - 322 - A

five classes of habitat suitability.

2. The habitat suitability rating system used in this assessment was created by the authors and has been utilized effectively for projects to quantify and assess habitat supply. EnCana specifically selected its expert environmental team based on their expertise at Suffield, and for their demonstrated expertise and responsible advice provided on other projects.

3. As stated in 2 above the habitat suitability rating system was created by the authors. Their position is that considering moderate habitat as being important when conditions are good (ie low environmental stress) is helpful.

4. The habitat suitability predictions were reviewed for reasonableness in the context of the authors’ understanding of the landscape scale distribution of each VEC. No formal assessment of accuracy was undertaken.

Reference: Volume 3 Section 5.8.3 Environmental Effects on VEC’s. Page 5-46

Preamble: Impact of the project on various Valued Ecosystem Components is addressed at the end of each relevant section in the form of a qualitative matrix. However, the quantitative thresholds used to derive the matrix are not explicit.

Request: GOC recommends that EnCana provide the quantitative thresholds used to create the matrix.

Response: No quantitative thresholds were used in the assessment of impact significance. Approaches to determining significance of impacts are outlined in Volume 2, Section 3.5.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 324

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 325

Requesting Party: Federal Government

Reference: Volume 3, Section 6.84, Page 6-7.

Preamble: Appendices 3-C, 3-D, and 3-E all document profound differences between disturbed and undisturbed areas, with documented differences lasting as much as 30 years (e.g., Sections 3C.4.6.3, 3C.5.3, 3C.5.4, 3D.3.1.3, 3D.3.2.4, 3D.3.3.2, 3D.3.3.3, 3D.4—Page 3D-45).

Request: GOC recommends that EnCana provide an analysis of the impacts on landscape level biodiversity.

Response: The differences in landscape-level plant species biodiversity between areas with 8 and 16 wells per section was assessed as part of the vegetation triangle sampling (Volume 3, Appendix 3C).

This program compared the number and percent cover of native plant species for randomly selected quarter-sections and compared these biodiversity parameters as they were influenced by well density, fire frequency, topographic habitat unit and grazing level (Volume 3, Appendix 3C). Two indices of diversity (Simpson’s Index and Sorenson’s Index) were used to compare species diversity and similarity between quarter sections with differing well densities. Further analysis is not considered necessary to draw conclusions as to impact of shallow gas fill drilling from the Project on vegetation biodiversity.

Reference: Volume 3. Section 6.6.3. Landscape Biodiversity.

Preamble:

Request: GOC recommends that EnCana explain and justify the use of the landscape biodiversity indicator index equation.

Response: The equation is useful since it integrates the spatial complexity of the landscape (landscape diversity) with habitat level biodiversity.

The habitat level of biodiversity provides a relative estimation of biodiversity for each habitat type. As a result, when mapping habitat biodiversity, all the polygons of the same habitat type would have the same biodiversity, no matter their spatial position or the spatial complexity inside of them. The integration of a measurement of landscape diversity allows capturing differences among polygons of the same habitat type and also inside of each polygon in terms of the heterogeneity produced by different levels of greenness, and vegetation and soil moisture. Further explanation of each component of the equation is provided in Volume 3, Appendix 6A.2.

Reference: Volume 3. Section 6.6.2. Habitat Diversity.

Preamble:

Request: GOC recommends that EnCana GOC describe information for the use and accuracy of the habitat level biodiversity equation, given that both the plant species diversity and the listed species diversity are both estimated.

Response: The habitat level of biodiversity equation is a relative estimation of the biodiversity potential of each habitat type. Rankings were based on professional experience and supplemented by field data from vegetation plot sampling during the Summer 2006.

Reference: Volume 3, Section 6.1, Table, Pages 6-1 to 6-2

Preamble: EnCana Page 6-1 does not include population effects from direct mortality (e.g. additive mortality in snakes) and disturbance (e.g. nesting of shrikes) in their project specific-effects that have potential to affect biodiversity.

Request: GOC recommends that EnCana include negative impacts upon population size in the use of any measures to assess change in biodiversity from the project.

Response: One aspect of biodiversity assessment is the ‘Species-level’ (Volume 3, Section 6.6.1). This level of biodiversity encompasses populations of specific species. Direct mortality effects were included in the assessment of significance of Project-specific and cumulative effects on wildlife populations (Volume 3, Section 5.8.1; Volume 3, Section 7.6.6).

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 330

Requesting Party: Federal Government

Reference: Volume 3, Section 6.4, Pages 6-2 to 6-3

Preamble: EnCana states Page 6-3 “The main issues for wildlife species are: loss and alteration of high quality habitat, habitat fragmentation and connectivity, and direct mortality (including rare species).” Although EnCana states that direct mortality is a main issue, in the next paragraph of Page 6-3 they do not include this as a key project-specific effect that can affect biodiversity.

Request: GOC recommends that EnCana discuss direct mortality in an assessment of possible changes in biodiversity due to the project.

Response: Listed species of wildlife such as burrowing owls and Prairie rattlesnake have the potential for direct mortality through vehicle interactions. Volume 3, Section 5.8.2, pages 5-45 and 5-46, and in Volume 1, Appendix I of the Environmental Protection Plan outline the mitigative measures that will minimize vehicle collisions and therefore, mortality is minimized so that biodiversity in the NWA will not be effected.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 332

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 333

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 334

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 335

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 336

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 337

Requesting Party: Federal Government

EnCana undertakes to provide a response to the above referenced Information Request as soon as practicable. EnCana Shallow Gas Infill Development in IR Due Date: the CFB Suffield National Wildlife Area CEAA File #05-07-15620 August 2nd, 2007 IR Requested By: Federal Government IR No. Page CEAA-EIS-012 1 #Terr - 338 - A

Reference: Volume 3, Section 9, Page 9-1

Preamble: EnCana states in EIS Volume 3, Section 9, Page 9-1 that “Severe weather is an important consideration in wellsite design, construction, operation, and decommissioning and abandonment and that severe weather over the prairies generally consists of blizzards, thunderstorms and lightning, heavy precipitation, and tornadoes.”

Request: GOC recommends that EnCana describe, with regards to Effects of the Environment on the Project, how winter thaw events and how summer drought periods may have an effect on the project.

Response: Winter thaw events will trigger the same evaluations mentioned in the Wet Weather Shutdown section of the Environmental Protection Plan (Volume 1, Appendix I, pg I- 17).

Summer drought periods will primarily extend the time necessary for disturbances to recover. As summer drought periods can increase the potential for soil erosion, erosion prone areas will be identified during the Pre-disturbance Assessment and these sites that are erosion prone will be monitored as part of the post construction monitoring program. Provisions are described in the Erosion Control section of the EPP (Volume 1, Appendix I, pg I-20).

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 339

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 340

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 341

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 342

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 343

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 344

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 345

Requesting Party: Federal Government

EnCana undertakes to provide a response to the above referenced Information Request as soon as practicable. EnCana Shallow Gas Infill Development in IR Due Date: the CFB Suffield National Wildlife Area CEAA File #05-07-15620 August 2nd, 2007 IR Requested By: Federal Government IR No. Page CEAA-EIS-012 1 #Terr - 346 - A

Reference: Volume 3. Page 8.2. Spills from vehicles.

Preamble: EnCana states “the mitigation measures outlines above will reduce the probability of occurrence and minimize the impacts to wildlife” Request: GOC recommends that EnCana GOC requests details of past vehicle releases and a detailed response plan that describes how sites will be cleaned, what the clean state is defined as and how the waste material will be disposed of.

Response: EnCana has not experienced a vehicle incident in the NWA since 2004 and this incident did not result in a release. In the unlikely event of an incident, responses plans will be carried out as per EnCana’s ERP and EnCana’s Draft Environmental Protection Plan. EnCana’s ERP can be viewed as and attachment to Health 9 and EnCana’s Draft Environmental Protection Plan can be viewed in Volume 1, Appendix I.

Production Operations practices specifically related to spills and releases can be found within Terrestrial 346.

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 347

Requesting Party: Federal Government

EnCana undertakes to provide a response to the above referenced Information Request as soon as practicable. EnCana Shallow Gas Infill Development in IR Due Date: the CFB Suffield National Wildlife Area CEAA File #05-07-15620 August 2nd, 2007 IR Requested By: Federal Government IR No. Page CEAA-EIS-012 1 #Terr - 348 - A

Reference: Volume 3. Pg. 8.5. Wetlands and Vehicles.

Preamble:

Request: GOC recommends that EnCana provide a detailed response plan of releases into a wetlands. Response: Any release into a wetland as a result of gas activities is extremely infrequent event. Response will be carried out in accordance with EnCana’s ERP. EnCana’s ERP can be viewed in an attachment contained in the response to Health 9. Production Operations practices specifically related to spills and releases can be found within the response to Terrestrial 346

EnCana Shallow gas Infill Development in the Suffield National Wildlife Area Environmental Impact Statement Information Request Responses filed 2007-08-16

The response to the following Information Request remains outstanding:

IR #: TERR 349

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 350

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 351

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 352b

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 353

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 354

Requesting Party: Federal Government

The response to the following Information Request remains outstanding:

IR #: TERR 355

Requesting Party: Federal Government

EnCana undertakes to provide a response to the above referenced Information Request as soon as practicable. EnCana Shallow Gas Infill Development in IR Due Date: the CFB Suffield National Wildlife Area CEAA File #05-07-15620 August 2nd, 2007 IR Requested By: Federal Government IR No. Page CEAA-EIS-012 1 #Terr – 356 - A

Reference: Volume 5, Appendix 2B, Pages 2B-3 to 2B-7

Preamble: The regional overview of archaeological knowledge takes a very chronological (time oriented) approach. There is no emphasis on land use through time. Request: DOC recommends EnCana place the pre-contact archaeological sites within a land use model that relates the sites to seasons of the year and seasonal activities. Response: Throughout prehistory the movement of bison herds across the landscape was one of the primary factors influencing prehistoric settlement and land use patterns. Several studies addressing bison migration patterns have suggested a link between the movement of bison with the seasonal variation between the parkland and the grassland zones on the Canadian Plains (Ray 1974; Arthur 1975, 1978; Gordon 1979; Morgan 1980; Epp 1988). The most recent model, developed and tested by Peck (2001), suggests that bison rutted at the edge of the parkland, wintered in the parkland and in large sheltered river valleys, calved back at the edge of the parkland, and summered on the plains.

Placing pre-contact archaeological sites that have been identified through limited shovel testing or as surface finds within a seasonal land use model is difficult. Specific faunal elements must be recovered in order to determine the seasonality of an archaeological site. Although foetal bones are by far the best-suited indicators of seasonality, complete long bone elements and mandibles also allow for identification of seasonality. Given the need for these specific elements, faunal remains recovered from excavated kills sites are ideal as they are often more numerous and better preserved than those recovered from buried campsite assemblages. Faunal material recovered from kill sites often have not been subjected to the intense butchering practices and grease or marrow extraction techniques that can severely damage and fragment bones. Similarly faunal remains recovered as surface finds are often too degraded to provide useful seasonality data.

Employing Peck’s model, and given the location of the Natural Wildlife Area within the southern plains, precontact archaeological sites located within upland areas would have been occupied during the summer months. Precontact archaeological sites located within the Saskatchewan River valley would have been occupied primarily during the winter months, although summer and spring occupation would also occur.

According to an ethnographic account of the late years of the buffalo days, the Blackfoot broke into bands and moved to their winter camps, which were staggered along major river valleys, in late October or early November (Ewers 1955:124). “For a Blackfoot camp to have remained on the open plains in winter would have been EnCana Shallow Gas Infill Development in IR Due Date: the CFB Suffield National Wildlife Area CEAA File #05-07-15620 August 2nd, 2007 IR Requested By: Federal Government IR No. Page CEAA-EIS-012 2 #Terr – 356 - A

suicidal” (Ewers 1955:124). A winter camp location provided firewood, feed for horses, and water (Ewers 1955:124; 1958:88 as cited in Peck 2001:15).

Authur, George W. 1975 An Introduction to the Ecology of Early Historic Communal Bison Hunting among Northern Plains Indians. Archaeological Survey of Canada Mercury Series paper No. 37. National Museum of Man, Ottawa.

Epp, Henry T. 1988 Way of the Migrant Herds: Dual Dispersion Strategy Among Bison. Plains Anthropologist 33(121):309-320.

Ewer, John C. 195 The Horse m Blackfoot Indian Culture, with Comparative Material Other Western Tribes. Bureau of American Ethnology, Bulletin 159.

1958 The Blackfeet: Raiders of the Northwest Pains. University of Oklahoma Press, Norman.

Gordon, Bryan H.C. 1979 Of Men and Herds in Canadian Plains Prehistory. National Museum of Man Mercury Series. Archaeological Survey of Canada, paper No. 84. Ottawa.

Morgan, R. Grace 1980 Bison Movement Patterns on the Canadian Plains: An Ecological Analysis. Plains Anthropologist 25(88):143-160.

Peck R, Trevor 2001 Bison Ethology and Native Settlement Patterns During the Old Women’s Phase on the Northwestern Plains. Unpublished Ph.D Dissertation, Department of Archaeology, University of Calgary, Alberta.

Ray, A.J. Jr. 1974 Indians in the Fur Trade, their role as hunters, trappers and middlemen in the lands southwest of Hudson Bay 1660-1870. University of Toronto Press.

Reference: Volume 5, Appendix 2B, Page 2B-6 and 2B-7

Preamble: Appendix 2B.5 Historic Period (A.D. 1874 -- 1950s) The discussion that follows this heading focuses on the exploration period and ends with the establishment of Fort MacLeod in 1875. In addition, section 4.7.1.1 History (Page 4-9) does not adequately identify these historical developments nor the resources that are representative of this period.

Request: GOC recommends Encana provide: 1. An overview of the settlement period between 1874 and 1950s. 2. Identify which lands were settled under the Homestead Act, and provide an overview of historical farming in the Suffield Area. 3. Describe the implications of formerly ploughed lands on the discovered of archaeological sites.

Response: 1. With the arrival of the North West Mounted Police a sense of order was established in southern Alberta. This provided an incentive for ranchers to move into vacant unfenced rangelands of the Suffield area in the 1870s. In the following decade more people settled Suffield, using the newly built (1883) Canadian Pacific Railway (CPR) with a stop in the town of Suffield, named after a financial backer of the CPR, Charles Harbord, Fifth Baron of Suffield (BCFBS 2000).

Additional incentive to settle within the Suffield area was made through the Dominion Lands Act, a Canadian law that encouraged the settlement of Canada’s prairie provinces, established in 1872. This act allowed for the purchase of 160 acres of land for $10.00 to any farmer that agreed to cultivate at least 40 acres and build a permanent dwelling within three years. For an additional $10.00 farmers could acquire a neighboring lot of 160 acres. This was especially important at Suffield as it lies within the Palliser’s Triangle, a very arid area of the prairie provinces.

Settlers worked the lands of the Suffield area with minimal success due to the arid conditions that made agriculture a difficult venture. Attempts to implement systematized irrigation in the early 1900s failed, but despite these obstacles a few farmers and ranchers stayed through the 1920s and 1930s. By 1941 there were approximately 125 scattered farms in the area known today as the Canadian Forces Base Suffield (BCFBS 2000).

In 1941, Canada and Great Britain set up the experimental station, known as Experimental Station Suffield, responsible for trials in biological and chemical EnCana Shallow Gas Infill Development in IR Due Date: the CFB Suffield National Wildlife Area CEAA File #05-07-15620 August 2nd, 2007 IR Requested By: Federal Government IR No. Page CEAA-EIS-012 2 #Terr – 357 - A

defence. This station included a 2,690 square kilometre range. In 1947 the station’s administration changed from the Canadian Army to the Defence Research Board (BCFBS 2000).

2. The Western Land Grants database is a comprehensive indexing of the legal descriptions of the prairie provinces including the first occupant of the land surveyed (ArchiviaNet 2007). Between 1870 and 1930 the records indicate that nearly 50 individuals had lands registered within the CFB Suffield National Wildlife Area (Table 1). It is unknown how many of these farmers and ranchers had broken the land for agriculture.

3. Disturbances to lands by ploughing have implications to the integrity of archaeological sites, although this is dependent on the type of archaeological site and processes of soil deposition. For example, farmsteads in the Suffield area, predating 1950, will most likely have remnants of architectural features, such foundations, walls, and cellars still visible on the surface. In addition, these historic sites can be identified though dilapidated farm equipment, garbage dumps, and other household debris. Ploughing will affect all archaeological sites.

Ploughing has a direct impact on prehistoric surface features, such as stone circles and cairns. The contexts of artifacts associated with these surface features are destroyed. However, with deeper soil deposition containing prehistoric occupations, site integrity remains intact.

NAME QUARTER SECTION TOWNSHIP RANGE CPR E 3 15 5 E17 155 SW 17 15 5 21 15 5 27 15 5 E33 155 SW 33 15 5 W 3 15 5 W 5 15 5 NE 5 15 5 NW 17 15 5 NW 33 15 5 SE 5 15 5 W15 165 NE 15 16 5 NE 27 16 5 35 16 5 SE 15 16 5 W27 165 SE 27 16 5 Andrew Rowand B Richmond NE 4 15 5 David H Williamson NW 4 15 5 Regina Turcotte SE 6 15 5 William Cousins NW 6 15 5 NE 7 15 5 NW 7 15 5 NW 7 15 5 NE 1 15 6 NE 12 15 6 NE 1 15 6 SE 12 15 6 SW 13 15 6 SE 13 15 6 SE 13 15 6 SE 34 15 6 SW 34 15 6 Alfred Huseby NW 1 15 6 Norlin Huslby SW 1 15 6 Herbert Love NE 2 15 6 Mels Christian Larson SW 2 15 6 George Washington Kaisler NW 12 15 6 John Brockie SW 12 15 6 Carl Krueger NW 13 15 6 Russell Nicholas Burkhoe SE 14 15 6 Russell N Burhoe SW 14 15 6 Narcisse Jumeau NE 22 15 6 SE 22 15 6 Rice Wm Wilber SW 22 15 6 David Holmes Smith NE 23 15 6 Joseph Dolphice Richard SE 23 15 6 Benjamin A Webb SW 23 15 6 John J Klein NW 24 15 6 SW 24 15 6 Arthur Linden SE 24 15 6 Hudson's Bay Co 26 15 6 8165 W26 165 SE 26 16 5 8166 W26 174 SE 26 17 4 8175 W26 175 SE 26 17 5 8184 W26 184 SE 26 18 4

Table 1: Land occupancy within the CFB Suffield National Wildlife Area between 1870-1930 EnCana Shallow Gas Infill Development in IR Due Date: the CFB Suffield National Wildlife Area CEAA File #05-07-15620 August 2nd, 2007 IR Requested By: Federal Government IR No. Page CEAA-EIS-012 4 #Terr – 357 - A

NAME QUARTER SECTION TOWNSHIP RANGE Hudson's Bay Co NE 8 18 4 8193 W26 193 SE 26 19 3 W26 194 SE 26 19 4 8203 The Southern Alberta Land Co Ltd 29 15 6 Harry Schilmar NW 31 15 6 Theodore Barneko SE 31 15 6 Theodore May Wood NW 36 15 6 James Beverly White NW 4 16 5 James Beverly White Sr SE 4 16 5 Ichabod Worden NE 17 16 5 SE 17 16 5 Walter P Purdy NW 17 16 5 SW 17 16 5 NW 20 16 5 SW 20 16 5 James Elwood Cleak NE 20 16 5 SE 20 16 5 NE 14 16 6 NW 13 16 6 Robert Nathaniel Murdock NW 3 16 6 John Reidlinger SW 3 16 6 William J Wilde SE 4 16 6 George Cyril Hay SW 4 16 6 Rex Norton Rose NE 5 16 6 S 5 16 6 Theodore Erickson SE 6 16 6 Oscar Joseph Deranlean NE 9 16 6 Sigvart Lien SE 9 16 6 Mary Delphine Huseby NW 10 16 6 William Henry Foley SE 10 16 6 Carl Klein SW 10 16 6 Walter Palmer Purdy SE 13 16 6 Samuel B Baker SE 15 16 6 Thomas H Tinney NE 28 17 4 SW 25 17 5 NW 25 17 5 E25 175 Mathilda Lawrence SW 28 17 4 Hettie Eugenie Graham NE 30 17 4 James Dunphy NW 30 17 4 Harry Martin Shirar NW 31 17 4 SW 31 17 4 William Winterbourne SW 2 17 5 William Sayers SW 6 17 5 Thomas I Lokier NE 14 17 5 NW 14 17 5 SE 23 17 5 SW 25 17 5 SE 25 17 5 Allan Chester Dimmock NW 14 17 5 SW 14 17 5 Ralph Strathie Harvey SE 22 17 5 John Hughes SW 22 17 5 The Soldier Settlement Board of Canada SW 23 17 5 NW 23 17 5 William Minno Sanders NE 26 17 5 Lauchy Matheson NE 35 17 5 William McKever SW 28 18 4 Frank Milton Gallup NE 6 19 3 William Ed McKay SE 25 19 3 John Lineham N 30 19 3 NE 32 19 3 S32 193 25 19 3

Table 1 (cont): Land occupancy within the CFB Suffield National Wildlife Area between 1870-1930 EnCana Shallow Gas Infill Development in IR Due Date: the CFB Suffield National Wildlife Area CEAA File #05-07-15620 August 2nd, 2007 IR Requested By: Federal Government IR No. Page CEAA-EIS-012 5 #Terr – 357 - A

References ArchiviaNet (2007) Retrieved August 1, 2007: http://www.collectionscanada.ca/02/020111_e.html

Backgrounder Canadian Forces Base Suffield (BCFBS) (2000) Retrieved August 1, 2007: http://www.army.forces.gc.ca/lfwa/Documents/Backgrounders/BG-Suffield.PDF