Environmental Assessment Track Report
EnCana Corporation’s Proposed Shallow Gas Development Project in the CFB Suffield National Wildlife Area
Submitted to the Minister of the Environment Pursuant to Subsection 21(2) of the Canadian Environmental Assessment Act
Prepared by Department of National Defence
February 2006
Table of Contents
2.0 Environmental Assessment Process ...... 4 2.1 Requirement for a Comprehensive Study 4 Responsible Authority (RA) ...... 4 Federal Authorities (FA’s) ...... 5 Federal Environmental Assessment Coordinator (FEAC)...... 5 Provincial Involvement...... 5 2.2 Current Path and Next Steps 5
3.0 Project Overview...... 6
4.0 CFB Suffield National Wildlife Area...... 7
5.0 Scope 7 5.1 Scope of Project 7 5.2 Scope of Assessment 8
6.0 Public consultation...... 8
7.0 Public Concerns in Relation to the Project ...... 9 Written Public Comments 15
8.0 The Potential of the Project to Cause Adverse Environmental Effects...... 18 8.1 Species At Risk 18 8.2 National Wildlife Regulations 19 8.3 Biological/Scientific Studies 19 8.4 Native Prairie and Ecology 20 8.5 Ancillary and Cumulative Effects 21 8.6 Supplementary Concerns 22
9.0 Ability of Comprehensive Study to Address Issues Relating to the Project 22
10.0 Recommendation...... 25 1.0 INTRODUCTION 1 ...... i 2.0 PROJECT DESCRIPTION 13...... i 3.0 ENVIRONMENTAL SETTING 23 ...... i 4.0 REQUIREMENTS RELATED TO FISH AND WATERWAYS 25...... i APPENDIX B – AEUB LICENCING PROCESS…………………………………...………29 ...... ii BIBLIOGRAPHY…………………………..…………………………………… ……..………30...... ii
1.0 INTRODUCTION ...... 1 1.1 PROJECT OVERVIEW 1
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1.1.1 Purpose of the Project ...... 1 1.1.2 Project Area ...... 2 1.1.3 Land Use ...... 3 1.1.4 Nature of Project...... 5 1.2 PROPONENT INFORMATION 7 1.3 REGULATORY OVERVIEW 7 1.3.1 Canadian Environmental Assessment Act...... 7 1.3.2 Other Federal Legislation, Regulations and Policies...... 10 1.3.3 Provincial Regulatory Process ...... 11 1.4 PUBLIC CONSULTATIONS 13
2.0 PROJECT DESCRIPTION ...... 13 2.1 PROJECT ACTIVITIES 15 2.1.1 Preparation Phase...... 15 2.1.2 Construction Phase...... 16 2.1.3 Operations Phase...... 19 2.1.4 Decommissioning and Abandonment...... 20 2.2 PROJECT SCHEDULE 21 2.3 WASTE DISPOSAL / WATER USE AND DISPOSAL 22 2.3.1 Water Required For Drilling & Drilling Products ...... 22 2.3.2 Water Usage for Completions...... 22
3.0 ENVIRONMENTAL SETTING ...... 23
4.0 REQUIREMENTS RELATED TO FISH AND WATERWAYS...... 25 4.1 ENVIRONMENTAL FEATURES 25 4.2 WATER SOURCES 26 The area within which a VEC functions and within which the Project’s effect may occur...... 9 Canadian Environmental Assessment Act ...... 16
Appendix 1 – Project Description
Appendix 2 – Scope of Assessment
Appendix 3 – Notice Requesting Public Comment
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1.0 Introduction
On March 4, 2005, EnCana Corporation (EnCana) submitted to the Department of National Defence (DND) a project description referred to as the CFB Suffield National Wildlife Area (NWA) Shallow Gas Infill Development Project, a proposal to install over a three-year period, up to 1275 new shallow gas wells within the boundary of the NWA (“the Project”). This document provides an overview of the proposed Project, steps taken to date with respect to the environmental assessment including a summary of federal coordination activities and public consultation.
The Department of National Defence (DND) has prepared this Environmental Assessment Track Report pursuant to paragraph 21(2)(a) of the Canadian Environmental Assessment Act (CEAA) to assist the Minister of the Environment in making a decision whether to continue the environmental assessment by way of a comprehensive study, or to refer the project to a mediator or review panel.
In accordance with paragraph 21(2) (a) of the CEAA the EA track report must address the following matters:
a) The scope of the Project; the factors to be considered in its assessment and the scope of those factors; b) Public concerns in relation to the Project; c) The potential of the Project to cause adverse environmental effects; and d) The ability of the comprehensive study to address issues relating to the Project.
2.0 Environmental Assessment Process
2.1 Requirement for a Comprehensive Study
The Project is subject to a comprehensive study in accordance with paragraph 2(c) of Part I to the Schedule to the Comprehensive Study List Regulations made pursuant to the CEAA, as it involves the construction of a gas pipeline in a National Wildlife Area as defined in section 2 of the Canada Wildlife Act. Paragraph 2(c) of the Comprehensive Study List Regulations states that a comprehensive study is required for “The proposed construction, decommissioning or abandonment, in a wildlife area or migratory bird sanctuary, of an oil or gas facility or oil and gas pipeline.” Responsible Authority (RA) In order to allow EnCana’s development in the NWA a permit is required pursuant to section 3 and 4 of the Wildlife Area Regulations. In the case of the CFB NWA, DND has been delegated the responsibility from the Minister of the
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Environment pursuant to section 4.2 (1) of the Canada Wildlife Act (CWA), R.S. 1985, c. W-9, as amended, for the administration of the area and those sections of the CWA that apply to it, this includes the permitting responsibilities. Because of its regulatory role, the DND is thus the responsible authority (RA) for this environmental assessment (EA). Federal Authorities (FA’s) Following the requirements of the Regulations Respecting the Coordination by Federal Authorities of Environmental Assessment Procedures and Requirements of the CEAA, the project description was distributed to other federal departments and agencies to determine their role in the assessment, if any. The other federal departments and agencies determined they were not a responsible authority (RA) for the project under section 5 of the CEAA. The following departments self- identified themselves as federal authorities under the CEAA possessing specialist knowledge and information which should be considered in the assessment of the proposed undertaking: Environment Canada, Parks Canada, Natural Resources Canada, Fisheries and Oceans Canada, Agriculture and Agri- Food Canada and Health Canada. Federal Environmental Assessment Coordinator (FEAC) Also, in accordance with section 12.4 of the CEEA, the Alberta Regional Office of the Canadian Environmental Assessment Agency is the federal environmental assessment coordinator for the Project, as the Project is described in the Comprehensive Study List Regulations. Provincial Involvement The Project is subject to regulatory approvals of the Alberta Energy and Utilities Board (AEUB). Although the Project does not require an environmental assessment under Alberta legislation, the AEUB and Alberta Sustainable Resources Development (ASRD) will participate in the federal environmental assessment under Appendix 3 of the Canada-Alberta Agreement for Environmental Assessment Cooperation.
Alberta Environment determined that a provincial environmental assessment is not required under the Alberta Environmental Protection and Enhancement Act and there is no need to participate in a cooperative environmental assessment at this time.
2.2 Current Path and Next Steps
The EA path for this project (in concordance with the CEAA) was established by the Responsible and Federal Authorities in April 2005 to include the following:
• Federal Co-ordination Process • Scope of Assessment and Scope of Project Submission • Public and Regulatory Comment on Draft Scope
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• Track Report Submission
As per subsection 21(1) of the CEAA this Track Report will consider the ability of a comprehensive study to address the issues relating to this project. After considering the Track Report and recommendation, the Minister of the Environment will make the irrevocable and final decision on whether the project will continue as a comprehensive study or to refer the project to a mediator or review panel under the CEAA.
If the Minister of the Environment determines that the environmental assessment will continue as a comprehensive study, an environmental assessment will be undertaken and a Comprehensive Study Report (CSR) will be prepared and submitted to the Minister of the Environment and to the Agency. The RA (DND) will ensure that there are opportunities for public participation during the comprehensive study process as outlined in CEAA.
If the Minister refers the project to a review panel, a group of experts selected on the basis of their knowledge and expertise (including one chairperson) will be appointed by the Minister of the Environment. The Minister of the Environment, after consulting the RA and other appropriate parties, will set the terms of reference for the review, and appoint the mediator or review panel members. The role of the review panel would be to review and assess the project, in an impartial and objective manner.
3.0 Project Overview
EnCana has proposed to drill up to 1,275 shallow sweet natural gas wells in the NWA over a three-year period. The wells will be connected into existing and new natural gas gathering infrastructure for delivery of the produced natural gas to market. The Project will add approximately 220 km of additional pipeline and will double the number of wells, currently in the CFB Suffield National Wildlife Area.
EnCana has indicated that it expects the Project to fulfill all the infill development necessary to fully extract the gas reserves in the NWA. Infill drilling is drilling that occurs within the boundaries of an existing developed gas or oil field. Associated with the gas wells, new infrastructure requirements include sumps, water and waste management development, including disposal areas and drilling fluid management, and infrastructure that connects the wells to existing facilities. The Project will require access to each of the wells during each physical activity phase (preparation, construction, operation/maintenance and decommissioning/abandonment).
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4.0 CFB Suffield National Wildlife Area
DND and the Canadian Forces have long recognized the area now known as the NWA as having national significance and special environmental components that must be protected. When CFB Suffield was established in 1971, the NWA was classified as environmentally protected and its use was restricted from certain development and ground military training.
The CFB Suffield Base Commander is accountable for all activities occurring on CFB Suffield. When the NWA was designated on 12 June 2003, the Minister of Defence was delegated the authority over the NWA by the Minister of the Environment in accordance with an amendment to the CWA. The Minister of Defence then sub-delegated this authority to the Base Commander of CFB Suffield. However, as prescribed in the pending MOU between the two departments, Environment Canada supports DND's administration of the NWA with advice and expertise on wildlife research and enforcement as required. This situation is unique among all National Wildlife Areas in Canada in that it is the only NWA that is administered by a department other than Environment Canada. This special arrangement allowed for the creation of the NWA as an integral part of the CFB Suffield training area. The NWA can be included within live fire safety templates in support of military exercises conducted elsewhere on the training area.
The NWA had been out-of-bounds to military ground training since 1972, and was precluded from deep rights access for petroleum development by the Canada - Alberta Partial Access Agreement of 1999. Cattle grazing and shallow gas recovery, which operate and were vetted under existing Memoranda of Agreement (MOAs) ratified during the 1970’s, were anticipated to continue subject to the environmental protocols specified in the respective MOAs controlling those activities, the Wildlife Area Regulations, and the management principles of the NWA as a place for wildlife.
5.0 Scope
5.1 Scope of Project
The scope of the EnCana Shallow Gas Development Project is described in the project description document prepared by EnCana Corporation in its capacity as the project proponent (Appendix 1). This document was released to the general public on 14 November 2005.
It includes the physical works related to the construction, operation, modification and decommissioning or abandonment of the proposed components of the
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Project and related undertakings.
5.2 Scope of Assessment
The RA is required to consider the factors specified in Section 16 of the CEAA, taking into consideration the definitions of the environment and environmental effect, prior to making a decision regarding whether to take action, in this case, to issue a permit, that would allow the project to proceed.
A draft Scope of Assessment document was prepared by DND in consultation with the Federal Authorities and provincial ministries involved. The (draft) Scope of Assessment document is found in Appendix 2.
6.0 Public consultation
The comprehensive study process requires that the public be given opportunities for public involvement in the comprehensive study as follows: consultation during the preparation of the scope of the assessment, participation in the conduct of the comprehensive study process, consultation during the preparation of the scope of the environmental assessment, during the preparation of the comprehensive study, and during the comment period administered by the Agency on the completed comprehensive study report.
This section describes the public consultation undertaken with respect to the proposed scope of the project, proposed factors to be considered, proposed scope of those factors and the ability of the comprehensive study to address issues relating to the project.
During the public consultation period 103 written comments were received in total. Submissions varied in form and content (see Table 1 Section 7.1) and were delivered through the identified feedback routes (i.e. fax, e-mail, and regular mail), as well as to the Minister of the Environment, the Prime Minister’s Office and the Minister of National Defence.
A public registry was established for the Project on 31, October 2005. The Project is listed on the Canadian Environmental Assessment Registry (CEAR) under project # 05-03-15620.
A 29-day public comment period was announced by way of a public notice on 14, November 2005. The comment period ended on 12 December 2005. The proponent’s draft project description and the scope of assessment were also published on the CEAR.
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DND advertised in various newspapers, starting the week of 14 November 2005, to provide notice of the public consultation period for the scoping phase of the environmental assessment. The newspapers and publication dates for the public notice, are as follows (copies are provided in Appendix 3):
Calgary Herald 25 November 2005 Medicine Hat News 15 November 2005 Lethbridge Herald Prairie Post 40 Mile Commentator 22 November 2005 Le Franco
The public notice, project description and scope of assessment documents were also published on the following websites:
The Canadian Army’s website at: http://www.army.gc.ca/lf/English/1_8_1.asp
The CFB Suffield website at: http://www.army.forces.gc.ca/cfb_suffield/environment.html
The Canadian Environmental Registry at: http//www.ceaa-acee.gc.ca/050/index_e.cfm
Copies of the scoping document and project description were also made available in printed form at the following locations:
Medicine Hat Public Library Medicine Hat, City Hall 414 First Street SE City Clerk’s Department - 2nd Floor Medicine Hat AB T1A 580 – 1st Street SE Medicine Hat AB T1A 8E6
Brooks Public Library Cypress County 420 – 1st Avenue West 816 – 2nd Avenue Brooks AB T1R 1B9 Dunmore AB T0J 1A0
Lethbridge Public Library 810 – 5th Avenue South Lethbridge AB T1J 4C4
7.0 Public Concerns in Relation to the Project
Since 1971, public interest in the NWA emerged through the accommodation of British Army training, petroleum development and emergency livestock grazing. In June 2003 interest was heightened as the area publicly received its
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designation as an NWA. The designation was established to ensure that the lands be maintained as federally protected and managed native wildlife habitat.
A total of 103 responses were received in response to the request for public consultation regarding the Project proposed by EnCana. Of these 103 items of correspondence, 75 responses represented individuals and the remaining 28 responses represented various organizations (government, non-government, research and private) originating from a range of sectors and industries (agricultural, environmental, oil and gas, archeological (cultural) and educational).
Through this public participation process, the RA has received valuable feedback with respect to the matters above, enabling the development of the EA track report. Feedback was organized and analyzed in relation to the categories as described by CEAA. Feedback material covered a broad range of issues, many of which were applicable to more than one category (i.e. Section 21(2) (a) and (b) and (c) etc). This information has been incorporated into Table 1 below.
Table 1. Summary Table of Public Consultation Comments
Number of Summary of Public Comments Comments Regarding Scope of Project (Out of 103 total) Concerns with the information presented in the Project Description including: inconsistencies regarding Landspraying While Drilling (LWD), water 2 withdrawal from the South Saskatchewan River, mitigation, scheduling and traffic. The scoping document does not clearly indicate how the environmental information gathered will be evaluated. Both the process and tools for 1 evaluation should be clearly defined. Thresholds should be established at the outset to determine if a change is significant. The NWA should be considered a Valued Ecosystem Components (VEC) in its own right to consider implications of the project on EC's entire protected 1 area Access should be included as a specific activity. The environmental effects of access should be addressed specifically based on the number of vehicles 1 required for each well.
The scoping document does not specifically outline dry or frozen ground 1 conditions and pipelining work outside of the growing season for the plants Water management protocols or assessment of dugouts and wetlands for use by the Suffield Industry Range Control are not specified in the Scope of 1 Projector Project Description
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Number of Summary of Public Comments Comments Regarding Scope of Project (Out of 103 total)
EnCana should explicitly state that no construction will occur in wetlands as 1 opposed to "no construction is anticipated" to occur in wetlands.
Reclamation efforts must not simply focus on a few native seed mixes; rather they must seek to re-establish the particular plant communities that match 1 reclaimed soil and landscape conditions. Native seeds should be harvested within DND Suffield lands or on native lands relatively close to the base.
Both Public Lands of Alberta Sustainable Resource Development and DND Suffield consider that LWD is not appropriate for application on native plant communities. It is strongly recommended that LWD be only applied on non- 1 native grasslands or on adjacent cultivated lands. EnCana Corporation should include this strategy in their Scoping Document.
The use of protective ground mats is recommended to cover access trails and the well sites. These mats distribute the weight load and protect native plant communities so that they can more easily recover from impacts. It is 1 recommended that each rig have its own set of protective ground mats to cover each active well pad and the access road.
Number of Summary of Public Comments Respecting Factors to be Considered Comments and the Scope of those Factors (Out of 103 total) Significance of Environmental Effects
Objection/concern with respect to the project and further development 78
Significant disruption/impact to the NWA species and environment (including: species at risk, loss of habitat, road induced mortality, effects of non-native 67 plants). Disruption of ongoing recovery/research efforts and studies on endangered species (e.g. Ord's Kangaroo Rat).
Need for Conservation/Preservation of the NWA 35
Ecological and ecoregional effects have a geographically far-reaching 3 implications broader than the boundaries of Alberta
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Number of Summary of Public Comments Respecting Factors to be Considered Comments and the Scope of those Factors (Out of 103 total) Review process should draw from independent expertise on sand hill ecosystems and species that would be affected by the proposed 1 developments Currently, not enough knowledge with respect to organisms and their habitat in the NWA to assess environmental impacts of the proposed development, 4 which is far greater than any past development. There will be lost opportunities for ecological research. Long term implications of development that is not sustainable 4
Other less sensitive locations may satisfy the oil/gas requirements. The NWA 2 should be considered the last location for drilling activity
Effects of drilling activities on water wells 1
EnCana’s historical conduct has not supported minimal disturbance 2
Concerns with increases in traffic and speed limits on site and surrounding 4 area Existing and increased Noise Issues 2 Cumulative Environmental Effects Concerns that existing damage by the proponent and practices have not been and should be assessed, monitored and restored prior to further 16 development. Cumulative effects including these past activities should be examined.
Unlike the existing wells, the proposed wells are above ground. The superimposed (cumulative) effects of the BATUS Templates in the NWA with 1 the above ground infrastructure of the development will increase the risk of collateral damage resulting in increased risk of environmental damage
Accidents and Malfunctions
There must be a requirement of up to 4 site inspections for each wellhead in the NWA annually. All inspections will have to be authorized by Range 1 Control and can only take place when it is safe to do so
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Number of Summary of Public Comments Respecting Factors to be Considered Comments and the Scope of those Factors (Out of 103 total) There will be a considerable amount of un-exploded ordnance in the NWA as the area has been used since 1941 for military trials and live fire exercises. 1 Any costs associated with land clearance would be the responsibility of EnCana. Socio-Economic Issues
Decrease in economic efficiency (e.g. too much production at the expense of 2 future supply specifically in a location where there is a social cost)
There is a need to preserve Cultural Values. 4 Due to the problems faced in the agricultural industry, it is the petroleum 1 sector that has enabled the community to grow and prosper.
Division of communities members through the promotion of job creation and 1 resulting tax dollars coming into the community A feasibility study should be done comparing monetary returns for the 1 existing and proposed well densities Policy Issues Concern that the responsibility of the NWA will be removed from DND and 1 placed with industry. Failure by EC and DND to uphold environmental commitments declared in June 2003 protecting the NWA. Federally protected areas should remain 43 protected. Concern that Alberta Environment is not involved in the process 2 The EA should be the responsibility of EC alone or jointly with DND. It should 1 not be the sole responsibility of DND
National Significance of the NWA
Failure to comply with historical agreements, goals and intent of NWA. Should proposed development occur, the level of disturbance will not be 21 compatible with the protection of species. Historical precedents (e.g. ANWR) have been set. Development will set a 11 poor precedent for NWAs in the future. Legislative Issues Amendment of the CWA to remove the Ministers ability to permit industrial 29 development within NWAs
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Number of Summary of Public Comments Respecting Factors to be Considered Comments and the Scope of those Factors (Out of 103 total) Direct violation of Section 4 of the CWA stating that the Minister may only permit the activity if "that activity will not interfere with the conservation of 1 wildlife" A number of species within the NWA are also listed as endangered under the 3 Provincial Wildlife Act, 2002
There is an onus is on Canada as a signatory of the Rio Convention on Biodiversity to conserve species with characteristics which do not occur any 1 where else in the world (ie. Canadian Ord's Kangaroo Rat) Issues Supporting Development Development should not be referred to negatively. Rewards outweigh the 5 minimal negative impact. Environmental Best Practices and commitments have always been followed by EnCana and are exemplary. EnCana has already shown environmental 8 stewardship with minimal impact There will be no increase in risks that haven't already been created by 1 historical and current use of the area
Economic benefits resulting from the project activity would be significant to 4 the City of Medicine Hat, City of Brooks and surrounding areas Assist EnCana in moving forward with the NWA project. Resource 5 development and the environment can co-exist Concerns with undue economic hardship drilling and operating restrictions may have on the ability to maintain operations and continue to grow the 2 employee base. Miscellaneous Concern that the NWA should be publicly accessible instead of being developed by the oil/gas industry. Lost opportunities for low impact 2 ecotourism (e.g. photography, birding, guided tours) Contractors of the highest standard should be used to supervise activities especially in the production phase as much of the damage occurs at this 1 point
Each land owner should have an independent environmental supervisor that is on site at all times throughout drilling, completions, pipelines, swabbing and 1 fracturing who would have the authority to shut down operations should the company not follow commitments.
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Number of Summary of Public Comments Respecting Factors to be Considered Comments and the Scope of those Factors (Out of 103 total) Consent of public servants to the demands of industry leads to a corporate 1 dictatorship The carrying capacity of routes must not be surpassed as deterioration of the routes may occur which could impact on the ability of BATUS to train. There 1 will need to be assurance that any additional route maintenance costs will be met by EnCana.
It is critical that the proponent understands that project work will be scheduled around BATUS activity and that BATUS has primary access to the Military 1 Training area from May1-October 31.
The province should consider buying back the mineral rights owned by 1 EnCana
Summary of Public Comments Respecting the Number of Ability of the Comprehensive Study to Address Comments Issues Related to the Project (Out of 103 total)
Request for a review panel 63
A public panel is necessary to ensure that concerns are expressed in an open and transparent manner, there is proper and fair consideration and the 53 full extent of environmental impacts will be assessed
Comprehensive Study will not allow the EA process to be transparent 5 enough, therefore review panel is required
Written Public Comments
The RA received a considerable number of responses (103 written comments) with respect to the Project (when compared to other EA’s). General profiles of the respondents and their comments received are summarized in general terms
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below:
• 11% (11/103) of the comments received through the public consultation raised concerns or provided suggestions towards improving and clarifying the scope of the project. The comments regarding the scope of project will be considered throughout the development of future documents and processes during this EA.
• 76% (78/103) of the comments indicated an objection or concern with the Project and the possibility of allowing any further industrial development in the NWA. 15 of the comments that were received were from organizations as follows: environmental groups (12 groups), University of Calgary, Royal Alberta Museum and Johnson and Sons Ranches (neighbouring landowner). The remaining 63 comments were received from private citizens.
• 65% (67/103) of those who responded indicated that they were disconcerted with the possibility of the Project resulting in significant disruption and impact to the NWA, its species and the surrounding area. 17 of the comments that were received were from organizations as follows: environmental groups and agencies (13 groups), Alberta Sustainable Resource Development (a provincial department), the University of Calgary, Royal Alberta Museum and Johnson and Sons Ranches (neighbouring landowner). The remaining 50 comments were received from private citizens.
• 61% (63/103) of comments received did not believe that a comprehensive study would be adequate to assess the impacts of the project proposed by EnCana Corporation and request a higher level of assessment. 60 comments literally requested a “panel review” while the other 3 referred to “full public review”, “public hearings” and “high level environmental assessment”. 10 of the comments that were received stemmed from environmental groups and agencies (9) and the Royal Alberta Museum. The remaining 53 comments were received from private citizens.
• 42 % (43/103) of respondents alluded that EC and DND did not fully uphold the commitments from when the NWA was declared in June 2003. Six of the 43 comments that were received were from environmental groups and agencies; the remaining 37 comments were received from private citizens.
• Concern was also expressed for the potential disruption of on-going recovery activities, research efforts and studies relating to endangered and SARA species. 34% (35/103) of comments reflected the need for the conservation and preservation of the NWA. Nine of the comments that
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were received were from organizations as follows: environmental groups and agencies (6 groups), Alberta Sustainable Resource Development (a provincial department), Royal Alberta Museum and Johnson and Sons Ranches. The remaining 26 comments were received from private citizens.
• 28% (29/103) of comments sought an amendment to the NWA regulations to disallow Ministers to approve development within NWA in Canada. There was also concern that this development might in principle set a precedent that for future industrial development within other National Wildlife Areas. Two of the comments that were received were from environmental groups and the remaining 27 comments were from private citizens.
• 16% (16/103) of public comments indicated concern with the potential for cumulative negative effects from the Project, based on the observed past practices of the Proponent, due to the proposed intensity of this development and due to the additional strain on current access routes. Six (6) of these comments came from organizations as follows: environmental groups (3 groups), as well as Johnson & Sons Ranches, the University of Calgary and the British Army Training Unit Suffield (BATUS). The remaining 10 comments were received from private citizens.
• Nine out of the 103 comments received were in support of the project. Comments were received from industry partners such as energy services firms (7) and those that had an interest in the economic development of the area (City of Medicine Hat, City of Brooks and surrounding areas). Comments indicated that the economic rewards of development outweighed the minimal negative environmental impacts. It was indicated that the economic benefits resulting from the project activity would be significant to the City of Medicine Hat, City of Brooks and surrounding areas.
• Concerns were raised regarding the undue economic hardship of possible drilling and operating restrictions and the impact it may have on the ability to maintain operations and to continue to grow the employee base.
The message received from the consultations was that there was a need for the federal government to undertake a transparent and “in-depth” environmental assessment process to ensure a high degree of impartiality, a fair and transparent process and to allow the public a greater opportunity for public participation. Additionally, it was acknowledged that the NWA is of utmost significance and should be protected from development. Comments received reflected concerns about issues such as the EA track recommendation; disruption/impact on species and the environment (including species at risk); the
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conservation/preservation of the NWA; ecological and ecoregional effects; cumulative effects; alleged failures by federal departments to uphold current environmental commitments respecting the NWA; and the environmental significance of the NWA.
8.0 The Potential of the Project to Cause Adverse Environmental Effects
Over the past 30 years, there have been various gas development activities within the NWA. This has resulted in the installation and construction of approximately 1,154 gas wells, associated pipeline, metering facilities, maintenance facilities and networks of access roads and trails. Although these oil and gas activities were subject to provincial regulations, the impacts of the activities, individually or cumulatively, have never been assessed via a federal environmental assessment under CEAA. In addition, the province provides no environmental oversight on federal lands.
Concerns have been expressed from within DND, as well as from federal expert authorities (Environment Canada), provincial departments (ASRD, Royal Alberta Museum), educational institutions (University of Calgary) and private citizens that there is currently insufficient data and evidence to ascertain whether this project is likely to cause significant adverse environmental effects to the NWA. These organizations have indicated that ongoing environmental research efforts (listed in Section 8.3) would also be disturbed with the onset of any alteration of the area. Although there are many ecological studies that have been conducted at CFB Suffield, none have directly focused on the full and cumulative impacts of the oil and gas activities.
8.1 Species At Risk
Subsection 32(1) of the Species at Risk Act (SARA) states that no person shall kill, harm, harass, capture or take an individual of a wildlife species that is listed as an extirpated species, an endangered species or a threatened species. Section 33 of SARA also stipulates that “no person shall damage or destroy the residence of one or more individuals of a wildlife species that is listed as an endangered species or a threatened species” while section 58 prohibits the destruction of any part of the critical habitat of any listed endangered species or any listed threatened species.
The proposed project has the potential to impact wildlife species listed as at risk and may potentially include activities that if allowed to proceed would require specific authorization under the SARA. It is likely that the NWA as a whole or a portion thereof will be identified as critical habitat once recovery strategies and action plans are finalized under the SARA. There are 14 SARA listed species at
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risk, known to inhabit the NWA. This includes 4 endangered species (Burrowing Owl, Swift Fox, Sand Verbena and Tiny Cryptanthe), 3 threatened species (Sprague's Pipit, Loggerhead Shrike and Slender Mouse Ear Cress) and 7 species of special concern (Yellow Rail, Ord's Kangaroo Rat, Long Billed Curlew, Ferruginous Hawk, Short-eared Owl, Great Plains Toad, and Northern Leopard Frog). The effects of this type of development on these species and their habitat are not yet fully understood. However, based on previous and ongoing studies as well as concerns expressed by federal and provincial experts, it is apparent that this type of development in the NWA has the potential to disturb or destroy known species at risk and/or critical habitats defined under SARA.
8.2 National Wildlife Regulations
There is potential for the Project to interfere with the conservation of wildlife and consequently be perceived as an inappropriate level of commercial or industrial activity within a nationally protected wildlife area. In the finalization of the NWA designation under the CWA, no significant changes in land use type were anticipated in the NWA.
Concern has been expressed by various non-governmental organizations throughout the public comment period as well as by the Environment Canada as Federal Authority (FA) that the type development proposed might contravene the spirit of conservation and stewardship for which the CFB Suffield NWA was declared. The proposed project may potentially include activities that would, if allowed to proceed, require a permit in accordance with Section 4, of the Wildlife Area Regulations. The proposed project also has the potential to set a precedent for increased industrial and resource development within other nationally protected areas.
8.3 Biological/Scientific Studies
Under the Auditor General Act, all federal departments are required to prepare Sustainable Development Strategies describing objectives and commitments for systematically integrating the principles of sustainable development into their policies, programs, legislation and operations. In order to fulfill the requirements of DND’s Sustainable Development Strategy, CFB Suffield has initiated an intensive long-term vegetation/habitat monitoring program on the Base. The goal of the study is to identify and compare the effects of military training to other land- uses, and examine changes in habitat over time as a result of management. The goals of the study include: identifying thresholds of environmental sustainability, assessing management activities and determining whether military training activities are environmentally sustainable. The proposed development will have implications for this study, as the fundamental assumption is that the NWA can
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provide large undisturbed areas of native prairie as baselines for comparison. While the direct effects of development may circumvent these sites, indirect and cumulative effects may compromise the study.
Additional completed studies related to the Project include the following:
“Audit of Encana’s Koomati Minimal Disturbance Shallow Gas Infill Program, Reference: 1262-1 (G3 Bio)—Review of Proposed 2005 Oil and Gas Drilling Programs for CFB Suffield”, January, 2005
“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” February, 2005
Ongoing studies related to the Project as previously discussed in Section 8.0 are as follows:
"Population and Habitat Monitoring for Ord's Kangaroo Rats in the Middle
Sand Hills Region, Canadian Forces Base Suffield", (University of Calgary and the Royal Alberta Museum)
"Conservation and Management of Ord’s Kangaroo Rats and Sandy Habitats on Canadian Forces Base Suffield", (University of Calgary and the Royal Alberta Museum)
"Assessment of Critical Habitat for Ord’s Kangaroo Rats", (University of Calgary and the Royal Alberta Museum)
"Seeds Collected by Ord''s Kangaroo Rats in the Sand Hills, CFB Suffield",(University of Calgary and the Royal Alberta Museum)
8.4 Native Prairie and Ecology
The proposed Project may compromise both the overall ecological integrity of the NWA and the population sources for wildlife species in southeastern Alberta. The NWA protects a large block of contiguous native prairie and sensitive sand hills habitat. Large tracts of native prairie typically act as population sources for wildlife species and a high number of species at risk, whereas fragmented landscapes support fewer species and tend to act as population sinks. These contiguous blocks of natural grasslands and associated rivers are among the most endangered ecosystems in the prairie region of Canada due to degradation and fragmentation from urbanization, industrial development, livestock grazing,
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invasive species, and rangeland conversion to croplands and seeded pastures frequently associated with irrigation development.
As indicated by the expert FA’s, native prairie is an endangered ecosystem, and is important for many ecological functions including carbon sequestration, water retention, water quality maintenance and primary productivity. CFB Suffield and the NWA, in a regional context, is a source for native prairie habitat and its dependent species. Given the nature of the current reclamation activities in native prairie the industrial development in this area will likely result in the deletion of native prairie habitat. Industrial reclamation, which attempts to restore ground cover and productivity (biomass), does not aim to replace the biodiversity lost during development. The NWA is also used as mitigation for military training impacts, where native seed is collected to restore native prairie in the most impacted areas. Thus, the NWA is capable of re-introducing species that have been lost elsewhere in the dry mixed-grass eco-region. This ability may be impaired, if industrial activities compromise the ecological functions of the NWA. Furthermore, given the sensitive nature of sandy soils across the NWA, there is a concern regarding long-term cumulative effects of fragmentation, and habitat degradation by invasion of non-native species.
The proposed Project also has the potential to impact wetlands within the NWA and; therefore, may impact the provision of wetland habitat for species at risk and other wildlife.
8.5 Ancillary and Cumulative Effects
EnCana has indicated that additional infrastructure and waste disposal methods will not be deployed in the NWA, therefore other locations within CFB Suffield will be used to support the development. The disturbance effects of this development to support the proposed development project, while not in the NWA, may affect military training and defense research.
The Suffield Environmental Advisory Committee (SEAC) provides advice to the Base Commander with respect to environmental aspects of oil and gas activities on CFB Suffield. The SEAC is comprised of three members: one member from EC (Canadian Wildlife Service), one member from Alberta Environment and one member from the Alberta Energy and Utilities Board (EUB). To date the SEAC has been involved in, and made recommendations and commented on, the approval of all development and reclamation activities in the NWA. The SEAC is expected to conduct annual inspections on a sampling of EnCana facilities to assess the level of implementation of mitigation measures. In 2004, the SEAC indicated in correspondence to CFB Suffield, that current knowledge is insufficient to conclude with confidence that disturbance activities will be neutral or have no long-term detrimental effects on the integrity of the NWA. SEAC further noted that activities were continuing in the absence of both a cumulative
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effects analysis and a comprehensive environmental management system, which would evaluate, monitor, and mitigate the effects of existing and future activities on the biophysical resources of NWA.
8.6 Supplementary Concerns
Studies carried out by the Canadian Wildlife Service, Prairie Farm Rehabilitation Administration, the University of Calgary, the University of Alberta, Alberta Sustainable Resource Development, and the Alberta Conservation Association will likely be compromised by additional development in the NWA. The scientific community has invested significant time and resources to study the NWA (see Section 8.3), as it provides a baseline source of information in its relatively undisturbed state. It provides a unique opportunity to study native prairie, as it would have looked 200 or more years ago. Thus, the influence of human activity on native prairie can be identified only in comparison to the NWA. The proposed development will have unpredictable and confounding effects on studies being carried out in the NWA.
Environment Canada, as a federal authority, has expressed concern that oil and gas activity will increase without a comprehensive environmental management system in place for monitoring, evaluating, and redressing the environmental effects associated with oil and gas activities in an environmentally sensitive area. This management system is needed to ensure the health and conservation goals that were intended when the CFB Suffield NWA was declared.
Through its participation on the Suffield Environmental Advisory Committee (SEAC), Environment Canada has expressed concern that the management of existing oil and gas activities on NWA has not demonstrated effective and timely mitigation and monitoring for environmental effects.
9.0 Ability of Comprehensive Study to Address Issues Relating to the Project
In deciding the track of the EA, the following conditions were evaluated and used to substantiate the project track recommendation:
(a) The project, has the potential to cause adverse environmental effects that, after detailed analysis, may be considered significant;
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Advice received by federal departments and government agencies have indicated that there is potential for the project to impact many environmental areas, and that more research is required to determine the long-term and cumulative effects. This would require further studies beyond the scope of the comprehensive study.
(b) Public concerns are substantial enough to warrant a referral to a mediator or review panel;
The type and relative amount of public comments received support the referral to review panel. Specifically, feedback related to the following issues: 61% of the 103 comments requested that the project be referred to panel review, 76% of the comments indicating objection or concern with the Project and the possibility of allowing any further industrial development in the NWA. Similarly, 62% of comments received did not believe that a comprehensive study would be adequate to assess the impacts of the project proposed by EnCana Corporation.
(c) There is likely to be substantial uncertainty associated with the environmental effects of the project, and the uncertainty is unlikely to be resolved through a comprehensive study.
It is clear that federal departments and internal stakeholders do not believe that a comprehensive study has the ability to address issues relating to the project. As well it is clear that there is not adequate information available to establish the full extent of the potential environmental effects and as such a comprehensive study would not adequately resolve the uncertainties of the effects.
The following resources were taken into consideration in order to evaluate the ability of the Comprehensive Study to Address issues Relating to the Project:
• The results of the public consultation (Section 7.0);
• Potential environmental effects of the Project as determined by historical studies (Section 8.3); • Potential considerable uncertainties associated with the environmental effects due to the impact and disturbance to ongoing studies in the site study area (section 8.3); • Potential for adverse environmental effects according to advice provided by federal authorities and government agencies (Section 8.0); and the
• Potential environmental effects and uncertainties of those effects according to advice provided by DND stakeholders (Section 8.0).
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In summary, there are potential adverse environmental effects that have been substantiated by past studies and research as well as instances where the effects of the proposed development are yet unknown. Effects on the ecosystem and overall ecology of species and the larger ecoregional impacts are also not known and would need to be considered to accurately determine the full impacts of the activities surrounding the project. In addition, the ASRD (participating in the federal EA process under the terms Canada-Alberta Agreement for Environmental Assessment Cooperation) has expressed substantive concerns through the public consultation process with regards to the potential for site- specific and far-reaching ecoregional impacts of the project.
Possible impacts to SARA species and critical habitat for example may not only have large ecological impact but also legal impacts. Under SARA the potential for adverse effects to SARA species must be determined and must include the study of possibly irreversible loss of critical habitat. In exercising its responsibility under section 4 of the Wildlife Area Regulations, DND must determine whether or not the proposed project will interfere with the conservation of wildlife in accordance with the Wildlife Area Regulations. Commercial or industrial activities may be allowed only "where the activity will not interfere with the conservation of wildlife" under the Wildlife Area Regulations, development proposals are only considered or permitted under exceptional circumstances, and only when it has clearly been demonstrated in advance that the activity will be compatible with the aims established for, and the integrity of the protected area. It would be best positioned to make these decisions with the benefit of an open and transparent process that a public review panel would achieve. It is the belief of the RA that this issue should be discussed within a review panel. Notably, DND will need to exercise their power, duty or function in conformity with the governments response to the panel report.
In considering the substantial amount and heightened concern expressed by the public consultation on the Project, it is clear the public also feels that a review panel would be the most appropriate method to continue the EA process. This recommendation is supported by Environment Canada’s Environmental Protection Operations Division, Prairie and Northern Region (as an FA) who recommends that the track decision consider a high level of public concern and that the public interest in this proposed project be given due consideration. A review panel would provide the members of the public with a forum within which they can bring forth their views and participate in a public debate on the merits of such a project and the role that National Wildlife Areas play in protecting critical habitat, species at risk and rare landscapes.
This EA and its conclusions have the possibility to affect broader policy and management practices for developments within protected areas. The possibility of setting such a precedent would benefit from a more independent discussion.
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10.0 Recommendation
It is recommended that the CFB Suffield National Wildlife Area Shallow Gas Infill Development Project be referred to a review panel.
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APPENDIX 1
CFB SUFFIELD NATIONAL WILDLIFE AREA SHALLOW GAS INFILL DEVELOPMENT PROJECT
PROJECT DESCRIPTION
NOVEMBER 1, 2005
1.1.1.1.1 TABLE OF CONTENTS
1.0 INTRODUCTION...... 1 1.1 Project Overview ...... 1 1.1.1 Purpose of the Project ...... 1 1.1.2 Project Area ...... 2 1.1.3 Land Use ...... 3 1.1.4 Nature of Project...... 5 1.2 Proponent Information...... 7 1.3 Regulatory Overview...... 7 1.3.1 Canadian Environmental Assessment Act...... 7 1.3.2 Other Federal Legislation, Regulations and Policies ...... 10 1.3.3 Provincial Regulatory Process ...... 11 1.4 Public Consultations...... 13
2.0 PROJECT DESCRIPTION...... 13 2.1 Project Activities...... 15 2.1.1 Preparation Phase ...... 15 2.1.2 Construction Phase ...... 16 2.1.2.1 Drilling ...... 16 2.1.2.2 Completions ...... 17 2.1.2.3 Well Tie-ins ...... 18 2.1.2.4 Post construction and clean-up activities ...... 18 2.1.3 Operations Phase ...... 19 2.1.3.1 Air Emissions Profile ...... 20 2.1.4 Decommissioning and Abandonment ...... 20 2.2 Project Schedule ...... 21 2.3 Waste Disposal / Water Use and Disposal...... 22 2.3.1 Water Required For Drilling & Drilling Products ...... 22 2.3.2 Water Usage for Completions...... 22
3.0 ENVIRONMENTAL SETTING ...... 23
4.0 REQUIREMENTS RELATED TO FISH AND WATERWAYS...... 25 4.1 Environmental Features ...... 25 4.2 Water Sources ...... 26 APPENDIX A MAP 1 – CFB Suffield Area Map…………………………………………………..…….26 Map 2 – Existing Shallow Gas Development in CFB Suffield NWA ….……………27 Map 3 – Proposed Shallow Gas Development in CFB Suffield NWA…...………...28
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APPENDIX B – AEUB LICENCING PROCESS…………………………………...………29
BIBLIOGRAPHY…………………………..…………………………………………..………30
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1.0 INTRODUCTION
This document is the project description for the Canadian Forces Base (“CFB”) Suffield National Wildlife Area (“NWA”) Shallow Gas Infill Development Project (the “Project”) proposed by EnCana Corporation (“EnCana”). The Project is designed to extract sweet, shallow gas from the NWA and deliver that gas to market. A project description is provided to assist the Department of National Defence (“DND”), in coordination with the Canadian Environmental Assessment Agency (“Agency”), in determining the level of environmental assessment required under the Canadian Environmental Assessment Act, R.S.C. 1992, c. 37 (“CEAA”) and to provide for the efficient coordination of the environmental assessment process.
1.1 PROJECT OVERVIEW
The Project is a continuation of EnCana’s existing shallow gas infill well development throughout the NWA. Infill drilling is drilling that occurs within the boundaries of an existing developed gas or oil field. The infill drilling that is part of this Project is necessary to efficiently produce the shallow gas reserves within the NWA that have been located by previous drilling programs. The Project is anticipated to fulfill all the infill development necessary in the NWA. Associated with these wells will be pipelines to connect the wells into existing and new infrastructure for delivery to market. In order to minimize the impact on wildlife and wildlife habitat in the NWA, it is anticipated that project construction will occur, for the most part, between October and April, over a three year period.
As a precursor to this project, EnCana conducted a 16 wells per section (“wps”) pilot project in the Riverbank and Middle Sandhills areas of the NWA. The pilot project evaluated the geological and economic suitability of the area for infill drilling. The project confirmed the suitability of the area for infill drilling. AXYS Environmental Consulting Ltd. (“AXYS”) was contracted to complete a post construction vegetation assessment to assess the impact of the pilot project on the vegetation within the pilot project area. The information gained from the pilot project and the AXYS assessment will be utilized to optimize operations in the NWA, to prepare the environmental assessment for the Project and to evaluate cumulative effects in the NWA.
1.1.1 Purpose of the Project
The primary purpose of the Project is to allow EnCana to exercise its rights under, and obtain economic benefits from, the natural gas leases issued to it by the Province of Alberta within the NWA. Additionally, the Project will allow EnCana to exercise the rights assigned to it by the Province of Alberta, as a result of an Agreement between the Government of Canada and the Government of Alberta under which the Government of Alberta was granted the right of access to, entry upon and occupation and use of such portions of the NWA as are required for shallow gas development.
CFB Suffield National Wildlife Area Shallow Gas Infill Development Project 1
By recovering the value of the reserves that EnCana obtained the rights to produce, it can provide a return to its shareholders on the capital invested in the Project. The value of the reserves recovered by the Project will be obtained by developing the opportunity presented by the considerable and growing demand for natural gas and other forms of energy in markets in Canada and the United States. The proximity of the natural gas reserves located within the NWA to existing infrastructure is an important aspect of the Project.
1.1.2 Project Area
CFB Suffield National Wildlife Area Shallow Gas Infill Development Project 2
The CFB Suffield Block is located in the Province of Alberta, north of Medicine Hat in Townships 15 to 19, Ranges three (3) to nine (9) west of the fourth (4th) meridian as shown in Map 1 of Appendix A. The Government of Canada owns the surface of the NWA land. The NWA covers the Eastern side of the Suffield military range and is approximately 200 sections in size (approximately 45,800 hectares (113,170 acres) of land).
On March 11, 1992, the Minister of National Defence and the Minister of the Environment signed a Memorandum of Understanding (MOU) that provided the basis for establishing the NWA on a portion of the CFB Suffield. The NWA was formally created when it was listed in Schedule 1 of the Wildlife Area Regulations, C.R.C., c. 1609, on June 19, 2003. Thereafter, pursuant to Section 4.2 of the Canada Wildlife Act, R.S.C. 1985, c. W-9, the Minister of the Environment delegated the powers conferred under the Canada Wildlife Act, in respect of the NWA to the Minister of National Defence. The authority over the NWA was subsequently subdelegated by the Minister of National Defence to the Base Commander of CFB Suffield.
At the time the NWA was formally created, the Regulations Amending the Wildlife Area Regulations (the “Amending Regulations”) were published in Part 1 of the Canada Gazette. The Regulatory Impact Analysis Statement (“RIAS”) which accompanied the Amending Regulations recognized that the “creation of the NWA will make a substantial contribution to conservation and protection of critical habitat for wildlife including species at risk”. It was recognized that the NWA encompasses 458 km2 of prairie grassland of national significance including sand hills, ancient glacial coulees and the riverbank and breaks along the South Saskatchewan River valley. According to the RIAS, natural grasslands and rivers are among the most endangered ecosystems in prairie Canada. The NWA was formed to provide habitat for over 1,100 catalogued species including the 14 federally listed endangered species and 78 provincially listed “at risk” or “sensitive” species in the NWA as well as to provide prairie habitat for migratory birds contributing to Canada’s international commitments under the Migratory Birds Convention, the North American Waterfowl Management Plan, the North American Bird Conservation Initiative, and the United Nations Convention on Biological Diversity. The creation of the NWA was designed to enhance regional wildlife populations while providing a better understanding of the response of the prairie ecosystem to long-term management and protection of the native habitat. This knowledge is intended to support regional landscape management.
1.1.3 Land Use
The CFB Suffield designated the Suffield Block to be operated by the Canadian Army as a mechanized training area for Canada and Great Britain. Land use on the Block was subdivided in 1971 into three distinct areas: the Military Training Area (MTA), the Defence Research experimental proving grounds (EPG), and the environmentally protected area (EPA) representing approximately 17% of the Base. No military ground training was contemplated in the EPA.
CFB Suffield National Wildlife Area Shallow Gas Infill Development Project 3
The EPA was formally designated as the CFB Suffield NWA in 2003. The area represents an integral component of the CFB Suffield. Although the NWA has been out of bounds for military ground training since 1972, military use of the area includes live fire safety templates in support of military exercises. Current land use of the NWA also includes its role in conserving and protecting critical wildlife habitat and maintaining the ecological integrity of the prairie grassland within its borders. Other land uses within the NWA include safety templates for defence research trials in adjacent areas and cattle grazing. Cattle grazing are subject to a 1976 Memorandum of Understanding between DND and Agriculture and Agri-Food Canada. Grazing occurs only from June to October and is limited to the Southern portion of the NWA. The grazing activity is overseen by the Suffield Grazing Advisory Committee that is comprised of one member from each of the Canadian Wildlife Service, Alberta Public Lands, and Agriculture and Agri-Food Canada. The Committee recommends the amount of grazing to occur based on grass/feed conditions. For safety reasons, there is no public access to the NWA.
Another important land use within the NWA involves shallow natural gas activities. The first shallow gas wells were drilled in the area that would later become the NWA in 1973. In 1975 the Government of Canada, as the owner of the surface of CFB Suffield, and the Government of Alberta, as the owner of the majority of the mines and minerals underlying CFB Suffield, entered into agreements (the “1975 Agreements”) which granted Alberta and its assignees access to CFB Suffield, including the NWA, for the purposes of exploring for, developing and producing oil and natural gas underlying CFB Suffield. In 1999, a partial assignment agreement between Canada and Alberta granted deep rights surface access for oil and gas at CFB Suffield excepting the NWA. As Alberta’s assignee, EnCana and its predecessor companies have engaged in oil and gas activities on CFB Suffield, and shallow natural gas activities within the NWA, since 1975.
As noted in the previous section, the RIAS recognized that the “creation of the NWA will make a substantial contribution to conservation and protection of critical habitat for wildlife including species at risk”. The RIAS also indicated “no major changes in land use are anticipated” and that: “Cattle grazing and shallow gas recovery which operate under existing Memoranda of Agreement (MOAs) will continue, subject to environmental screening protocols identified in respective MOAs controlling those activities and the Wildlife Area Regulations.”
CFB Suffield National Wildlife Area Shallow Gas Infill Development Project 4
The existing MOA for shallow gas recovery referred to in the Regulatory Impact Analysis Statement is contained in the 1975 Agreements. The 1975 Agreements established the Suffield Environmental Advisory Committee (“SEAC”) to provide advice to the Base Commander with respect to environmental aspects of oil and gas activities on CFB Suffield. The SEAC is comprised of three members: one member from EC (Canadian Wildlife Service), one member from Alberta Environment and one member from the Alberta Energy and Utilities Board (“EUB”). To date the SEAC has been involved in, and made recommendations for, the approval of all development and reclamation activities in the NWA. The SEAC also conducts annual inspections of EnCana facilities to ensure that proper mitigation measures have been followed. It is anticipated that SEAC will continue in this role.
Of the 1154 existing wells within the NWA, shown on Map 2 of Appendix A, shallow gas comes from a maximum depth of approximately 650 meters. The low impact techniques utilized to drill these existing wells were developed with input from SEAC and include:
• no leveling or stripping of shallow gas well sites; • suspension of drilling and other activities during unfavorable conditions; and • removal of all fluids (for drilling and completions) from the NWA.
The current well density in the NWA varies from a low of four (4) wps to a maximum of 16 wps. A section is equivalent to one square mile (640 acres). In several areas, the well density has already been increased to 16 wps with the intention of this Project being additional development to a maximum of 16 locations per section.
The existing 1154 wells within the NWA are tied-in to an existing natural gas gathering (pipeline) system. The majority of the existing gas gathering system consists of two (2) inch (50.8 millimeter) individual well tie-ins that are connected to four (4) to eight (8) inch (101 to 203 millimeter) main laterals. The total amount of existing pipelines in the NWA is estimated at 760 kilometers. Since 2001 in the NWA, all two (2) inch (50.8 millimeter) tie-in lines have utilized plastic polyethylene pipe and have been installed using low impact, minimal disturbance plowing techniques.
The history of the NWA reflects the area’s shared land use between military training and research, wildlife conservation, oil and gas development and cattle grazing. For over 30 years, DND has managed the multiple land uses within the NWA in cooperation with the oil and gas industry, cattle ranchers, Defence Research and Development Canada, and various provincial and federal authorities, in particular, Environment Canada.
1.1.4 Nature of Project
The proposed Project consists of four phases: (1) preparation; (2) construction; (3) operations; and (4) decommissioning and abandonment.
CFB Suffield National Wildlife Area Shallow Gas Infill Development Project 5
The preparation phase includes the following activities:
• Pre-field project planning (constraints mapping; desktop database search; planning meeting to discuss project well site, pipeline and access locations) • An environmental assessment will be conducted in the field for each location by an environmental crew (consisting of wildlife specialists, botanists, archeologists (historical resources) other specialists as required (e.g., weeds)), surveyors and construction personnel for each location • An ordinance sweep will be conducted by Suffield Industry Range Control (SIRC)
The largest activity phase but the smallest temporal phase of the project is the construction phase including the initial drilling, completion and tie-in of the wells. It is anticipated that all of the wells proposed will be drilled, completed and tied-in during a three year period. It is expected that approximately one third of the new wells will be drilled, completed and tied-in in each of the three years; with activities primarily occurring between October and April in order to respect environmental constraints and the military training calendar. A conceptual activity schedule will be provided as part of the environmental assessment and the potential impacts assessed on that basis. The project will not require the installation of compression facilities within the NWA. Existing facilities located outside of the NWA are sufficient for the project to be carried out.
During the operations phase, the following activities will occur regularly to ensure that operations are continuing efficiently: well testing, swabbing (if necessary due to water production), well inspections, recompletions and pipeline integrity checks.
It is anticipated that the wells will continue to produce for twenty or more years. When production is no longer economically feasible, the decommissioning and abandonment of both production and pipeline facilities will be undertaken in accordance with the regulatory requirements applicable at that time. Well sites will be reclaimed using the appropriate seed mixes and methods at the time of decommissioning and abandonment in consultation with the DND. Although abandonment practices may change in the future, the current practice is for pipelines to be abandoned in place in order to minimize disturbance to the environment.
CFB Suffield National Wildlife Area Shallow Gas Infill Development Project 6
1.2 PROPONENT INFORMATION
Principle point of contact: Francis L’Henaff, Team Lead; Suffield SBU 421 - 7th Ave SW Calgary, Alberta T2P 2S5 Phone: 403-645-3844 Fax: 403-645-8368 [email protected]
Alternate contacts: Catherine Watson, Environmental Advisor 421 - 7th Ave SW Calgary, Alberta T2P 2S5 Phone: 403-645-5882 Fax: 403-290-7435 [email protected]
Vasile Klaassen, Canadian Plains Region Group Lead 421 - 7th Ave SW Calgary, Alberta T2P 2S5 Phone: 403-645-3831 Fax: 403-290-7435 [email protected]
1.3 REGULATORY OVERVIEW
Natural gas projects in the NWA are regulated by several different agencies and various forms of legislation govern their operations. The Government of Canada owns the surface rights while the Province of Alberta primarily owns the subsurface rights; as such, provincial and federal regulations apply.
1.3.1 Canadian Environmental Assessment Act
Responsible Authority and Federal Authorities
The DND will be the responsible authority for the Project as the Minister of Environment has delegated authority over the NWA to the Minister of National Defence, pursuant to Section 4.2 of the Canada Wildlife Act.
In accordance with the Regulations Respecting the Coordination by Federal Authorities of Environmental Assessment Procedures and Requirements (Federal Coordination Regulations), the Agency, as the Federal Environmental Assessment Coordinator (FEAC), referred the project to other federal agencies. The following federal
CFB Suffield National Wildlife Area Shallow Gas Infill Development Project 7
departments have self identified as Federal Authorities (FAs) and will provide specialist advice to the assessment as follows:
• Agriculture and Agri-Food Canada; • Environment Canada; • Fisheries and Oceans Canada; • Health Canada. • Natural Resources Canada; and • Parks Canada.
Provincial Involvement
In accordance with the Canada-Alberta Agreement for Environmental Assessment Cooperation (the Agreement), the FEAC also referred the project to Alberta Environment (AENV), the Alberta Energy and Utilities Board (AEUB) and Alberta Sustainable Resources Development (ASRD). AENV’s review of the project determined that no provincial environmental assessment is required and AENV has no regulatory interest under the Environmental Protection and Enhancement Act (EPEA) or the Water Act. Thus, AENV does not wish to participate in a cooperative environmental assessment at this time.
However, the AEUB does have a regulatory interest in oil and gas development at CFB Suffield, as Alberta retains the Crown mineral rights. Public issues and concerns raised during the federal environmental assessment of the project may have direct relevance to the AEUB regulatory process. The AEUB will participate in the federal environmental assessment process pursuant Appendix 3 of the Agreement. Additionally, the Wildlife Management Branch of ASRD has also expressed an interest to participate in the assessment.
Overview of the Environmental Assessment Process
Under subsection 5(1) of the CEAA, a federal environmental assessment may be required (“triggered”) when, in respect of a project, a federal authority:
• Is the proponent; • Makes or authorizes payment or any other form of financial assistance to the proponent; • Sells, leases or otherwise disposes of lands; or • Issues a permit, or license or other form of approval pursuant to a statutory or regulatory provision referred to in the Law List Regulations of the CEAA.
In the case of the Project, a federal approval (permit) is required under the Law List Regulations, which triggers the need for a federal environmental assessment under CEAA. Section 3 of the Wildlife Area Regulations prohibits the carrying on of any commercial or industrial activity unless the activity is done under, and in accordance with, a permit issued by the Minister pursuant to Section 4. Section 4 of the Wildlife
CFB Suffield National Wildlife Area Shallow Gas Infill Development Project 8
Area Regulations states that the Minister may, on application, issue a permit to any person authorizing that person to carry on an activity described in Section 3 provided that activity will not interfere with the conservation of wildlife. Therefore, EnCana requires a permit under Section 4 of the Wildlife Area Regulations to carry out the Project.
Pursuant to section 2(c) of the Comprehensive Study List Regulations, the Project is subject to a comprehensive study as the Project involves the construction of a gas pipeline in a wildlife area. The Minister of the Environment must determine the appropriate track for the Project (whether the environmental assessment should continue as a comprehensive study or whether the Project should be referred to mediation or a review panel). To make the tracking decision, the following process is utilized. Firstly, In accordance with subsection 21(1) of the CEAA, DND must ensure that public consultation on the following issues is carried out prior to the tracking decision: • the proposed scope of the project for the environmental assessment; • the proposed factors to be considered in the environmental assessment; • the proposed scope of those factors; and • the ability of the comprehensive study to address issues relating to the project.
Secondly, pursuant to subsection 21(2) of the CEAA, the DND, as soon as it is of the opinion that it has sufficient information to do so, must submit a report to the Minister of the Environment, which includes the following:
• the scope of the project, the factors to be considered in the environmental assessment and the scope of those factors; • public concerns in relation to the project; • the ability of the comprehensive study process to address issues relating to the project; and • the DND must also recommend whether the environmental assessment should be continued by means of a comprehensive study, or whether the project should be referred to a mediator or review panel.
After considering the report and recommendation, the Minister of the Environment must decide whether to refer the project back to the DND to continue with the comprehensive study process, or refer the project to a mediator or review panel. If the Minister of the Environment decides that the project should continue as a comprehensive study, the project cannot be referred to a mediator or review panel at a later date. Whether the environmental assessment proceeds by means of a comprehensive study or is referred to a review panel, participant funding will be made available by the Agency to facilitate public participation.
If after considering the report and recommendation, the Minister of the Environment refers the project to a mediator or review panel, the project will no longer be subject to a comprehensive study under the CEAA. The Minister of the Environment, after consulting the DND and other appropriate parties, will set the terms of reference for the review, and appoint the mediator or review panel members.
CFB Suffield National Wildlife Area Shallow Gas Infill Development Project 9
If the Minister of the Environment determines that the environmental assessment will continue as a comprehensive study, an environmental assessment will be undertaken and a Comprehensive Study Report (CSR) will be prepared and submitted to the Minister of the Environment and to the Agency. The DND must ensure that there are opportunities for public participation during the comprehensive study process.
Following submission of the CSR, the Agency will invite the public to comment on the report prior to the Minister of the Environment making his determination. The Minister of the Environment may request additional information or require that public concerns be further addressed before issuing the environmental assessment decision statement. Once the environmental assessment decision statement is issued, the Minister of the Environment will refer the project back to the DND for action.
1.3.2 Other Federal Legislation, Regulations and Policies CFB Suffield, including the NWA, is situated within federal lands. In addition to complying with relevant provincial requirements (see section 1.3.3 below), EnCana must comply with all relevant federal regulatory requirements. Applicable federal regulatory requirements include provisions under the Species at Risk Act, the Migratory Birds Convention Act, and the Fisheries Act. In addition, the Federal Policy on Wetland Conservation also applies. Species at Risk Act The Species at Risk Act (SARA) prohibits the killing, harming, harassment, capture or take of listed species and the destruction of their residence and critical habitat, except under the authority of a permit. The prohibitions apply to those species listed under the Act as Extirpated, Endangered or Threatened. The permitting authority rests with Environment Canada, Fisheries and Oceans Canada and Parks Canada, and cannot be delegated. Applicants for permits must meet specific criteria as outlined in the Act. SARA also has requirements for notification of the competent Minister or Ministers. Section 79 of SARA states that:
1) Every person who is required by or under an Act of Parliament to ensure that an assessment of the environmental effects of a project is conducted must, without delay, notify the competent minister or ministers in writing of the project if it is likely to affect a listed wildlife species or its critical habitat.
2) The person must identify the adverse effects of the project on the listed wildlife species and its critical habitat and, if the project is carried out, must ensure that measures are taken to avoid or lessen those effects and to monitor them. The measures must be taken in a way that is consistent with any applicable recovery strategy and action plans.
Given the known occurrence of SARA listed species, as well as provincially listed species, and the ecological integrity of the mixed prairie found within the NWA, it will be necessary to identify the potential impacts to the biophysical environment and develop suitable mitigation measures during the environmental assessment. EnCana is
CFB Suffield National Wildlife Area Shallow Gas Infill Development Project 10
committed to ensuring the environmental assessment process is carried out in accordance with the terms of reference to be developed. As the NWA is a wildlife area, EnCana understands that a greater level of detail will be required during the environmental assessment process. Migratory Birds Convention Act The regulations under the Migratory Birds Convention Act (MBCA) prohibit the disturbance, destruction or taking of a nest, egg or nest shelter of a migratory bird and the deposit of oil, oily wastes or any other substances harmful to migratory birds in any waters or any areas frequented by migratory birds. Migratory birds are known to occur and nest within the boundaries of the NWA; therefore, this will be a consideration in the development of mitigation measures.
1.1.1.1.1.1.1.1 Fisheries Act Section 35 of the Fisheries Act is the key habitat protection provision that prohibits the harmful alteration, disruption or destruction (HADD) of fish habitat without an authorization from the Minister or through regulations under the Act. Additionally, Section 36(3) of the Fisheries Act identifies pollution prevention requirements. Specifically the Act states that: “no person shall deposit or permit the deposit of a deleterious substance of any type in water frequented by fish or in any place under any conditions where the deleterious substance or any deleterious substance that results from the deposit of the deleterious substance may enter any such water.” This provision would apply to portions of the project and project activities that border the South Saskatchewan River.
During this project, EnCana does not propose to construct any facilities, well sites or pipelines or bridges across or within the South Saskatchewan River or within any fish- bearing streams.
1.1.1.1.1.1.1.2 Federal Policy on Wetland Conservation The proponent is expected to comply with the Federal Policy on Wetland Conservation by taking steps to avoid, minimize or remediate impacts to wetlands on CFB Suffield, including the NWA. Through this policy the Federal Government is expected to ensure a number of principles are followed, including no net loss of wetland functions on all federal lands and waters by reducing all the effects of development related to these wetlands, and enhancement and rehabilitation of wetlands in areas where there is continuing loss or degradation of wetlands or their function.
1.3.3 Provincial Regulatory Process
The Province of Alberta owns most of the subsurface rights in the NWA and has issued mineral leases to EnCana. In Alberta, energy activities are primarily regulated under the Acts and Regulations administered by the EUB, AENV, and ASRD. As a result, all wells drilled, and pipelines installed, as part of the Project will be licensed by the EUB. Additionally, all drilling, completion, and tie-in practices are regulated by the EUB, as well as the ongoing operations of the wells.
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EnCana will comply with the following EUB guidance as appropriate including: EUB Directive 056: Energy Development Applications and Schedules (formerly Guide 56: “Energy Development Applications and Schedules”). Directive 056 outlines the primary requirements for the pipeline and well licensing process. Section 6 and Schedule 3 of Directive 056 details the pipeline license application process, while Section 7 and Schedule 4 detail the well license application process. Directive 056 requires that all well sites located within the required 100 meter setback distance from well centre to a wetland must have the appropriate mitigation in place. Directive 056 also establishes rules regarding:
• emergency response planning; • groundwater protection (based on Guide 8: Surface Casing Depth Minimum Requirements); • setback requirements; and • requirements for acceptable measures to protect the environment.
Several key EUB and AENV requirements, related to the project, are listed below:
- EUB Information Letter 82-14: A Summary of Policies and Procedures Respecting Well Spacing Provisions and Means to Vary Them; - January 2002, Petroleum Industry Activity in Native Prairie and Parkland Areas Guidelines for Minimizing Surface Disturbance; - EUB Guide 50: Drilling Waste Management; - EUB Guide 58: Oilfield Waste Management Requirements for the Upstream Petroleum Industry; - EUB Interim Directive 2000-03: Harmonization of Waste Management - EUB IL 2002-01: “Principles for Minimizing Surface Disturbance in Native Prairie and Parkland Areas”; - Alberta Sustainable Resource Development (ASRD) Industry Directive 2002-01 - Slope and Break Setback Guidelines; - Alberta Environment R&R/03-2: “Siting an Upstream Oil and Gas Site in an Environmentally Sensitive Area on Private Land: Guidance for Private Land”; and, - EUB: Recommended Land Use Guidelines for the Protection of Wildlife Species and Habitat within Grassland and Parkland Natural Regions of Alberta.
To ensure compliance with the numerous EUB Directives, Guidelines, Information Letters and provincial acts and Regulations, the EUB utilizes an auditing process. For example, within Directive 056, this auditing process is detailed in Section 6.10 and 7.10. If an audit indicates that a company is not in compliance with Directive 56, then the EUB’s enforcement process, detailed in EUB IL 99-04, will be engaged.
To ensure compliance with all regulatory requirements and to ensure conformance with EnCana’s best practices (including the Environmental Protection Plan (EPP)) and other commitments made during the environmental assessment and approval process, EnCana will continue to implement its existing internal audit program during all phases of construction and throughout the life of the Project. In addition, EnCana is subject to
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periodic regulatory EUB/Alberta Environment audits. Additional information on these audit programs and the standards used in these programs will be provided in the environmental assessment report.
EnCana will develop a project specific EPP as part of the environmental assessment process. The EPP will include EnCana’s Access Management Plan. EnCana is committed to ensure its development program includes appropriate measures to effectively identify, monitor, and adaptively manage any effects of the Project.
EnCana proposes to continue to withdraw water from the South Saskatchewan River and dugouts and water wells to meet the water requirements of the Project. The new sources of water will be licensed by Alberta Environment. Alberta Environment typically requires that EnCana appropriately screen water intake pipes and limit the velocity of flow at intake.
1.4 PUBLIC CONSULTATIONS
Throughout the course of the environmental assessment, there will be a number of opportunities for public involvement. In the initial stage, pursuant to subsection 21(1) of the CEAA, the DND will ensure public consultation is carried out with respect to:
• the proposed scope of the project for the purposes of the environmental assessment; • the factors proposed to be considered in its assessment; • the proposed scope of those factors; and • the ability of the comprehensive study to address issues relating to the project.
Pursuant to section 21.2 of the CEAA, the DND will also ensure that the public is provided with an opportunity to participate in the comprehensive study. Pursuant to subsection 22(1) of the CEAA, after receiving the comprehensive study report in respect of the Project, the Agency will ensure that the public has an opportunity to comment on the conclusions, recommendations and any other aspect of the comprehensive study report.
As the project proceeds through the environmental assessment process, EnCana will initiate and conduct consultations with external stakeholders as appropriate in cooperation with the Agency and the DND so as to facilitate meaningful public participation. EnCana will conduct open houses during the environmental assessment to ensure that the public is aware of all aspects of the Project.
2.0 PROJECT DESCRIPTION
The proposed Project encompasses all of the anticipated future infill locations that will be required to adequately recover the shallow gas reserves within the NWA. It is expected that a maximum of 16 wells per section (wps) will be required in several areas of the NWA to adequately capture the gas in place. Up to 1275 new infill wells may be
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required at various locations throughout the NWA. The Project does not involve additional drilling activities on existing wells. The proposed locations with some contingent well locations are shown in Map 3 of Appendix A. The exact locations may vary when actually surveyed due to mitigation measures related to terrain or other factors. The Project will employ the low impact development techniques described above under section 1.1.4, and for which a more detailed description will be provided in the environmental assessment report. Mitigation techniques will also be incorporated into the Project’s EPP.
The project schedule envisioned for construction activities is to work between the lock out periods such as the military imposed lock out, the snake migration and migratory birds and their breeding periods. Generally, the lock out period is from mid-March to mid-October depending on the species involved and weather constraints. For example, the snake migration lock out period is typically from May to October. The Burrowing Owl lock out period is typically from early April to mid-October.
It is currently envisioned that the development will commence at the south end of the NWA during the first year with subsequent phases in the middle and northern portions of the NWA in subsequent years. Further, it is anticipated that only four (4) to five (5) drilling rigs will be required at any given time during drilling, and such rigs will use low impact technology. A drilling rig move requires approximately five (5) loads to move with bed trucks, one drilling rig, water truck and vacuum truck. It is anticipated that a maximum two (2) to four (4) completions crews and two (2) to (3) tie-in crews will be active in the NWA at any one time. A fracturing operation typically requires 10 to 15 trucks on location. This anticipated project schedule may be modified based upon the outcome of the environmental assessment process.
Associated with these wells are approximately one hundred and eighty (180) kilometers of two (2) inch (50.8 millimeter) high-density polyethylene plastic pipe (“HDPE”) to tie the wells into an existing pipeline. All two (2) inch (50.8 millimeter) pipelines will be constructed using minimal disturbance plowing techniques. The project scope also includes the installation of approximately forty (40) kilometers of six (6) or eight (8) inch (152.4 to 203.2 millimeter) steel pipe to effectively transport the gas to the compressor stations located outside of the NWA. EnCana proposes to install six (6) and eight (8) inch steel pipelines using conventional ditching techniques (e.g. wheel ditcher). Conventional ditching techniques will also be utilized to install two (2) inch HDPE pipe in the limited areas where plowing is not possible due to rocky terrain. Applicable pipeline installation techniques will be evaluated during the environmental assessment process and will be discussed in the EPP.
The only above ground facilities envisioned for the Project in the NWA (outside of the wellheads) will be pig catchers and gas meters. Additional above ground gas meters and pig catchers for each gas battery will be installed if a back end tie-in loop is required for that battery. Pigging facilities (catchers and launchers) may be required for the additional pipelines associated with the Project. At 16 WPS density, gas batteries can
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service between 96 and 128 wells. There is an existing buried water separation facility located at 16-23-17-5W4M, outside of the NWA, which the Project facilities will access.
Additional sumps may be required outside of the NWA if drilling occurs during the times when land spraying while drilling (LWD) is not possible. LWD is generally a preferred method as it returns the water to the water system while providing additional nutrients to the soil. It is not anticipated that additional water disposal wells will be required. Existing water disposal wells are located on CFB Suffield, outside of the NWA.
All compressor facilities are located outside the NWA. It will not be necessary to construct any new compressor facilities for the project as there is currently enough compression installed on the existing system to produce the additional NWA wells. As the reservoir pressure depletes, compression will have to be modified at existing locations outside the NWA to accommodate the changes in gathering system pressure and flow rates to optimize recovery of natural gas.
During the life of a reservoir, the pressure is reduced and adjustments to compression are required. This normal maintenance practice is used to maximize the recovery from the reservoir and will be carried out regardless of reservoir location, and is independent of the NWA infill drilling project.
2.1 PROJECT ACTIVITIES
It is anticipated that the majority of preparation activities will occur from spring to fall to ensure that activities are appropriately located based on the identification of environmental constraints. During each year of the three year program, drilling will commence in the late fall and continue through the winter (October to April). EnCana’s current plan is to drill between 300 and 400 wells each year for three years. Completion activities will also be carried out in late fall and winter (October to April). Well tie in activity will either occur during this same time period or during dry conditions throughout the year. This preliminary schedule is designed to avoid conflicts with species at risk (including rare plants). Environmental assessments (including field work) and pre- planning work will be completed during the summer to ensure all activities and facilities are appropriately located. This anticipated project schedule may be modified based upon the outcome of the environmental assessment process. Further, it is anticipated that between two and four drilling rigs will be required at any given time during drilling, and that such rigs will use low impact technology.
2.1.1 Preparation Phase
Several steps occur prior to the construction of the project. One of the key steps is the initial planning activities associated with the identification of potential project locations, pipeline routing and identification of access routes.
EnCana also utilizes its constraint mapping tool to:
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• supplement preliminary desktop information that is gathered from other database sources (e.g., provincial databases) • select preliminary routing • identify potential locations for well sites and their associated tie-ins, and • determine preliminary access routes.
The constraints mapping tool consists of an environmental database that is gathered from different provincial and federal sources, as well as information gathered during desktop studies or additional fieldwork collected for other EnCana projects at CFB Suffield. This process allows a screening level desktop assessment and is followed by a planning meeting prior to going to the field.
Once the preliminary locations are chosen and the potential environmental issues are identified, a field crew consisting of environmental specialists (e.g. wildlife, archeologists, botanists, etc.), surveyors and construction staff will go to each of the locations to ensure that the location is sited in the optimum location prior to construction taking place. This process also reduces the number of visits and the number of crews visiting each of the sites. Mitigation is developed for any potential issues identified in the field, at each location, prior to construction taking place.
Also during the preparation phase, Suffield Industry Range Control (“SIRC”) will conduct a site sweep for unexploded ordinance prior to any activity taking place in the field.
2.1.2 Construction Phase
There are three main elements of the Project’s construction phase: (1) drilling; (2) completions; and (3) tie-in of new wells into the existing gathering system via HDPE pipelines. It is anticipated that all of the wells proposed will be drilled, completed and tied-in during a three (3) year period. The largest activity phase of the project is the initial drilling, completion and tie-in of the wells.
2.1.2.1 Drilling
As mentioned in the preparation phase, the location of the well or pipeline ROW may be adjusted as necessary to accommodate terrain, wildlife, and other environmental concerns. A project specific EPP is developed for all EnCana projects. It is important to note that an EPP will be developed for this Project for all phases of construction based on the issues identified during the environmental assessment process to ensure implementation of the follow up and monitoring required and to implement an adaptive management approach to the development.
After the drilling location is finalized, access to the well site is determined and marked. To minimize the disturbance to the prairie environment, roads are not constructed to the locations. An access route is marked to allow all traffic to follow only one path to the well site thus avoiding multiple paths to the location. Whenever possible, EnCana will use
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existing access in the NWA. EnCana will be developing an access management plan as part of the environmental assessment of the Project.
All wells will be drilled using minimal disturbance techniques to minimize soil disturbance, preserve the soil regime and maintain the existing seed bed. Typically, no topsoil is removed on the lease during drilling; with the only disturbance being the wellhead itself. These minimal disturbance techniques will be described as part of the environmental assessment process.
To drill the well, a small conductor rig is moved in. The conductor rig drills until a seven (7) inch (177.8 millimeter) conductor pipe can be cemented in place at approximately 27 meters. After the conductor pipe has been set, the drilling rig and associated equipment will move onto the lease (approximately five (5) truck loads). The drilling rigs used to drill the shallow gas wells will be either “single rigs” or coil tubing rigs, which have a continuous coil of 2 3/8 inch (60.3 millimeter) tubing that serves as the drill pipe. Such rigs are much smaller than conventional deeper well rigs and cause significantly less disturbances to the area due to the low impact technology used. It takes 14 to 20 hours to drill each well to the total depth of 450 to 650 meters depending on location. A string of 4.5 inch (114.3 millimeter) casing is then run in the total length of the hole and cemented in place. All drill cuttings and drilling fluid (water) are collected into onsite tanks while drilling, and removed from the NWA for disposal according to EnCana’s Waste Disposal Policy and provincial regulations. Lastly, the wellhead is installed.
2.1.2.2 Completions
The completions stage follows drilling and allows the gas encountered during drilling to be produced.
After the well is drilled, the following steps are taken to complete the well:
1. a well logging truck and crew run an electronic well log from the total depth to surface; 2. the well is pressure tested to ensure casing integrity; 3. a swabbing unit, typically a five (5) ton truck, removes the water that is in the wellbore and collects it in a truck mounted tank for disposal outside the NWA; 4. a perforating unit places perforations in the casing at the appropriate depths as determined by an interpretation of the well log; 5. a blowback tank (truck mounted tank) is placed on location for the duration of the fracturing;
6. the well is fracture stimulated. This activity pumps sand and a gelled water/CO2 fluid mixture down the wellbore at high pressure. The pressure forces the formations downhole to fracture and the sand fills these fractures. This operation allows the wells to flow at commercial rates. The fracturing operation requires 10 to 15 trucks on location and typically takes four (4) to six (6) hours.
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7. the well is flowed back to the blowback tank to remove as much of the water that was used in the “frac” process as possible. Included in the water that is flowed back, there are typically small amounts of sand. The recovered fluid and sand are contained in the blowback tanks are taken off site, out of the NWA, and recycled. 8. using a small coil tubing unit, the well is cleaned out to remove any more fluid; and, 9. the well is shut-in until it is tied into the gathering system.
2.1.2.3 Well Tie-ins
The wells will be tied into the existing or new gathering system using two (2) inch (50.8 millimeter) HDPE pipe. All HDPE pipelines will be buried using low impact plowing equipment. The HDPE pipe is a continuous pipe brought to location on a large roll. Using specialized plowing equipment the roll of pipe is plowed into the ground at a depth of 1.5 meters (five (5) feet). This technique results in minimal disturbance to the ground. In addition, the width of the pipeline ROW is kept as narrow as possible. The total pipeline length used will depend on the proximity of the existing gathering system to the wellbore. Lengths of tie-ins are typically between 200 and 400 meters. Once the well is tied in, the well is brought onstream.
In certain areas four (4) to eight (8) inch (101.3 to 203.2 millimeter) diameter steel pipelines may be required to allow for effective transport of the gas to an existing gathering system. These pipelines are expected to average three (3) to six (6) km in length and will be installed using conventional ditching techniques. Potential areas requiring conventional ditching techniques will be identified during the environmental assessment.
Once the pipeline is ditched, either using conventional ditching techniques (i.e. steel) or low impact ploughing equipment (i.e. HDPE pipe), post construction reclamation activities will take place. Post construction and clean-up activities include re-contouring (if required), re-seeding and post construction monitoring. Post construction and clean- up and monitoring activities associated with conventional ditching methods and low impact ploughing will be evaluated and discussed in further detail in the environmental assessment and in the EPP.
If bell holes are required (e.g. road crossings) topsoil and subsoil are stripped and stored separately in the immediate area. Once construction is complete, the bell holes are immediately backfilled using native subsoil and topsoil. The site is then recontoured and reseeded. This process also will be discussed in further detail in the environmental assessment and in the EPP.
2.1.2.4 Post construction and clean-up activities
Post construction and clean-up activities associated with the wells and pipelines will be evaluated in both the environmental assessment and in consultation with the DND. The
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environmental assessment will determine the requirements for actions such as exclusion fencing, weed control and erosion control measures.
It is anticipated that, for the proposed Project in the NWA, no borrow pits for gravel will be required for any construction remediation, reclamation, operational, decommissioning or abandonment activities during the lifetime of the Project. Since existing access will be utilized for the Project, no roads will be built for this Project, therefore, the use of gravel (and construction, maintenance and reclamation) from borrow pits in the NWA will not be necessary. In the unlikely event that gravel may be required to improve the road conditions, gravel could be brought in from outside the NWA – but this activity is not anticipated to be required.
Additional soil (from a borrow pit or stockpile) may be required for reclamation of ROWs, lease areas and access roads during the reclamation, remediation maintenance or abandonment processes. It is important to note that well leases and pipeline ROWs will be constructed using minimal disturbance and no-strip techniques therefore, it is not anticipated that any additional fill or soil material will be required.
2.1.3 Operations Phase
The main activities conducted in the operations phase are:
1. Well testing – Wells are regularly required to be stabilized and evaluated. Well site visits average one visit per month in the first year of production. These visits would involve the use of a three quarter ton truck and typically one truck would visit approximately 15 to 20 wells in a day. For future years, a yearly test of the well’s performance is required as per EUB regulations.
2. Swabbing - Well site visits after the first year of production would average one visit per year if no water is produced in the well bore. In the event that water is produced at any time in the wellbore, well site visits would average four visits per year. If there were water produced then well site visits would involve the use of a swabbing unit and tank truck or a coil tubing unit and blowback tank. The water that has produced into the wellbore would be removed. All water that is “swabbed” out of the wells would be contained in a tank truck and disposed of outside the NWA. It is not expected that the management of produced water will require any additional infrastructure such as permanent tanks, berms or methanol tanks.
3. Refracture – For some wells it may be necessary to refracture the producing formation. This activity is essentially a repeat of the completion process described above. A refracture is not typically required, but if required, would take place 15 to 25 years after the initial completion.
4. Well Inspections and Pipeline Integrity Checks - On a yearly basis the pipelines and wellheads are inspected for leaks and/or damage. Any leaks detected would
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be immediately repaired pursuant to EUB regulations. Additionally, EnCana periodically monitors its pipeline ROWs during the operational phase. While performing their operational activities, operators, trained to identify such issues, also check for issues such as subsidence, erosion and weeds.
As road and lease conditions are one of the primary factors for planning and scheduling operational activities, EnCana’s practice is to defer operational site visits and construction activities when conditions are excessively wet. The intent of this practice is to prevent the rutting of lease sites and undeveloped lease access routes.
2.1.3.1 Air Emissions Profile
The potential sources of air emissions associated with this Project include: vehicles (exhaust and dust); completion clean-up (short term venting); swabbing operations (tank vent gasses) and fugitive emissions. The extent and impact of air emissions associated with the Project will be detailed in the Environmental Assessment Report.
2.1.4 Decommissioning and Abandonment
It is expected that ongoing operations and subsequent abandonment of the wells and pipelines will occur over the next 20 to 40 years. Decommissioning and abandonment of both production and pipeline facilities will be undertaken at the end of the wells’ life in accordance with the regulatory requirements applicable at the time of such activities. Although regulatory requirements may change prior to the time of abandonment, current practices would see the wellbores plugged back with cement and bridge plugs and the wellhead removed below grade and buried. The leases will be reclaimed using appropriate seed mixes determined after consultation with the DND, EC and AENV. The pipelines will be filled with inhibited fluid, cut off below grade and abandoned in place. The Environmental Assessment Report will consider alternatives means of decommissioning and abandoning the facilities associated with the Project.
Under the Alberta Environmental Protection and Enhancement Act (“AEPEA”), operators are required to employ effective conservation and reclamation measures and to ensure that the disturbed land is reclaimed to meet the goal of equivalent land capability. Equivalent land capability means that the ability of the land to support various land uses after conservation and reclamation is similar to the ability that existed prior to an activity being conducted on the land.
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2.2 PROJECT SCHEDULE
The project schedule envisioned for the Project is to work around environmental constraints such as the snake migration and migratory birds breeding periods. The project schedule is designed to avoid conflicts where possible with species at risk (including rare plants). The environmental constraints are primarily in the summer months thus drilling and completions will occur in the late fall and continue through the winter (October to April) with well tie in activity happening in either this same time period or during dry conditions throughout the year. Environmental overviews and pre-planning work will be completed from spring to fall to ensure activities are appropriately located. The project schedule may be modified based upon the outcome of the environmental assessment process.
Table 1, below, provides examples of types of environmental constraints that will be considered in determining the appropriate timing for activities:
Table 1: Environmental Constraints
ISSUE CONSTRAINTS Wildlife: Birds Migratory species returning to breeding grounds (spring) and overwintering grounds (fall); seasonal breeding activities (e.g. leks in spring and in fall); nesting activities (e.g. multiple broods); different activities for rearing young or different lifecycle requirements (e.g. roosting areas may be different than feeding areas for Burrowing Owls Mammals Seasonal requirements during winter range (e.g. winter activity and hibernation requirements for Ord’s Kangaroo Rats; seasonal yarding requirements for ungulates, etc.) and other timing/seasonal constraints associated with breeding periods, having young and rearing (e.g. ungulates rearing young verses calving grounds, Swift Fox denning, etc.) Reptiles and Amphibians Migration or seasonal travel to hibernacula/spawning and breeding grounds; moisture/ ecological requirements for amphibians for breeding, hibernation (e.g., great plains toads; prairie rattlesnake) Rare plants Timing of annual vs. bi-annual flowering species; and early vs. late flowering plants Wet areas /wetlands /South Migratory, breeding or seasonal utilization of the Saskatchewan River wet areas depending on type of water.
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2.3 WASTE DISPOSAL / WATER USE AND DISPOSAL
EnCana will follow its Waste Disposal Policy and ensure that all produced water and associated waste products are disposed of in accordance with provincial and federal requirements. The most common waste product is produced water; however, all waste will be dealt with as is appropriate. The exact procedures to be utilized for this Project will be determined during the environmental assessment process.
2.3.1 Water Required For Drilling & Drilling Products
Each well requires approximately 70m3 of water to be used. The water necessary for drilling is transported to the drill-site via a truck-mounted tank. Approximately 80 percent, or 56m3, of the water used to drill a well is captured. This 56m3 of water, captured during the drilling process, is either returned to the water system via land spraying (“LWD”) or via disposal in sumps located outside the NWA.
Regardless of whether an LWD process or sump disposal method is used, a water recycling process is employed. Where an LWD process is used approximately 12m3 of water is captured via the recycling process and is used to drill the next well in the program. This process decreases the “new” water requirement for the “next well” to 58m3. Where LWD is not employed, water recovered from the drilling process is recycled until it becomes too dense for use in the next well. The recycling process associated with sump disposal allows approximately 25m3 of water from each well to be re-used.
Currently, whether LWD on CFB Suffield is allowed is determined, on a yearly basis, by the AEUB. At this time, LWD is not permitted inside of the NWA. The drilling cuttings and fluids from the drilling of NWA wells are contained in tanks and disposed of outside the NWA using LWD or remote sumps.
2.3.2 Water Usage for Completions
Based on previous operations in the NWA, each well will require 110 m³ of fluid for well completions of which approximately 40% is recovered. The recovered water is transferred to a remote sump where fluid and solids are separated. During summer operations, the fluid is reused as a drilling fluid and the solids are sent to a provincially approved reclamation site. In the winter, all fluid is sent to a water disposal well and the solids are sent to a provincially approved reclamation site.
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2.4 MALFUNCTIONS AND ACCIDENTS
EnCana has an emergency response plan (“ERP”) in place in the event of an accident, malfunction or well blow out. This ERP includes plans pertaining to both the initial construction phase as well as the ongoing operational phase.
In addition, EnCana inspects all wellheads and pipelines on an annual basis. As required by EnCana procedures, any leaks detected at the wellheads or along the pipeline right of ways are repaired immediately.
3.0 ENVIRONMENTAL SETTING
The NWA encompasses 458 km2 of prairie grassland blanketing landscapes including sand hills, ancient glacial coulees, and the riverbank and breaks along the South Saskatchewan River valley. The western portion of the base is found in the Rainy Hills Upland physiographic district; comprised of hummocky and undulating moraine materials. The eastern portion of the base is found in the Cavendish Plain district. This area is comprised of undulating, rapidly draining glaciofluvial deposits. The Schuler Upland district is found immediately adjacent to the South Saskatchewan River in the southeast corner of the base; this area is comprised of hummocky and undulating till deposits (Pettapiece, 1986). The NWA is the most topographically diverse area of the Suffield Block. This is attributed to the sand hills area, the melt water channels or depressions, numerous ravines and highlands, and the South Saskatchewan River valley. From an ecological perspective, the area is found within the Dry Mixedgrass Subregion of the Grasslands Natural Region of Alberta (Alberta Environmental Protection, 1998). [Modal sites within this sub-region are characterized by spear grass – blue grama grass (Stipa spp. – Bouteloua gracilis) on Brown Chernozemic soils (Strong and Leggatt, 1992]. The “A” horizon is on the average 10 centimeter thick, with two (2) to three (3) percent organic matter (Pettapiece and Kjearsgaard, 1986).
The landscape within the NWA is dominated by 3 broad physiographic units, the Eastern Alberta Uplands, the Eastern Alberta Plain, and the South Saskatchewan River Valley (Pettapiece 1986 and Strong 1992). The terrain associated with the Eastern Alberta Uplands is regionally characterized as hummocky to rolling. Locally, surface relief is generally limited to a maximum of 30 m but more typically is 10 m. This physiographic unit is the second most common landscape in southern Alberta and represents approximately one quarter of the land within the Dry Mixed Grass Ecoregion. The Eastern Alberta Plain tends to have relatively level- to-undulating topography and occurs only in the southern one-fifth of the study area. The South Saskatchewan River Valley occurs along most of the eastern side of the study area. This physiographic unit includes steep-sided, often poorly vegetated, valley walls; discontinuous terraces that range from current-to-early, post-glacial age; and the present day South Saskatchewan River. Relief within the valley ranges up to about 150 m.
The origin of the surficial deposits on upland sites in the study area tends to be complex. Based on maps prepared by Berg and McPherson (1972) and Shetsen
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(1987), air-photo interpretation and field observations, the uplands of the study area appear to be dominated by surficial materials derived from glacio-fluvial and eolian deposition and erosion processes, and moraine deposited by glacial ice (Adams et al. 1997).
Morainal deposits probably once covered the entire study area, but currently are limited to elevations above 700 m in the southern half of the study area. These materials tend to have a surface texture ranging from sandy loam to loam, with a loam-to-clay loam subsurface texture. It appears that during deglaciation and after the deposition of moraine, a layer of sandy textured materials was deposited over low elevational lands. This material and the water that transported it probably originated from the disintegration of stagnant glacial ice located to the west and northwest of the study area. The pre-existing morainal plain was partially eroded both before and during the deposition of outwash (Adams et al. 1997).
The zonal soils of the Dry Mixed Grass Ecoregion are Brown Chernozems. These soils typically develop in semi-arid steppe environments. Two broad types of soils dominate upland sites in the NWA: Orthic and Calcareous Brown Chernozems, and Orthic Regosol subgroups.
The vegetation cover of the NWA consists of 28 types representing 29 plant community- types recognized to date (Adams et al. 1997). The 28 cover types occur within 4 broad types of vegetation: grassland, wetlands, deciduous shrub and deciduous trees. The area of these types varies significantly between the North and South blocks of the NWA; the former supporting a greater proportion of woody vegetation compared with the South Block, which has more extensive tracts of herbaceous-dominated grassland. The proportion of woody cover in the vegetation correlates with the occurrence of sandy parent material and, similarly, with the protected slopes of ravine and dune complexes.
Grasslands are the dominant cover over the entire NWA. Wetlands and tree-dominated landscapes comprise less than 1% of the NWA, shrub dominant landscapes comprise less than 13%, shrub-grasslands: 14%, grassland-shrubs: 32%, grasslands: 38%, and barren areas: 2%.
Ten comprehensive reports documenting ecological land classes and vegetation cover, vascular plant flora, wetlands, ungulates, birds, small mammals, raptors, herpetiles, carnivores, and arthropods were prepared during the mid 1990s (Adams et al. 1997, Macdonald 1997, Adams et al. 1998, Banasch and Barry 1998, Dale et al. 1999, Didiuk 1999, Finnamore and Buckle 1999, Carbyn et al. 1999, and Reynolds et al. 1999.) The wildlife inventory was carried out to support management of the proposed NWA and to provide a baseline for evaluating the environment.
The grasslands, sand hills, river breaks and wetlands are habitat to a number of plants, mammals, birds, reptiles, amphibians and insects currently exceeding 1,100 known species, 14 of which are listed in the Species at Risk Act; Schedule 1. Examples of species at risk include the Swift Fox, Ord’s Kangaroo Rat and the Burrowing Owl. In
CFB Suffield National Wildlife Area Shallow Gas Infill Development Project 24
addition, 78 species of animals and plants that are listed by the Status of Alberta Wildlife 2000 as “at risk” or “sensitive” because of their declining abundance, occur in the NWA.
4.0 REQUIREMENTS RELATED TO FISH AND WATERWAYS
4.1 ENVIRONMENTAL FEATURES
The South Saskatchewan River provides the westernmost boundary of the NWA (see Map 1). Typical landscape forms such as sand hills, ancient glacial coulees, and the riverbank and breaks are found along and within the South Saskatchewan River (“SSR”) valley.
Under the Fisheries Act, R.S. 1985, c. F-14, Section 35 is the key habitat protection provision that prohibits the harmful alteration, disruption or destruction (“HADD”) of fish habitat without an authorization from the Minister or through regulations under the Act. During this Project, EnCana does not propose to construct any facilities, well sites or pipelines across or within the South Saskatchewan River or within any fish-bearing streams. It is therefore anticipated that a HADD permit will not be required.
EnCana will withdraw water from the SSR to meet the water requirements of the Project. Such water withdrawals are licensed by Alberta Environment. Alberta Environment typically requires that EnCana appropriately screen water intake pipes and limit the velocity of flow at intake.
Navigable Waters Protection Program ensures “the protection of the public right to navigation and the protection of the environment through the administration of the Navigable Waters Protection Act, R.S. 1985, c. N-22, (“NWPA”). It is anticipated that there will be no temporary bridges required across any water crossings or navigable waters during this Project. Therefore, an approval or permit under the NWPA will not be required.
Throughout the NWA, the landscape is dotted with many small depressional areas. These areas provide important habitat for migratory and breeding birds and provide important habitat and breeding grounds for many species of wildlife. Different classifications of wetlands are also found throughout the NWA. In general, wetlands are more frequently found in the southern part of the NWA (the Riverbank area, and the National Wildlife Area) than in the northern portion of the NWA (Middle Sand Hills).
EUB Directive 056 requires that all well sites located within the required 100 meter setback distance from well centre to a wetland must have the appropriate mitigation measures in place. In situations where the need to construct within the required 100 meter setback is unavoidable, EnCana has developed criteria by which to identify, locate, and construct well sites. It is anticipated that EnCana will avoid constructing within wetlands. In addition, EnCana consults with Alberta Sustainable Resource
CFB Suffield National Wildlife Area Shallow Gas Infill Development Project 25
Development (“ASRD”) to ensure that issues with both the pipelines and wetlands have the appropriate mitigation measures in place prior to construction.
Given that the locations are preliminary at this stage, it is currently anticipated, at this time, that all of the water crossings will be non-fish bearing. In the unlikely event that EnCana must construct through a fish-bearing water course crossing, EnCana will conduct the appropriate Federal and Provincial regulatory consultation and obtain appropriate regulatory approvals prior to construction and appropriate mitigation measures will be developed as part of the environmental assessment.
Where practical, EnCana intends to avoid locating well sites, access roads and pipelines within 100 meters of a water crossing including wetlands. In the event that the location must be within 100 meters from well centre, EnCana will implement the appropriate mitigation such as buffer zones. Mitigation measures will be identified in the environmental assessment process and included in the EPP.
4.2 WATER SOURCES
The potential water sources on CFB Suffield include:
Water source wells and dugouts
12-6-17-5 W4 (20,000m3/yr licensed) 4-4-16-6 W4 (73,000m3/yr licensed) 5-2-20-7 well & dugout 10-16-20-7 well & dugout 9-16-20-7 well & dugout 10-16-20-8 well & dugout
South Saskatchewan River water withdrawals (in the NWA)
NE 23-17-5 W4 (Temporary license for 12,480m3)
Water sources off the base
Local dugouts from local area farmers
No wetlands will be used as water sources for the Project. The amount of water required from each source will be determined based on the number of wells drilled and locations of the wells.
CFB Suffield National Wildlife Area Shallow Gas Infill Development Project 26 APPENDIX A
MAP 1 – CFB Suffield Area Map
CFB Suffield National Wildlife Area Shallow Gas Infill Development Project 27 APPENDIX A
Map 2 – Existing Shallow Gas Development in CFB Suffield NWA
CFB Suffield National Wildlife Area Shallow Gas Infill Development Project 28 APPENDIX A
MAP 3 – Proposed Shallow Gas Development in CFB Suffield NW A
CFB Suffield National Wildlife Area Shallow Gas Infill Development Project 29 APPENDIX B AEUB LICENSING PROCESS
1.1.1.1.1.1.1.1 Figure 1: Routine license application process
Source: EUB Guide 56- Energy Development Applications and Schedules (October 2003)
CFB Suffield National Wildlife Area Shallow Gas Infill Development Project 30
BIBLIOGRAPHY
Adams, Glen D, Garry C. Trottier, Wayne L. Strong, Ian D. Macdonald, Samuel J. Barry, Paul G.Gregoire, Gregg W. Babish and Garry Weiss, 1997. Canadian Forces Base Suffield National Wildlife Area Wildlife Inventory. Can. Wildlife Ser., Unpubl. Rep. Edmonton, pp 96.
Adams, Glen D, Andrew D. Didiuk and Ian D. MacDonald, 1998, Wetlands Component Report, Canadian Forces Base Suffield National Wildlife Area Wildlife Inventory. Can. Wildlife Ser., Unpubl. Rep. Edmonton, pp 37.
Alberta Environmental Protection. 1998. Natural Regions and Subregions of Alberta 1:1,000,000. Alberta Environmental Protection, Edmonton, AB.
Banasch, Ursula and Samuel J. Barry, 1998. Raptor Component Report, Canadian Forces Base Suffield National Wildlife Area Wildlife Inventory. Can. Wildlife Ser., Unpubl. Rep. Edmonton, pp 51.
Berg, T., and R.A. McPherson. 1972. Surficial geology of the Medicine Hat area-NTS 72 L. Research Council of Alberta, Edmonton, AB.
Carbyn, L.N., M. Woelfl and H. Schinke, 1999, Carivore Component Report, Canadian Forces Base Suffield National Wildlife Area Wildlife Inventory. Can. Wildlife Ser., Unpubl. Rep. Edmonton, pp 62.
Dale, Brenda C., Philip S. Taylor and J. Paul Goossen, 1999, Avifauna Component Report, Canadian Forces Base Suffield National Wildlife Area Wildlife Inventory. Can. Wildlife Ser., Unpubl. Rep. Edmonton, pp 161.
Didiuk Andrew B., 1999, Reptile and Amphibian Component Report, Canadian Forces Base Suffield National Wildlife Area Wildlife Inventory. Can. Wildlife Ser., Unpubl. Rep. Edmonton, pp 69.
Finnamore, Albert T. and Don Buckle, 1999, Arthropod Component Report, The Stinging Wasps (Hymenoptera: Chrysidoidea, Vespoidea, Apoidea) and Spiders (Araneae). Can. Wildlife Ser., Unpubl. Rep. Edmonton, pp 197.
Macdonald, Ian D. 1997, Vascular Plant Flora Component Report, Canadian Forces Base Suffield National Wildlife Area Wildlife Inventory. Can. Wildlife Ser., Unpubl. Rep. Edmonton, pp 209.
Pettapiece, W. W. 1986. Physiographic subdivisions of Alberta 1:1,500,000. Agriculture Canada
Pettapiece, W. W. and A.A. Kjearsgaard. 1986. Soil Map: Medicine Hat 72 L SE.
CFB Suffield National Wildlife Area Shallow Gas Infill Development Project 0
Reynolds, Hal W., Samuel J. Barry and Hendrik P.L. Kiliaan, 1999, Small Mammal; Component Report, Canadian Forces Base Suffield National Wildlife Area Wildlife Inventory. Can. Wildlife Ser., Unpubl. Rep. Edmonton, pp 140
Shetsen, I. 1987. Quaternary geology, southern Alberta. 1:500,000 scale. Alberta Res. Council, Edmonton, AB, Canada.
Strong, W.L. and K. Leggatt. 1972. Ecoregions of Alberta 1:1,000,000. Alberta Environmental Protection, Edmonton, AB.
APPENDIX 2
CFB Suffield National Wildlife Area Shallow Gas Infill Development Project
Comprehensive Study
Scope of Assessment Document
November 9, 2005
1.0 INTRODUCTION
1.1 Purpose of this Document
EnCana Corporation has asked the Department of National Defence (DND) to approve its proposed Canadian Forces Base (CFB) Suffield National Wildlife Area (NWA) Shallow Gas Infill Development Project (the Project), by issuing a permit as per the Wildlife Area Regulations. Pursuant to section 5 of the Canadian Environmental Assessment Act (CEAA), an environmental assessment must be conducted before a permit can be issued. As such, DND has determined that it is a responsible authority (RA) for this Project, and therefore must ensure that the environmental assessment is conducted.
DND and the Canadian Environmental Assessment Agency (the Agency) have also determined that the Project is subject to a comprehensive study under CEAA pursuant to Section 2(c) of the Comprehensive Study List Regulations, as the Project involves the construction of an oil and gas pipeline in a protected area.
This scope of assessment document describes the proposed factors to be considered in the environmental assessment and the proposed scope of those factors. It also outlines information on the federal environmental assessment process as set out in the CEAA. It is intended to assist the public in preparing preliminary comments on the Project and the scope of assessment for the Project. The project description is available under separate cover and is available on the Canadian Environmental Assessment Registry.
Following the public comment period on the project description and this scope of assessment, in accordance with subsection 21(2) of the CEAA, DND will provide a report to the federal Minister of the Environment with a recommendation to either continue with the environmental assessment by means of a comprehensive study or to refer the project to a mediator or a review panel.
This is the first opportunity for public participation in the federal environmental assessment process for this project. Further formal public consultation will be carried out should the environmental assessment process be completed through comprehensive study, mediation or review panel.
1.2 The Project
EnCana Corporation (EnCana) proposes to drill up to 1,275 shallow sweet natural gas wells in the CFB Suffield NWA over a three-year period. The wells will be connected into existing and new natural gas gathering infrastructure for delivery of the produced natural gas to market. The Project will add approximately 220 km of additional pipeline and will double the number of wells currently in the NWA.
EnCana has indicated that it expects the Project to fulfill all the infill development they have identified as necessary for their operation, to fully extract the gas reserves in the NWA. Infill drilling as defined by EnCana is: drilling that occurs within the boundaries of an existing
developed gas or oil field. Associated with these wells, EnCana is proposing new infrastructure such as sumps, water and waste management development, including disposal areas and drilling fluid management, and infrastructure that connects the wells to existing facilities. The Project will therefore require access to each of the wells during each phase of the physical activity (preparation, construction, operation and decommissioning) and as such will require access management and an associated access management plan.
For additional information regarding the project, members of the public should consult the project description document available on the Canadian Environmental Assessment Registry.
1.3 Biophysical Environment
Since the establishment of CFB Suffield in 1971 to support military training, the areas comprising the CFB Suffield NWA were classified as environmentally protected and their use was restricted. In 1992, DND and Environment Canada signed a Memorandum of Understanding to work towards the establishment of the NWA. Although unofficially treated as a NWA since that time, it was officially designated on 12 June 2003.
The CFB Suffield NWA encompasses 458 km2 of unploughed prairie grassland blanketing rare landscapes of national significance including sand hills, wetlands, ancient glacial coulees, and the riverbank and breaks along the South Saskatchewan River valley. As a protected area, the NWA protects natural capital considered significant both nationally and internationally. It is a unique prairie natural area. It serves as a comparison to measure and understand the impact of land use on prairie ecosystems within the Base, on neighboring lands, and regionally.
From an ecological perspective, the area is found within the Dry Mixed Grass sub-region of the Grasslands Natural Region of Alberta (Alberta Environmental Protection, 1998). Modal sites within this sub-region are characterized by spear grass – blue grama grass (Stipa spp. – Bouteloua gracilis) on Brown Chernozemic soils (Strong and Leggatt, 1992). The “A” horizon is on the average 10 centimeter thick, with two (2) to three (3) percent organic matter (Pettapiece and Kjearsgaard, 1986). Undisturbed grasslands, sand hills, river breaks and wetlands are refuge to a number of plants, mammals, birds, reptiles, amphibians and insects currently exceeding 1,100 known species. This list includes 244 vertebrates, 462 plants and 436 invertebrate species, a number of which are currently listed under SARA. Examples of species at risk include the Swift Fox and the Burrowing Owl. In addition, 78 species of animals and plants that are listed by the Status of Alberta Wildlife 2000 as “at risk” or “sensitive” because of their declining abundance, occur in the NWA.
2.0 FEDERAL ENVIRONMENTAL ASSESSMENT
2.1 Regulatory Context
Under subsection 5(1) of the CEAA, a federal environmental assessment may be required when, in respect of a project, a federal authority:
• Is the proponent; • Makes or authorizes payment or any other form of financial assistance to the proponent; • Sells, leases or otherwise disposes of lands; or • Issues a permit, or license or other form of approval pursuant to a statutory or regulatory provision referred to in the Law List Regulations of the CEAA.
These planned actions of federal authorities are commonly called “triggers.” In the case of the CFB Suffield NWA Shallow Gas Infill Development Project, a federal approval is required under the Law List Regulations, which triggers the need for a federal environmental assessment under CEAA. Pursuant to section 3 of the Wildlife Area Regulations, EnCana will require a permit to conduct the operations necessary for the Project in the NWA. Section 4 of the Wildlife Area Regulations provides that the Minister may issue a permit to carry out the Project so long as the Project will not interfere with the conservation of wildlife.
Pursuant to section 4.2 of the Canada Wildlife Act, R.S. 1985, c. W-9, the Minister of the Environment delegated authority with respect to the NWA to the Minister of National Defence, who, in turn, subdelegated such authority to the Base Commander of CFB Suffield. Accordingly, the RA for this environmental assessment is the DND.
DND and the Agency have determined that the Project is subject to a comprehensive study under CEAA pursuant to Section 2(c) of the Comprehensive Study List Regulations. As such, pending the conclusion of the Track Decision Report (i.e. the Minister of the Environment makes a decision on whether the project should proceed as a comprehensive study, mediation or review panel), in accordance with subsection 21(1) of the CEAA, DND must ensure that public consultation is carried out on:
• the proposed scope of the project for the environmental assessment; • the proposed factors to be considered in the environmental assessment; • the proposed scope of those factors; and • the ability of the comprehensive study to address issues relating to the project.
In accordance with the Regulations Respecting the Coordination by Federal Authorities of Environmental Assessment Procedures and Requirements (Federal Coordination Regulations), the Agency, as the Federal Environmental Assessment Coordinator (FEAC), referred the project to other federal agencies. The following federal departments have self identified as Federal Authorities (FAs) and will provide specialist advice to the assessment as follows:
• Environment Canada; • Parks Canada; • Natural Resources Canada; • Agriculture and Agri-Food Canada; • Fisheries and Oceans Canada; and • Health Canada.
In accordance with the Canada-Alberta Agreement for Environmental Assessment Cooperation (the Agreement), the FEAC also referred the project to Alberta Environment (AENV), the Alberta Energy and Utilities Board (AEUB) and Alberta Sustainable Resources Development (ASRD). AENV’s review of the project determined that no provincial environmental assessment is required under the Environmental Protection and Enhancement Act (EPEA). It also determined that there is no regulatory interest in the project from an EPEA or Water Act perspective. AENV does not wish to participate in a cooperative environmental assessment at this time.
However, while the AEUB does not have an environmental assessment responsibility, it does have a regulatory interest in oil and gas development at CFB Suffield, as Alberta retains the Crown mineral rights. Public issues and concerns raised during the federal environmental assessment of the project may have direct relevance to the AEUB regulatory review process. The AEUB will participate in the federal environmental assessment process under Appendix 3 of the Agreement. Similarly, the Wildlife Management Branch of ASRD will also participate.
2.2 Overview of the Environmental Assessment Process
Following the initial public consultation, pursuant to subsection 21(2) of the CEAA, the RA, as soon as it is of the opinion that it has sufficient information to do so, must submit a report to the Minister of the Environment which includes the following:
• the scope of the project, the factors to be considered in the environmental assessment and the scope of those factors; • public concerns in relation to the project; and • the ability of the comprehensive study to address issues relating to the project.
The RA must also recommend to the Minister of the Environment whether the environmental assessment should be continued by means of a comprehensive study, or whether the project should be referred to a mediator or review panel.
After considering the report and recommendation, the Minister of the Environment must decide whether to refer the project back to the RA to continue with the comprehensive study process, or refer the project to a mediator or review panel. If the Minister of the Environment decides that the project should continue as a comprehensive study, the project cannot be referred to a mediator or review panel at a later date.
If after considering the report and recommendation, the Minister of the Environment refers the project to a mediator or review panel, the project will no longer be subject to a comprehensive study under the CEAA. The Minister of the Environment, after consulting the RA and other appropriate parties, will set the terms of reference for the review, and appoint the mediator or review panel members.
If the Minister of the Environment determines that the environmental assessment will continue as a comprehensive study, an environmental assessment will be undertaken and a Comprehensive Study Report (CSR) will be prepared and submitted to the Minister of the Environment and to
the Agency. The RA must ensure that there are opportunities for public participation during the comprehensive study process.
Following submission of the CSR, the Agency will invite the public to comment on the report prior to the Minister of the Environment making his determination. The Minister of the Environment may request additional information or require that public concerns be further addressed before issuing the environmental assessment decision statement. Once the environmental assessment decision statement is issued, the Minister of the Environment will refer the project back to the RA for action.
Whether the environmental assessment proceeds by means of a comprehensive study or is referred to a review panel, participant funding will be made available by the Agency to facilitate public participation.
3.0 SCOPE OF ASSESSMENT
The scope of assessment defines the proposed factors to be considered in the environmental assessment and the proposed scope of those factors.
DND is required to consider the factors specified in Section 16 of the CEAA, taking into consideration the definitions of the environment and environmental effect, prior to making a decision regarding whether to take action, in this case, to issue a permit, that would permit the project to proceed.
3.1 Factors to be Considered
As per the CEAA, the following factors will be considered in the environmental assessment:
• the environmental effects of the project, any change the project may cause in the environment including: land, water, air, organic and inorganic matter, living organisms, and the interaction of natural systems; • the effects of a project-related environmental change on: health and socio-economic conditions; physical and cultural heritage; and any structure, site or thing that is of historical, archeological, paleontological or architectural significance; • any human health impact resulting from any change the project may cause in the environment including, but not limited to, air quality, water quality (both surface and ground), noise and country foods; • the effects of the environment on the project (including effects due to climate change); • the significance of those environmental effects; • the environmental effects of accidents and malfunctions that may occur in connection with the project;
• the cumulative environmental effects that are likely to result from the project in combination with other projects or activities that have been or will be carried out1; • the purpose of the project; • alternative means of carrying out the project; • the need for and requirements of a follow up program; • comments from the public obtained in accordance with CEAA; • measures that are technically and economically feasible that would mitigate any significant adverse environmental effects of the project; • the capacity of renewable resources affected by the project to meet the needs of the present and those of the future; • community knowledge; and • a description of the existing environment.
3.2 Scope of the Factors to be Considered
The EA will address the factors listed above, and document any issues and concerns that may be identified through regulatory, stakeholder and public consultations. The “valued ecosystem component” (VEC) approach will be used to focus the analysis during the EA. A definition of each VEC identified for the purposes of the EA, and the rationale for its selection, will be provided in the EA report. This approach will be used to determine the overall effects on the ecological integrity of the NWA.
The assessment will consider the potential effects of the proposed Project within spatial and temporal boundaries that encompass the areas and time periods during and within which the proposed Project may potentially interact with, and have an effect on, components of the environment. These boundaries may vary with each VEC and the factors considered, and should reflect a consideration of:
• The proposed schedule/timing of the Project; • The natural variation of a VEC or subset thereof; • The interrelationships/interactions between and within VECs; • The time required for recovery from an effect and/or return to a pre-effect condition, including the estimated proportion, level, or amount of recovery; and
The area within which a VEC functions and within which the Project’s effect may occur.
Ecosystem Components • Air quality (Valued Ecosystem • Water quality Components) • Soil capability and quality • Fish and fish habitat • Mammals and mammal habitat
1 For more information on cumulative effects assessment please refer to the Canadian Environmental Assessment Agency’s operational policy statement on cumulative effects, http://www.ceaa-acee.gc.ca/013/0002/cea_ops_e.htm
• Birds and bird habitat • Amphibians and reptile and their habitat • Groundwater resources • Surface water resources • Wetlands and wetland function • Greenhouse gas emissions (fugitive methane) • Vegetation (including grasses and forbs) • Range health • Biodiversity • Archaeological, paleontological and heritage resources • Aboriginal interests (traditional knowledge and cultural sites) • Species at Risk (SAR)
Socio-Economic • Regional, provincial and national economic benefits • Recreational activities • Aesthetics • Public health and safety
Other Land Uses • Cattle grazing • Military operations • Other oil and gas operations • Functions and uses of the NWA as an important wildlife area • Ecological and biological research and monitoring programs • Research and development activities
Project Activities The assessment will include project activities and possible causes of environmental effects on each of the study areas including but not limited to the following:
• Preparation activities (including siting and surveying, constraint mapping, unexploded ordinance clearance and chemical warfare agent clearance) • Construction activities (pipelines, sumps, bellholes) • Drilling activities (including access) • Completion activities (including fracturing) • Reclamation, operations, decommissioning and abandonment • Air emissions • Noise • Erosion • Vehicle traffic • Plowing/trenching (associated with pipeline installation) • Malfunctions and accidental effects (spills, leaks, blowouts) • Water and waste water management • Induced seismic activity and subsidence
• Waste management (including drill mud management and disposal methods).
Mitigation Measures A list and description of all mitigation measures, referenced to the environmental effects that are intended to eliminate, reduce, or control, including any restitution for any damage to the environment through replacement, restoration, compensation or other means will be provided. This list will also include: environmental protection policies, best practices and procedures; emergency response plan(s); waste management policies, best practices and procedures; and health and safety practices (including coordination with DND for clearances with respect to unexploded ordinance and chemical warfare areas).
Alternatives to the Project In accordance with paragraph 16(1)(e) of CEAA, the assessment will also include a consideration of the need for the project and alternatives to the project. This assessment will identify alternative means of carrying out the project that are technically and economically feasible and the environmental effects of any such alternatives.
Spatial Boundaries The boundaries must be flexible and adaptive to enable adjustment or alteration based on field data. The selection of spatial and temporal boundaries for the study area will be consistent with the guidelines provided under the CEAA.
The following spatial boundaries are proposed for the environmental assessment of the spatial impact:
Site Study Area: The area directly affected by the preparation, construction, operation and decommissioning/ abandonment activities forming part of the Project.
Local Study Area: The area that could potentially be affected by preparation, construction, operation and decommissioning/ abandonment activities forming part of the Project.
Regional Study Area: The area that could potentially be affected by the Project beyond the Local Study Area.
Temporal Boundaries The following temporal boundaries are proposed for assessing the duration of environmental impacts:
Temporary: effects measurable for less than or equal to seven days;
Short-term: effects are measurable for longer than seven days but less than one year;
Medium-term: effects are measurable for one to ten years; and
Long-term: effects are measurable for greater than ten years.
Cumulative Environmental Effects Assessment The assessment of cumulative environmental effects will be consistent with the principles described in the CEAA Cumulative Effects Assessment Practitioners Guide, the CEAA operational policy statement Addressing Cumulative Environmental Effects under the Canadian Environmental Assessment Act, and applicable Court decisions, and will include a consideration of environmental effects that are likely to result from the proposed Project in combination with other projects or activities that have been or will be carried out.
The evaluation of potential cumulative environmental effects will include the net environmental effects associated with the project in combination with the environmental effects of other past, present or future projects or activities. Cumulative effects are to be considered for those reasonably foreseeable projects and activities, the effects of which have the potential for overlapping in time and space with the environmental effects of the proposed project activities. The approach and methodologies used to identify and assess cumulative effects will be explained in the environmental assessment report. The cumulative effects assessment will focus on, but not necessarily be limited to:
• Ecological integrity and role/mandate of the NWA; • Wildlife use; • Military operations and developments; • Biological research programs; • Other oil and gas developments; • Agricultural land uses; • Other land and resource use activities (hunting, river recreational usage, etc.); • Other airshed emissions sources; and • Transport corridors.
Land and Resource Use The Land and Resource category encompasses current and future proposed occupation and use of the lands, both public and private, and resources at and adjacent to the proposed project, as well as occupation and use of lands and resources along the right-of-way corridor for the pipelines, access areas and any off-site work areas, directly related to the Project. Land and resource use beyond the immediate vicinity (i.e. the local study area) of the project areas will also be considered.
Effects of the Environment on the Project In addition to evaluating the environmental effects of the Project, including cumulative environmental effects, changes to the Project that may arise as a result of the environment will also be considered. For example, natural phenomena like grass fires, tornadoes and hailstorms, can result in environmental effects as defined in the CEAA. This analysis will include consideration of natural hazards such as extreme weather events (lightning, fire, extreme precipitation, flooding, drought and wind erosion), natural seismic events, wildlife interference,
corrosion and climate change. Proposed mitigation, including design strategies, will be considered in the evaluation of the effects of the environment on the Project and the determination of their significance.
Capacity of Renewable Resources Sustainability will be addressed in the assessment. This will include a consideration of the capacity of renewable resources that are likely to be significantly affected by the Project to meet the needs of the present and those of the future. Consideration will be given to the ecological integrity of the NWA lands, their multi-species values, and the effectiveness of protection for the conservation of wildlife.
Potential Accidents and Malfunctions The assessment will include consideration of the potential accidents, malfunctions and unplanned events that could occur in any phase of the Project, the likelihood and circumstances under which these events could occur, and the environmental effects that may result from such events.
Proposed Design of the Follow-up Program The purpose of the follow-up program is to assist in determining if the environmental and cumulative effects of the project are as predicted in the comprehensive study report. It is also to confirm whether the impact mitigation measures are effective and to determine if any new mitigation strategies may be required. The follow-up program will encompass the monitoring of project activities, and include the implementation of an auditing framework.
4.0 PUBLIC PARTICIPATION
The public is invited to provide its views at this stage of the environmental assessment of the project on the following areas:
• the project description (under separate cover); • the factors proposed to be considered in the assessment and the proposed scope of those factors; and • the ability of the comprehensive study to address issues relating to the project.
Persons wishing to submit comments may do so in writing to DND. Please be as detailed as possible and clearly reference the CFB Suffield National Wildlife Area Shallow Gas Infill Development Project and CEAR #05-03-15620 on your submission. Comments must be received by the close of business on 12 December 2005.
Comments may be sent electronically to [email protected] or mailed to:
Director Land Environment Land Force Command Department of National Defence
18NT, 101 Colonel by Drive Ottawa (ON) K1A 0K2
In accordance with subsection 21(2) of CEAA, after this public consultation, DND will report to the federal Minister of the Environment regarding the following: the scope of the of the project, the factors to be considered in its assessment and the scope of those factors; public concerns in relation to the project, and the ability of the comprehensive study to address issues relating to the project. DND will also recommend to the Minister to continue the EA by means of a comprehensive study or refer the project to a mediator or review panel. Therefore, the consultation seeks to gather the public’s comments for the purpose of preparing the recommendation. The public will have further opportunities to participate in the EA process whether the project is assessed by means of a comprehensive study, mediation or review panel.
A public registry has been established for the Project and the Project is listed on the Canadian Environmental Assessment Registry as project #05-03-15620.
APPENDIX 3
Public Notice
Canadian Environmental Assessment Act
Comprehensive Study Assessment of the Proposed EnCana Corporation CFB Suffield National Wildlife Area Shallow Gas Infill Development Project
Public Consultation on Scoping Document
EnCana Corporation proposes to install, over a three-year period, up to 1275 new shallow gas wells within the boundary of the Canadian Forces Base Suffield National Wildlife Area (NWA), located in Southeastern Alberta, approximately 50 kilometres Northwest of Medicine Hat and 250 kilometres Southeast of Calgary. The project is in addition to the existing natural gas development activities within the NWA and includes the physical works and the activities associated with the preparation, construction, operation, decommissioning and abandonment of the shallow gas wells, pipelines, and supporting infrastructure.
The project is subject to a comprehensive study under the Canadian Environmental Assessment Act. Pursuant to subsection 21(1) of the Act, the Department of National Defence, as the federal responsible authority for the project assessment, now invites the public to comment on the proposed scope of the project, factors proposed to be considered, proposed scope of those factors, and the ability of the comprehensive study to address issues relating to the project.
Following this public consultation, the Department of National Defence will provide a report to the Minister of the Environment that will address the issues mentioned above, and recommend whether the environmental assessment of the project should proceed by means of a comprehensive study, or should be referred to a mediator or review panel.
The project is also subject to provincial regulatory approvals. Although the project does not require an environmental assessment under Alberta legislation, provincial authorities will participate in the federal environmental assessment under the Canada-Alberta Agreement for Environmental Assessment Cooperation.
Comments received by December 12, 2005, will be considered in the preparation of the report and the recommendation to the Minister of the Environment.
The scoping document and project description are available at the following locations:
Medicine Hat Public Library Medicine Hat, City Hall 414 First Street SE City Clerk’s Department - 2nd Floor Medicine Hat AB T1A 0A8 580 – 1st Street SE Medicine Hat AB T1A 8E6 Brooks Public Library Cypress County 420 – 1st Avenue West 816 – 2nd Avenue Brooks AB T1R 1B9 Dunmore AB T0J 1A0
Lethbridge Public Library 810 – 5th Avenue South Lethbridge AB T1J 4C4
The documents are also available on the Canadian Environmental Assessment Registry at http://www.ceaa-acee.gc.ca/050/index_e.cfm. Enter project reference #05-03-15620.
Interested persons may submit their comments in the official language of their choice to:
Department of National Defence
Mr. Eric Trépanier Senior Environmental Advisor Director Land Environment Land Force Command 101 Colonel By Drive, 18NT Ottawa ON K1A 0K2 Telephone: (613) 945-0398 Fax: (613) 945-0483 E-mail: [email protected]
NOTE: All documents and/or comments received regarding this project are considered public and will become part of the public registry for the project. Please quote the project title and CEAR # 05-03-15620 on all correspondence.
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