KEYSTONE XL PIPELINE PROJECT Rare and Rare Ecological Communities (Condition 8)

KXL1399-STCE-EN-RP-0002 Rev C

January 2019

Prepared for:

TransCanada Keystone Pipeline Limited Partnership

A Wholly Owned Subsidiary of TransCanada PipeLines Limited Calgary, Alberta

Prepared by:

Stantec Consulting Ltd. Calgary, Alberta

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Table of Contents

EXECUTIVE SUMMARY ...... I

ABBREVIATIONS ...... III

1.0 INTRODUCTION ...... 1.1

2.0 SURVEY METHODS ...... 2.1 2.1 SUMMARY OF PREVIOUS SURVEYS ...... 2.1 2.1.1 Previous Rare Plants ...... 2.1 2.1.2 Previous Rare Ecological Communities ...... 2.2 2.1.3 Other Data Sources ...... 2.2 2.2 2017 SURVEYS ...... 2.2 2.2.1 Rare Plants ...... 2.3 2.2.2 Rare Ecological Communities ...... 2.4

3.0 RESULTS ...... 3.1 3.1 RARE PLANTS ...... 3.1 3.1.1 Alberta ...... 3.1 3.1.2 Saskatchewan ...... 3.5 3.1.3 Mitigation Changes due to Updates in Provincial Species Ranks and Species Identification ...... 3.9 3.2 RARE POLYGONS ...... 3.10 3.3 RARE ECOLOGICAL COMMUNITIES ...... 3.11

4.0 MITIGATION ...... 4.1 4.1 MITIGATION STRATEGIES ...... 4.1 4.1.1 Avoidance of Effects on Rare Plants and Rare Ecological Communities ...... 4.1 4.1.2 Reducing Effects on Rare Plants and Rare Ecological Communities ...... 4.1 4.1.3 Species-specific Mitigation Strategies ...... 4.2 4.1.4 Mitigation Strategies for Rare Plants ...... 4.2 4.1.5 Mitigation Strategies for Rare Ecological Communities ...... 4.5 4.2 CONSTRUCTION MITIGATION MEASURES ...... 4.5 4.2.1 Construction Mitigation for SARA-listed Plants ...... 4.6 4.2.2 Construction Mitigation for Provincially-listed Rare Plants ...... 4.7 4.2.3 Construction Mitigation for Rare Ecological Communities ...... 4.8 4.3 SUPPLEMENTAL MITIGATION FOR RARE PLANTS ...... 4.8 4.3.1 Rare Plants Associated with Uplands ...... 4.8 4.3.2 Rare Plants Associated with Wetlands ...... 4.9 4.3.3 Seed Collection and Transplantation Completed ...... 4.10 4.4 MITIGATION FOR RARE ECOLOGICAL COMMUNITIES ...... 4.11

5.0 ASSESSING MITIGATION SUCCESS ...... 5.1 5.1 DETERMINING THE EXTENT OF NON-AVOIDABLE EFFECTS ...... 5.1 5.2 POST-CONSTRUCTION MONITORING ...... 5.1

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

5.2.1 Rationale for Post-Construction Monitoring ...... 5.1 5.2.2 Scope of Post-Construction Environmental Monitoring ...... 5.2 5.3 POST-CONSTRUCTION MONITORING SURVEY METHODS ...... 5.3 5.3.1 Mitigation Area ...... 5.3 5.3.2 Rare Plant Monitoring Survey Protocols ...... 5.3 5.3.3 Rare Ecological Community Monitoring Survey Protocols ...... 5.4 5.3.4 Qualifications of Monitoring Personnel ...... 5.5 5.3.5 Monitoring Schedule ...... 5.5 5.3.6 Controls ...... 5.6 5.4 ASSESSING RARE PLANT MITIGATION SUCCESS ...... 5.6 5.5 ASSESSING RARE ECOLOGICAL COMMUNITY MITIGATION SUCCESS ...... 5.7 5.6 PLANNING FOR THE PROVISION AND IMPLEMENTATION OF OFFSET MEASURES ...... 5.7

6.0 REGULATORY CONSULTATION ...... 6.1

7.0 REFERENCES ...... 7.1 7.1 LITERATURE CITED ...... 7.1 7.2 PERSONAL COMMUNICATIONS ...... 7.5

LIST OF TABLES Table 2-1 Comparison of Rare Plant Survey Methods in the 2010 Condition 6 Filing vs. 2017 Survey Methods – Saskatchewan...... 2.5 Table 3-1 Rare Plant Occurrences Identified in 2017 on or within 30 m of the Construction Footprint – Alberta ...... 3.3 Table 3-2 Rare Plant Occurrences Identified in 2017 on or within 30 m of the Construction Footprint – Saskatchewan ...... 3.7 Table 3-3 Species Rank and Identification Changes ...... 3.9 Table 3-4 Summary of Total Area for Each REC Identified in 2017 along the Project Construction Footprint ...... 3.13 Table 4-1 Quarter Sections containing Occurrences within 300 m or Critical Habitat crossed by the Project Footprint ...... 4.6 Table 4-2 Supplementary Mitigation for Rare Plants Associated with Uplands ...... 4.9 Table 4-3 Supplementary Mitigation for Rare Plants Associated with Wetlands ...... 4.9 Table 4-4 Date of Seed Collection and Transplantation for Rare Plant Species ...... 4.11

LIST OF FIGURES Figure 2-1 Keystone XL Pipeline Route through Alberta and Saskatchewan ...... 2.7

LIST OF APPENDICES

DEFINITIONS

SASKATCHEWAN FIELD QUALIFICATIONS

REGULATORY CONSULTATION DOCUMENTATION

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

RARE PLANT RECORDS ON THE CONSTRUCTION FOOTPRINT

RARE PLANT RECORDS WITHIN 30 M OF THE CONSTRUCTION FOOTPRINT

RARE ECOLOGICAL COMMUNITIES WITHIN THE CONSTRUCTION FOOTPRINT

RARE PLANT AND RARE ECOLOGICAL COMMUNITY FIGURES

PROJECT SPECIFIC MITIGATION

DESCRIPTIONS OF RARE PLANT SPECIES WITHIN 30 M OF THE CONSTRUCTION FOOTPRINT

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Executive Summary

This report assesses potential effects of Project construction on rare plant species and communities. In accordance with the National Energy Board (NEB) OH-1-2009 Reasons for Decision, Certificate OC-56 Condition 8, for the Keystone XL Pipeline Project (the Project), this report has been prepared to provide:

• Results of updated surveys done in 2017 for rare plants (including Species at Risk Act (SARA) listed plants), and rare ecological communities (RECs) • Updates to mitigation plans for rare plants and REC potentially affected by Project construction, including construction mitigation and measures for post-construction mitigation • Monitoring survey protocols for post-construction reclamation of rare plants and RECs

The 2017 surveys are an update to the previous rare plant and REC data collected for the Project between 2008 and 2011 as part of the 2012 Condition 8 filing (NEB filing ID: A40331). These surveys were designed to identify rare plants (including SARA-listed plants), and RECs prior to construction and to validate mitigation requirements for construction of the Project. This report also presents rare plant and REC data collected in 2014 by the Vantage Pipeline for areas where it parallels the Project in Saskatchewan. In addition to the survey results from 2008 to 2011, the 2017 surveys were also based on data from the Alberta Conservation Information Management System (ACIMS), the Saskatchewan Conservation Data Centre (SK CDC), and surveys conducted for the proposed Energy East Project in 2013 and 2014 for where it paralleled the Keystone XL route in Alberta. Updates to mitigation measures for rare plants and RECs are included in this report. These updates are based on survey results, changes in regulatory guideline documents and agency consultation.

Survey methods were previously reviewed with appropriate regulatory agencies. Survey methods were filed with the NEB on April 9, 2010 (NEB filing ID: A1S4U9), and subsequently approved pursuant to NEB OH-1-2009, Certificate OC-56 Condition 6. The 2017 rare plant survey methods followed previously approved methods, with some minor adjustments as a result of agency consultation. Updates to provincial survey guidelines made since the 2008-2011 surveys (ANPC 2012, Government of Saskatchewan 2017) did not contain changes to survey protocols for RECs. Therefore, the 2017 REC surveys in Alberta and Saskatchewan were conducted using the same methods described in the 2010 Condition 6 filing (NEB filing ID: A1S4U9).

The 2017 rare plant and REC surveys yielded the following results:

• Twelve rare plant species (ranked S2, S2S3 or S3, and on the Alberta tracking or watch list) were identified on or within 30 m of the Project construction footprint in Alberta. In total, 138 individual occurrences of rare plant species were found in Alberta during the 2017 surveys. • Thirty-nine rare plant species (ranked S1, S2 or S3, and on the Saskatchewan tracking list) were identified on or within 30 m of the Project construction footprint. In total, 663 occurrences of rare plant species were found in Saskatchewan during the 2017 surveys.

i

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

• Surveys conducted in 2014 in quarter sections where Keystone XL is adjacent to the Vantage Pipeline ROW (in Saskatchewan only) identified 15 rare plant species (ranked S1, S2 or S3, and on the Saskatchewan tracking list). In total 25 occurrences of these species were found within 30 m of the Project ROW during the Vantage adjacent surveys. • Several occurrences of RECs were identified along the Project route in 2010. Additional occurrences were identified during surveys for the proposed Energy East Project in Alberta in 2013 and 2014 (where the two projects parallel). Based on the Energy East surveys, and surveys conducted in 2017, the mapped extent of several RECs identified in 2010 were reduced or expanded based on changed conditions.

The underlying context for mitigation planning is how best to route, construct and reclaim the Project to avoid or lessen effects on rare plant species and RECs. When avoidance is not compatible with project design constraints, mitigation planning assesses how best to reduce effects on rare vegetation species, communities and their habitat. TransCanada Keystone Pipeline GP Ltd.’s (the Company) mitigation strategy applies a risk-based approach that considers the rarity of the plant or community locally and provincially, existing threats, the biological characteristics of the plant or community, the seral stage of the associated plant community, effectiveness of previous mitigation and response to disturbance.

Construction mitigation measures presented in this report are incorporated into the mainline pipeline Environmental Protection Plan filed with the NEB as per NEB OH-1-2009, Certificate OC-56 Condition 13 (Environmental Protection Plan, NEB filing ID: A6H1U4). These measures adhere to the recommendations and guidelines of the NEB’s Environmental Screening Report (ESR) for the Canadian portion of the Company’s approved Keystone XL Pipeline project (the Project).

In accordance with Certificate OC-56 Condition 9, the Companyhas prepared a preliminary plan for monitoring success of rare plant mitigation measures. The Company will develop and file a detailed plan for the provision and implementation of offsets, including consultation with appropriate regulatory agencies, as required by Condition 9. This pan will be field 120 days prior to application for leave to open. The plan will be implemented should non-avoidable impacts be realized, after completion of the five-year post-construction environmental monitoring period.

ii

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Abbreviations

ACIMS Alberta Conservation Information Management System

AEP Alberta Environment and Parks

AESB Agri-Environment Services Branch

ANHIC Alberta Natural Heritage Information Centre

ANPC Alberta Native Plant Council

CDC Conservation Data Centre

EAS Environmental Alignment Sheet

ECCC Environment and Climate Change Canada

EPP Environmental Protection Plan

ESR Environmental Screening Report

FNA Flora of

GPS global positioning system

ITIS Integrated Taxonomic Information System m metre

NEB National Energy Board

PFRA Prairie Farm Rehabilitation Administration

iii

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

REC rare ecological community

ROW right-of-way

SARA Species at Risk Act

SK CDC Saskatchewan Conservation Data Centre

SK MOE Saskatchewan Ministry of Environment ssp. subspecies

USDA Department of Agriculture var. variety

iv

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Introduction January 2019

1.0 INTRODUCTION

This report assesses potential effects of Project construction on rare plant species and communities. In accordance with the National Energy Board (NEB) OH-1-2009 Reasons for Decision, Certificate OC-56 Condition 8, for the Keystone XL Pipeline Project (the Project), this report has been prepared to provide:

• Results of updated surveys done in 2017 for rare plants (including Species at Risk Act (SARA) listed plants), and rare ecological communities (RECs) • Updates to mitigation plans for rare plants and REC potentially affected by Project construction, including construction mitigation and measures for post-construction mitigation • Monitoring survey protocols for post-construction reclamation of rare plants and RECs

The 2017 surveys are an update to the previous rare plant and REC data collected for the Project between 2008 and 2011 as part of the 2012 Condition 8 filing (NEB filing ID: A40331). These surveys were designed to identify rare plants (including SARA-listed plants), and RECs prior to construction and to validate mitigation requirements for construction of the Project. This report also presents rare plant and REC data collected in 2014 by the Vantage Pipeline for areas where it parallels the Project in Saskatchewan. In addition to the Company survey results from 2008 to 2011, the 2017 surveys were also based on data from the Alberta Conservation Information Management System (ACIMS), the Saskatchewan Conservation Data Centre (SK CDC), and surveys conducted for the proposed Energy East Project in 2013 and 2014 for where it paralleled the Keystone XL route in Alberta.

Updates to mitigation measures for rare plants and RECs are included in this report. These updates are based on survey results, changes in regulatory guideline documents and agency consultation.

The 2017 rare plant and REC surveys were completed on the final approved route that incorporates route changes previously addressed in Condition 11 reporting. As such, no update to Condition 11 is required. The crossings of the Red Deer River and South Saskatchewan River were successfully completed as Horizontal Directional Drills (HDD); therefore, updated surveys of rare plants and RECs on contingency routes were not required.

The construction mitigation measures presented in this report are incorporated into the mainline pipeline Environmental Protection Plan (EPP) filed with the NEB as per NEB OH-1-2009, Certificate OC-56 Condition 13. These measures adhere to the recommendations and guidelines of the NEB’s Environmental Screening Report (ESR) for the Canadian portion of the TransCanada Keystone Pipeline GP Ltd.’s (the Company) approved Keystone XL Pipeline project (the Project).

In accordance with Certificate OC-56 Condition 9, the Company has prepared a preliminary plan for monitoring success of rare plant mitigation measures. The Company will develop and file a detailed plan for the provision and implementation of offsets, including consultation with appropriate regulatory agencies, as required by Condition 9. This plan will be filed 120 days prior to application for leave to open. The plan will be implemented should non-avoidable impacts be realized, after completion of the five-year post-construction environmental monitoring period.

1.1

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Introduction January 2019

1.2

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Survey Methods January 2019

2.0 SURVEY METHODS

2.1 SUMMARY OF PREVIOUS SURVEYS

The 2017 surveys to identify the occurrences of rare plants (including SARA-listed plants) and RECs were based on occurrences found during rare plant and REC surveys conducted between 2008 and 2011 and previously reported as part of the 2012 Condition 8 filing (NEB filing ID: A4033). The 2017 surveys were also based on data collected in 2014 by the Vantage Pipeline project and in 2013 and 2014 by the Energy East Project in areas where they parallel the Keystone XL Project in Saskatchewan and Alberta, respectively. Survey methods for 2008-2011 were reviewed with appropriate regulatory agencies, filed with the NEB on April 9, 2010 (NEB filing ID: A1S4U9).

2.1.1 Previous Rare Plants

Several different survey techniques with different objectives were used for rare plant surveys conducted between 2008 and 2011.

Site based general rare plant surveys were completed in 2008. Sites were chosen to include all major native vegetation and wetland types occurring along the Project route, including areas associated with uncommon landscape features (e.g., Great Sand Hills, river valleys). A few additional areas with higher rare plant potential were surveyed using this method in 2009.

Transect surveys were conducted in 2009 during the appropriate survey window to detect the target species in areas of suitable habitat for three SARA-listed plants: slender mouse-ear-cress (Transberingia bursifolia ssp. virgata); tiny cryptantha (Cryptantha minima); and, smooth goosefoot (Chenopodium subglabrum). Transects were surveyed at 100 m intervals perpendicular to the Project footprint. Transects extended to a distance of 300 m from the edge of the Project footprint in each direction.

In addition, rare plant surveys were done twice (early and late growing season) between 2009 and 2011 in community pastures (formerly known as Prairie Farm Rehabilitation Administration [PFRA] pastures) in Saskatchewan. These surveys also included perpendicular transects to a distance of 100 m from the edge of the Project footprint along the full length of the ROW within the community pastures.

In addition, occurrences of S1, S2, and S3 rare plants (see Appendix A for provincial S-Rank definitions) within 30 m of the project footprint outside of the community pastures were documented between 2008 and 2011.

2.1

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Survey Methods January 2019

2.1.2 Previous Rare Ecological Communities

Rare ecological communities (RECs) include communities described as unusual, uncommon, of limited extent or encountered infrequently. They also include community types that have been described by vegetation experts as in decline or threatened. All are considered important at the provincial scale; some may be considered nationally or globally important (Allen 2014). RECs in Alberta are based on descriptions currently provided and tracked by ACIMS (Allen 2014). A tracking list for RECs has not been developed in Saskatchewan. Two versions of the document Saskatchewan Rangeland Ecosystems: Ecoregions, Ecosites and Communities (Thorpe 2007 and 2014) were consulted to determine if communities listed in Alberta are common in Saskatchewan. Professional judgment was then used to eliminate communities that are not rare in Saskatchewan from the observed list of potential RECs intersected by the Project footprint.

The spatial extent of REC occurrences within 30 m of the Project footprint were documented from 2009 through 2011. For each REC, dominant and characteristic plant species composition was documented, and the spatial extent of REC polygons were determined with hand-held GPS units.

2.1.3 Other Data Sources

In addition to the Project survey results from 2008 to 2011, the 2017 surveys were also based on data from the Alberta Conservation Information Management System (ACIMS), the Saskatchewan Conservation Data Centre (SK CDC), and surveys conducted for the proposed Energy East Project in Alberta in 2013 and 2014 (where the two projects were parallel). This report also presents rare plant and REC data collected in 2014 by the Vantage Pipeline for areas where it parallels the Project in Saskatchewan.

2.2 2017 SURVEYS

The 2017 surveys were conducted on the approved Project route on approximately 95% of the construction footprint occurring in native range in Saskatchewan and on approximately 80% of native range in Alberta. The Project construction footprint comprises the standard construction ROW, which includes the permanent ROW and temporary workspace. The Project route through Alberta and Saskatchewan is shown in Figure 2-1.

Qualifications and experience of rare plant surveyors are provided in Appendix B. Rare plant surveys were conducted by teams of two botanists with the following qualifications, which meet or exceed provincial requirements (ANPC 2012; Government of Saskatchewan 2017):

• At least one team member has at least 10 years of experience with the local flora • All team members have at least 120 days of taxonomic field experience • All team members have specific training with terminology in plant anatomy and and have competence in the use of regional or provincial floras to distinguish rare plants • All team members have a well-developed search image for potential rare plants

2.2

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Survey Methods January 2019

• All team members have the ability to identify rare plant species most likely to occur in the search area, to distinguish between similar species, and to know the best time of year to survey for the potential rare plants • All team members have the ability to identify survey locations, to operate a GPS receiver, to identify different habitats in the field and to stratify habitats using imagery

2.2.1 Rare Plants

Updated provincial rare plant survey guidelines were released by the Alberta Native Plant Council (ANPC 2012) and the Saskatchewan Ministry of Environment (SK MOE; Government of Saskatchewan 2017). In addition, federal recovery strategies for SARA-listed plant species with known occurrences, home ranges, and critical habitat near the Project were released in 2012 (for slender mouse-ear-cress [Environment Canada 2012a] and tiny cryptantha [Environment Canada 2012b]) and in 2015 (for smooth goosefoot [Environment Canada 2015]).

The following is a summary of how updated provincial and federal rare plant survey guidelines compare to the survey methods used previously and described in the 2010 Condition 6 filing (NEB filing ID: A1S4U9):

• Alberta Rare Plant Species: The 2012 update for the Alberta guidelines (ANPC 2012) did not add any additional requirements compared to what was previously done for the Project; therefore, the 2017 rare plant surveys in Alberta were conducted using the same methods described in the 2010 Condition 6 filing. • Saskatchewan Rare Plant Species: The primary change in the 2017 Saskatchewan guidelines is a move away from meander surveys to linear transect surveys for rare plant species. In addition, the recommended survey area is up to a distance of 300 m from the Project footprint. Consultation was undertaken with the SK MOE and SK CDC as the Project’s survey methods include minor deviations from the 2017 provincial survey guidelines (see Section 6.0 for a summary of the consultation communication and Appendix C for the consultation documentation). The 2017 rare plant survey methods for the Project in Saskatchewan are summarized in Table 2-1. • SARA-listed Plant Species: The recovery strategies released in 2012 and 2015 require that survey methods for SARA-listed plant species follow linear transect methods, as described by Henderson (2009). The recovery strategies also identify critical habitat for these species based on known occurrences. The previous SARA-listed plant surveys done for the Project followed the Henderson (2009) linear transect methods and surveyed the same areas of critical habitat and known occurrences as identified in the recovery strategies. Therefore, 2017 SARA-listed plant survey methods continued to follow the Henderson (2009) methods described in the 2010 Condition 6 filing and surveyed the same areas of known occurrences and critical habitat.

Survey methods in Alberta were reviewed with Alberta Environment and Parks (AEP) and Environment and Climate Change Canada (ECCC) who agreed with use of existing provincial and federal guidelines for SARA-listed and other rare plant surveys.

2.3

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Survey Methods January 2019

Consultation with SK MOE and SK CDC took place in May 2017, to discuss the adequacy of existing rare plant data, combined with the meander survey method used by the Company, to confirm and augment known rare plant occurrences. Ken Dillabaugh, SK MOE, and Sarah Vinge-Mazer, SK CDC, indicated that meander methods for rare plant surveys, as described in the 2010 Condition 6 filing, are acceptable, with the exception of approximately 20 km of the Project construction footprint with high potential habitat for rare plant species (including plant species at risk) in and near the provincial community pasture between NW 07-015-25 W3M and SE 01-014-25 W3M and between SW 29-013-24 W3M and SW 21- 013-24 W3M (Dillabaugh and Vinge-Mazer 2017, pers. comm.). In this area, linear transect surveys were required, to a distance of 300 m from the Project construction footprint (rather than the meander survey method previously used). As a result, the Saskatchewan rare plant survey methods were modified in 2017 to incorporate linear transect surveys in this area (see Table 2-1).

Table 2-1 provides a comparison between the rare plant survey methods described in the 2010 Condition 6 filing and the 2017 Saskatchewan guidelines (Government of Saskatchewan 2017). Table 2-1 also indicates how the 2010 survey methods meet the 2017 guidelines or how the 2017 survey methods were modified to meet the 2017 requirements, as appropriate.

2.2.2 Rare Ecological Communities

The 2012 and 2017 updated provincial rare plant survey guidelines (ANPC 2012, SK MOE [Government of Saskatchewan 2017]) did not contain changes to survey protocols for RECs. Therefore, the 2017 REC surveys in Alberta and Saskatchewan were conducted using the same methods described in the 2010 Condition 6 filing (NEB filing ID: A1S4U9).

2.4

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Survey Methods January 2019

Table 2-1 Comparison of Rare Plant Survey Methods in the 2010 Condition 6 Filing vs. 2017 Survey Methods – Saskatchewan

Regulatory Survey Guidelines for 2017 Surveys (Government of Change from 2010 Survey Methods Requirement 2010 Survey Methods Saskatchewan 2017) (Y/N) Survey Target • Surveyed potential habitats, • Survey potential habitats, including Discussion with Ken Dillabaugh (SK Areas including native range and native range and uncultivated MOE) and Sarah Vinge-Mazer (SK CDC) uncultivated wetlands, within the wetlands, within the Project indicated that a 30 m survey buffer is Project footprint construction footprint acceptable for all areas of potential for • Surveyed areas with past SK CDC • Survey areas with SK CDC provincial rare plant species except for observations observations approximately 20 km between NW 07-015-25 W3M and SE 01-014-25 • Surveyed appropriate setback • Survey appropriate setback W3M and between SW 29-013-24 W3M distances: potential habitats were distances (30 m to 300 m) and SW 21-013-24 W3M, which is to be surveyed within the Project footprint surveyed using a 300 m buffer on either (32 m ROW) plus a 30 m buffer side of the ROW (Dillabaugh and Vinge-Mazer 2017, pers. comm.) Survey Timing • A minimum of two survey visits were • A minimum of two survey visits are None made at each sample site required at each sample site • The survey periods were: • The survey periods are: − May 15 to early July for early − May 15 to early July for early season species season species − Mid-July to September 15 for − Mid-July to September 15 for late season species late season species • Surveys were conducted during • Surveys must be separated by at appropriate weather conditions least 7 weeks (49 days) • Surveys must be conducted during appropriate weather conditions

2.5

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Survey Methods January 2019

Table 2-1 Comparison of Rare Plant Survey Methods in the 2010 Condition 6 Filing vs. 2017 Survey Methods – Saskatchewan

Regulatory Survey Guidelines for 2017 Surveys (Government of Change from 2010 Survey Methods Requirement 2010 Survey Methods Saskatchewan 2017) (Y/N) Transect Method • Meander survey methods were used • For all rare plants (including Discussion with Ken Dillabaugh (SK for all rare plant habitat SARA-listed plants), linear transect MOE) and Sarah Vinge-Mazer (SK CDC) methods are the required sampling indicated that previously used meander unit, not meander surveys survey methods are acceptable for all areas of the Project except for approximately 20 km between NW 07-015-25 W3M and SE 01-014-25 W3M and between SW 29-013-24 W3M and SW 21-013-24 W3Mthat are to be surveyed using linear transect methods (Dillabaugh and Vinge-Mazer 2017, pers. comm.) Personnel • Teams of two conducted all rare • Teams of two must conduct the None Conducting plant surveys survey Survey • Survey team leads had at least • Personnel should have at least 120 days and 10 years of taxonomic 120 days and 10 years of taxonomic field experience with the local flora field experience with the local flora Notification • Discussion of proposed survey • Discussion of proposed survey None protocols was conducted with SK protocols with SK MOE is MOE prior to survey recommended prior to survey

2.6

Vernon 378 Lake

Wells North Wainwright Battleford PS1 - Hardisty B Lake Ribstone 40 Redberry Pump Station & 17 Manitou Battleford Lake Lake Terminal Lake CFB 340 Rabbit Seagram Hardisty Wainwright Freshwater Lake Little Lakes 29 Bellshill Lake Manitou Lake Lake Thackeray N Radisson Hardisty Lake or th Lake S er Pipeline Segment a iv sk R at e che Langham tl Gillespie Wilkie Keppel wan at 14 River B Unity Lake Lake 4 Dalmeny Horseshoe 376 Muddy Goose PS2 - Lakesend East Lake Provost Lake Lake Pump Station Macklin Ear Lake Grill Lakesend East Lake Sounding 374 Pipeline Segment Whiteshore Van Scoy Rice Lake Biggar Coronation Lake Lake Lake Tramping 12 Lake Delisle White 51 Heron Kirkpatrick Grassy Kerrobert Lake Lake PS3 - Monitor South Island Opuntia Herrick Goose Pump Station Lake Lake SASKATCHEWAN Low Lake Lake

Contracosta ALBERTA Monitor South 31 Lake Goose Lake Pipeline Segment Kiyiu Dewar Rosetown Lake Lake 45 9 317 15 Plover Outlook Kindersley 7 Lake Milden 30 Lake Bad Lake

44 Oyen PS4 - Oyen South Pump Station Snipe Oyen South Lake Pipeline Segment 42 Luck Eston Lake Cabri Lake Whitebear Lake

41 Leader Red Deer River 342

Lake PS5 - Bindloss South Diefenbaker Pump Station Bindloss South Pipeline Segment

r ive R n Tide a w e Lake h tc CFB a k s 371 Reed Suffield a S Lake h t 332

u o Highfield S PS6 - Fox Valley Fox Valley Reservoir Red Pump Station Swift Deer Bigstick Pipeline Segment Current Lake Lake 363

Many Island Bitter Crane Gull Medicine Lake Lake Lake Lake Hat Reid Redcliff Lake 1 Hay Lake PS7 - Piapot Piapot 43 Bow 3 Island Maple Pump Station Pipeline Segment Creek

271

21 Shaunavon

PS8 - Grassy Creek Pump Station Cypress renchma 13 F n R Grassy Creek Lake 37 iv er Pipeline Segment 61 Pakowki Lake Newton 13-21 Lake 18

Taits Lake

M ALBERTA ilk R i ve

r SASKATCHEWAN Keystone XL Pump Station Keystone XL Pipeline Military Base Provincial Park MONTANA First Nations Reserve Fresno 0 10 20 30 40 50 Reservoir

kilometres

123512436-0032 1:1,350,000 NAD 1983 UTM Zone 12N Nelson Reservoir

NU PREPARED BY NT TransCanada Keystone Pipeline GP Ltd. MB

AB PREPARED FOR SK KXL Pipeline Route through Alberta and Saskatchewan BC Area of Interest FIGURE NO.

WA ID MT ND Sources: Project data provided by TransCanada Pipelines Limited. Base data provided by the Governments of Canada, Alberta, and Saskatchewan. 2-1 Last Modified: 12/12/2017 By: bcurry

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Results January 2019

3.0 RESULTS

A complete list of rare plant occurrences, including SARA-listed plant occurrences, on the construction footprint from all surveys from 2008 through 2017 is presented in Appendix D. Appendix D includes construction mitigation measures for each rare plant occurrence. Additional records for rare plants within 30 m of the construction footprint are presented in Appendix E. No mitigation is planned for these occurrences since they have been avoided. However, records outside of the construction footprint are presented provide a full record of observations made during Project surveys, and in case additional workspace is required during construction. The information in Appendix E will be used if the contractor requests additional workspace that could affect rare plants within this area (i.e., within 30 m of the ROW boundary). Supplementary mitigation may be applied depending on the species involved and its ranking, as outlined in Tables 4-1, 4-3, and 4-4.

A complete list of REC records on the construction footprint from all surveys from 2008 through 2017 is presented in Appendix F. Appendix F includes construction mitigation measures for each REC.

Rare Plant and Rare Ecological Community Figures (Appendix G) are provided to illustrate the location of rare plants and REC identified during surveys from 2008 through 2017 for all occurrences on the construction footprint and within 30 m of the footprint. These figures also display all mitigation required for each occurrence on the construction footprint. In addition, construction mitigation measures for each rare plant and REC occurrence on the construction footprint are also summarized in Appendix H (Project Specific Mitigation).

3.1 RARE PLANTS

3.1.1 Alberta

Twelve rare plant species (ranked as either S2 and S3, and on the Alberta tracking or watch list) were identified on or within 30 m of the Project construction footprint in 2017. No S1 species were identified on or within 30 m of the Project construction footprint in Alberta in 2017. In total, 138 individual occurrences of tracked or watched species were found in Alberta. Table 3-1 provides the rare plant occurrences of tracked or watched species in Alberta recorded during the 2017 surveys. Appendices D and E provide a record of all occurrences of rare plants, including points and polygon areas, identified from 2008 through 2017.

Occurrences of slender mouse-ear-cress (Transberingia bursifolia ssp. virgata formerly known as Halimolobos virgata) were found both on the Project footprint and within 300 m in 2017 in Alberta between the Red Deer and South Saskatchewan Rivers (Table 3-1). This species is listed as threatened under SARA and endangered under the Alberta Wildlife Act. Slender mouse-ear-cress occurrences were also found both on the Project footprint and within 300 m during Project previous surveys. Critical habitat has been designated for this species, which overlaps the Project construction footprint (Environment Canada 2012a). Special mitigation for slender mouse-ear-cress is included in Section 4.0 and is indicated

3.1

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Results January 2019 in Appendix D and on the 2018 Environmental Alignment Sheets and the Project-Specific Mitigation Measures and Notes (Environmental Protection Plan).

Another species listed as threatened under SARA and endangered under the Alberta Wildlife Act, is tiny cryptantha (Cryptantha minima), which was found within the 300 m, but not on the Project footprint, during previous surveys in 2008. No occurrences of this species were found either on the Project footprint or within 300 m during surveys in 2017 in the area of the original occurrences or in other suitable habitat in the home range for this species (i.e., between the Red Deer River and the Alberta-Saskatchewan border). Designated critical habitat for this species does not overlap the Project construction footprint (Environment Canada 2012b). Special mitigation for previously identified occurrences of tiny cryptantha within 300 m of the Project footprint is included in Section 4.0 and is indicated in Appendix D and on the 2018 Environmental Alignment Sheets and the Project-Specific Mitigation Measures and Notes (Environmental Protection Plan).

A third species listed as threatened under SARA, smooth goosefoot (Chenopodium subglabrum), has a home range which overlaps the Project construction footprint. No occurrences of this species have been identified during any Project surveys in Alberta.

See Appendix I for a description of each rare plant species found in Alberta, including its rarity and habitat association.

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Table 3-1 Rare Plant Occurrences Identified in 2017 on or within 30 m of the Construction Footprint – Alberta

Species Count Pipeline Section Lakesend Monitor Bindloss Species Common Name Alberta S-Rank Habitat Life Cycle Adaptation to Disturbance 1 Hardisty East South Oyen South South Total Almutaster pauciflorus few-flowered S3 Wetland Perennial Evidence of recovery from 4 2 6 disturbance over time Corispermum americanum American bugseed S2 Upland Annual Evidence of recovery from 1 1 2 disturbance over time Cryptantha minima 2, 3 tiny cryptantha 2, 3 S2 Upland Annual Evidence of recovery from 12 12 disturbance over time Draba reptans whitlow-grass; creeping draba S2 Upland Annual Evidence of recovery from 1 1 disturbance over time Epilobium campestre smooth boisduvalia S3 Wetland Annual Not adapted to disturbance 1 1 Lycopus americanus American water-horehound S3 Wetland Perennial Evidence of recovery from 1 1 disturbance over time Marsilea vestita hairy pepperwort S3 Wetland Perennial Evidence of recovery from 1 1 disturbance over time Mirabilis linearis narrowleaf umbrella-wort S2 Upland Perennial Evidence of recovery from 11 2 13 disturbance over time Oenothera serrulata shrubby evening-primrose S3 Upland Perennial Evidence of recovery from 1 1 2 disturbance over time Potentilla lasiodonta sandhills cinquefoil S3 Upland Perennial Evidence of recovery from 14 21 3 33 71 disturbance over time Potentilla plattensis low cinquefoil S2 Upland Perennial Not adapted to disturbance 1 1 Schedonnardus paniculatus tumble grass S2 Upland Perennial Evidence of recovery from 10 2 12 (Muhlenbergia paniculata) disturbance over time Transberingia bursifolia ssp. slender mouse-ear-cress 2 S2 Upland Biennial/Perennial Evidence of recovery from 15 15 virgata 2 disturbance over time Total 32 25 3 76 2 138 NOTES: 1 Characteristics of species of adapted to disturbance include: annual life history, primary reproduction by seed, adaptation to sandy or dry soils and adaptation to low vegetation cover habitats 2 Tiny cryptantha (Cryptantha minima) and slender mouse-ear-cress (Transberingia) occurrences are located on or within 300 m of the Project footprint. They are included here because this species is listed by SARA as threatened and all occurrences have a 300 m setback (Henderson 2011). 3 Although tiny cryptantha occurrences were not recorded in 2017, this species is included here because this species is SARA-listed.

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3.1.2 Saskatchewan

Thirty-nine rare plant species (ranked S1-S3, and on the Saskatchewan tracking list) were identified on or within 30 m of the Project construction footprint in 2017. In total, 663 occurrences of tracked species were found in Saskatchewan. Table 3-2 provides the rare plant occurrences of tracked species in Saskatchewan recorded during the 2017 surveys. Appendices D and E provide a record of all occurrences of rare plants identified from 2008 through 2017.

One previously unrecorded species listed as threatened under SARA, smooth goosefoot, was found in 2017 at nine locations along the Fox Valley section between 80 m and 300 m from the Project construction footprint in quarter sections: SE 21-14-25 W3, SW 22-14-25 W3, NE 15-14-25 W3, SE 15-14-25 W3 and NW 11-14-25 W3 and one location near Piapot Creek (NE 19-12-23 W3); see Table 3-2. This species has a 300 m setback from disturbance (Henderson 2011). In addition, ECCC- designated critical habitat overlaps the Project construction footprint (Environment Canada 2015). This species is not listed by the Saskatchewan Wildlife Act. Special mitigation for smooth goosefoot is included in Section 4.0 and is indicated in Appendix D and on the 2018 Environmental Alignment Sheets and the Project-Specific Mitigation Measures and Notes (Environmental Protection Plan).

The home ranges indicated in the recovery strategies for both slender mouse-ear-cress and tiny cryptantha overlap the Project construction footprint (Environment Canada. 2012a; 2012b); however, no occurrences of either of these species have been found in Saskatchewan during surveys for the Project and there is no designated critical habitat for either species within 300 m of the Project construction footprint.

See Appendix I for a description of each rare plant species found in Saskatchewan including its rarity and habitat association.

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Table 3-2 Rare Plant Occurrences Identified in 2017 on or within 30 m of the Construction Footprint – Saskatchewan

Species Count Pipeline Section Saskatchewan Bindloss Fox Grassy Species Common Name S-Rank Habitat Life Cycle Adaptation to Disturbance 1 South Valley Piapot Creek Total Alisma gramineum Narrow-leaved Water Plantain S3 Wetland Perennial Evidence of recovery from disturbance over time 2 1 1 4 Almutaster pauciflorus few-flowered aster S3 Wetland Perennial Evidence of recovery from disturbance over time 1 9 10 Alopecurus carolinianus Carolina Foxtail S2 Wetland Annual Evidence of recovery from disturbance over time 3 3 59 65 minima (Lysimachia Chaffweed S3 Wetland Annual Evidence of recovery from disturbance over time 1 1 minima) Astragalus kentrophyta var. spiny milk-vetch S2 Upland Perennial Evidence of recovery from disturbance over time 4 4 kentrophyta Astragalus purshii Pursh's milk-vetch S3 Upland Perennial Evidence of recovery from disturbance over time 1 1 2 Astragalus spatulatus tufted milk-vetch S3 Upland Perennial Evidence of recovery from disturbance over time 2 10 12 Chenopodium subglabrum 2 smooth goosefoot 2 S3 Upland Annual Evidence of recovery from disturbance over time 9 9 Chenopodium watsonii Dakota stinking goosefoot S3 Upland Annual Evidence of recovery from disturbance over time 4 4 Cryptantha celosioides Minerscandle; clustered S2 Upland Perennial Evidence of recovery from disturbance over time 12 58 70 oreocarya Cryptantha kelseyana Kelsey's Cryptantha S2 Upland Annual Evidence of recovery from disturbance over time 1 2 3 Danthonia unispicata few-flowered oat-grass S3 Upland Perennial Evidence of recovery from disturbance over time 1 1 2 Draba reptans whitlow-grass S1 Upland Annual Evidence of recovery from disturbance over time 4 4 Epilobium campestre smooth boisduvalia; smooth S3 Wetland Annual Evidence of recovery from disturbance over time 11 11 spike-primrose Eremogone congesta var. lithophila rocky-round sandwort S3 Upland Perennial Evidence of recovery from disturbance over time 14 69 83 compositus compound fleabane S3 Upland Perennial Evidence of recovery from disturbance over time 2 1 3 confusus few-flowered rush S2 Wetland Perennial Not adapted to disturbance 2 15 17 Juncus interior inland rush S3 Wetland Perennial Not adapted to disturbance 3 3 6 Lupinus pusillus ssp. pusillus small lupine S3 Upland Annual Evidence of recovery from disturbance over time 7 7 Mentzelia decapetala eveningstar S3 Upland Biennial/Perennial Evidence of recovery from disturbance over time 2 2 Mirabilis linearis narrow-leaved umbrella-wort S3 Upland Perennial Evidence of recovery from disturbance over time 20 2 22 apetalus var. borealis awned mousetail S2 Wetland Annual Evidence of recovery from disturbance over time 8 8 Myosurus apetalus var. montanus bristly mousetail S2 Wetland Annual Evidence of recovery from disturbance over time 12 12 Myosurus minimus least mousetail S3 Wetland Annual Evidence of recovery from disturbance over time 39 39 Navarretia saximontana Rocky Mountain S3 Wetland Annual Evidence of recovery from disturbance over time 2 1 8 11 pincushion-plant Oenothera flava ssp. flava low yellow evening-primrose S3 Upland Perennial Evidence of recovery from disturbance over time 3 3 Orobanche ludoviciana Louisiana broom-rape S3 Upland Annual Evidence of recovery from disturbance over time 1 93 25 119 Paronychia sessiliflora low whitlowwort S3 Upland Perennial Not adapted to disturbance 1 1 4 6 Perideridia gairdneri ssp. borealis northern Gairdner's squawroot S1 Upland Perennial Not adapted to disturbance 2 2 Physaria spatulata spatulate bladderpod S3 Upland Perennial Not adapted to disturbance 7 7

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Table 3-2 Rare Plant Occurrences Identified in 2017 on or within 30 m of the Construction Footprint – Saskatchewan

Species Count Pipeline Section Saskatchewan Bindloss Fox Grassy Species Common Name S-Rank Habitat Life Cycle Adaptation to Disturbance 1 South Valley Piapot Creek Total Plantago patagonica var. spinulosa spinulose plantain S2 Upland Annual/Biennial/ Adapted to disturbance 1 1 Perennial Potentilla lasiodonta sandhills cinquefoil S2 Upland Perennial Evidence of recovery from disturbance over time 4 35 2 23 64 Ruppia maritima beaked ditch-grass S3 Wetland Perennial Not adapted to disturbance 1 1 Schedonnardus paniculatus tumble grass S3 Upland Perennial Evidence of recovery from disturbance over time 4 1 2 7 (Muhlenbergia paniculata) Scirpus nevadensis Nevada bulrush S3 Wetland Perennial Not adapted to disturbance 4 4 Sedum lanceolatum ssp. lanceolatum lance-leaf Stonecrop S3 Upland Perennial Not adapted to disturbance 4 4 Sisyrinchium septentrionale northern blue-eyed-grass S3 Upland Perennial Not adapted to disturbance 2 1 3 ascendens western aster S3 Wetland Perennial Not adapted to disturbance 4 4 Townsendia hookeri Hooker's townsendia S1 Upland Perennial Evidence of recovery from disturbance over time 1 24 25 Vulpia octoflora six-weeks fescue S3 Upland Annual Evidence of recovery from disturbance over time 2 2 Total 15 184 65 399 663 NOTES: 1 Characteristics of species of adapted to disturbance include: annual life history, primary reproduction by seed, adaptation to sandy, dry or shifting soils and adaptation to low vegetation cover habitats 2 Smooth goosefoot (Chenopodium subglabrum) occurrences are located between 80 m and 300 m from the Project footprint. They are included here because this species is listed by SARA as threatened and all occurrences have a 300 m setback (Henderson 2011).

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3.1.3 Mitigation Changes due to Updates in Provincial Species Ranks and Species Identification

Table 3-3 indicates rare plant species which were previously included as part of mitigation commitments in the 2013 Environmental Alignment Sheets and Resource Specific Mitigation Tables (NEB filing ID: A52031), but which no longer require mitigation, either because all the occurrences of that species occur in Alberta and that species was subsequently removed from the Alberta provincial tracking list (ACIMS 2018), or because the species was previously mis-identified. The three species previously mis-identified were brown-bracted pussytoes (Antennaria umbrinella), Nevada rush (Juncus nevadensis), and giant wild-rye (Leymus cinereus).

Table 3-3 Species Rank and Identification Changes

Species Common Name Rationale1 Antennaria umbrinella brown-bracted Originally identified as brown-bracted pussytoes (Antennaria pussytoes umbrinella), an S2 species, but subsequently determined to be a mix of two other species, small-leaved everlasting (Antennaria parvifolia) and pink pussytoes (Antennaria rosea), both of which are listed as S4. Astragalus lotiflorus low milk vetch This species was previously listed as S3 tracked but is now listed as S3 do not track. Carex parryana Parry’s sedge This species was previously listed as S3 tracked but is now listed as S3 do not track. Cirsium undulatum wavy-leaved thistle This species was previously listed as S3 tracked but is now listed as S3 do not track. Crepis occidentalis small-flowered This species was previously listed as S3 tracked but is now hawk's-beard listed as S3 do not track. Cymopterus plains spring parsley This species was previously listed as S3 tracked but is now glomeratus listed as S3 do not track. Dalea purpurea purple prairie-clover This species was previously listed as S3 tracked but is now listed as S3 do not track. Epilobium annual willowherb This species was previously listed as S3 tracked but is now brachycarpum listed as S3 do not track. Equisetum smooth scouring-rush This species was previously listed as S3 tracked but is now laevigatum listed as S3 do not track. Erysimum asperum prairie rocket This species was previously listed as S3 tracked but is now listed as S3 do not track. Hedeoma hispida Pennyroyal This species was previously listed as S3 tracked but is now listed as S3 do not track. Hypericum majus large Canada St. This species was previously listed as S3 tracked but is now John's-wort listed as S3 do not track. Juncus nevadensis Nevada rush Originally identified as Nevada rush (Juncus nevadensis), an S1 species, but subsequently determined to be Nevada bulrush (Amphiscirpus nevadensis), which is listed as S3 do not track.

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Table 3-3 Species Rank and Identification Changes

Species Common Name Rationale1 Leymus cinereus giant wild-rye Originally identified as giant wild-rye (Leymus cinereus), an S1 species, but subsequently determined to be Altai wild-rye (Leymus angustus), which is not native to Alberta, and was planted as part of a reclamation seed mix on an adjacent ROW Lomatogonium marsh felwort This species was previously listed as S3 tracked but is now rotatum listed as S3 do not track. Lycopus asper western water- This species was previously listed as S3 tracked but is now horehound listed as S3 do not track. Muhlenbergia marsh muhly This species was previously listed as S3 tracked but is now racemosa listed as S3 do not track. Oenothera nuttallii white evening- This species was previously listed as S3 tracked but is now primrose listed as S3 do not track. Piptatherum little-seed rice grass This species was previously listed as S3 tracked but is now micranthum listed as S3 do not track. Plagiobothrys scouleri Scouler's allocarya This species was previously listed as S3 tracked but is now listed as S3 do not track. Sisyrinchium northern blue-eyed This species was previously listed as S3 tracked but is now septentrionale grass listed as S4 do not track in Alberta. In Saskatchewan, this species is listed as S3 tracked. Spergularia salina salt-marsh sand This species was previously listed as S3 tracked but is now spurry listed as S3 do not track. Sphenopholis prairie wedge grass This species was previously listed as S3 tracked but is now obtusata listed as S3 do not track. Symphyotrichum meadow aster This species was previously listed as S3 tracked but is now campestre listed as S3 do not track. (Aster campestris) Symphyotrichum Eaton's aster This species was previously listed as S3 tracked but is now eatonii listed as S3 do not track. (Aster eatonii) NOTE: 1 Previous S-Rank from Kemper (2009); current S-Rank is from ACIMS (2018)

3.2 RARE PLANT POLYGONS

Where multiple occurrences of a rare plant species were identified within approximately 50 m of each other, a polygon boundary was mapped in the field using a hand-held GPS unit to capture these adjacent occurrences. Occurrences separated by more than approximately 50 m were mapped separately. Occurrences mapped as rare plant polygons are presented in the 2018 Environmental Alignment Sheets and the Project-Specific Mitigation Measures and Notes (Environmental Protection Plan).

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3.3 RARE ECOLOGICAL COMMUNITIES

Several occurrences of RECs were identified along the Project footprint in 2010. Additional occurrences were identified during surveys for the proposed Energy East Project in Alberta in 2013 and 2014 (where the two projects are parallel to each other).

Based on the results of the proposed Energy East surveys, and surveys conducted in 2017, the mapped extent of several RECs identified in 2010 were reduced or expanded. The RECs confirmed in 2017 are presented in Table 3-4. RECs are numbered in alphabetical order. The numbering was changed from the previous Condition 8 filing (NEB filing ID: A40331) because of the addition of several RECs identified during field surveys for the proposed Energy East Project. Several previously identified RECs were not confirmed in 2017 due to limited land access; however, these occurrences will be mitigated. See Appendix F for all REC occurrences identified from 2010 through 2017.

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Table 3-4 Summary of Total Area for Each REC Identified in 2017 along the Project Construction Footprint

Area of REC (ha) Pipeline Section Rare Ecological Community Species Rare Ecological Community Lakesend Monitor Bindloss Code Names Common Name Hardisty East South Oyen South South Fox Valley Piapot Grassy Creek Total REC 01 Acer negundo / Prunus virginiana Forest Manitoba maple / choke cherry forest 0.1 0.1 REC 03 Artemisia cana/Hesperostipa comata - silver sagebrush / needle-and-thread - 7.8 4.4 6.2 18.4 Calamovilfa longifolia shrub herbaceous sand grass shrub herbaceous REC 04 Artemisia cana/Stipa comata - silver sagebrush / needle-and-thread - 6.5 6.5 Pascopyrum smithii - Bouteloua gracilis western wheat grass - blue grama shrub herbaceous shrub herbaceous REC 05 Calamovilfa longifolia - Hesperostipa sand grass - needle-and-thread 8.3 8.3 comata Grassland grassland REC 07a1 hallii - Hesperostipa curtiseta plains rough fescue - western 3.1 3.1 grassland porcupine grass grassland REC 07b1 Festuca hallii - Hesperostipa curtiseta plains rough fescue - western 12.5 12.2 24.8 grassland porcupine grass grassland REC 08a1 Festuca hallii grassland Plains rough fescue grassland 3.7 12.4 16.1 REC 09 Pascopyrum smithii - Carex duriuscula western wheat grass - low sedge 0.8 3.5 4.3 meadow meadow REC 10 Puccinellia nuttalliana community Nuttall's salt-meadow grass community 1.5 0.1 1.6 REC 13 Sarcobatus vermiculatus / Distichlis stricta greasewood / salt grass - western 4.1 4.1 - Pascopyrum smithii shrub herbaceous wheat grass shrub herbaceous vegetation vegetation REC 14 Sporobolus cryptandrus semi-active dune Sand dropseed Semi-active dune 0.1 0.1 Total 3.7 29.5 13.0 11.3 0.0 12.8 4.2 12.7 87.2 NOTE: 1 REC 07 and REC 08 are divided into healthy and unhealthy communities following Alberta Rangeland Health Assessment methods (Adams et al. 2016) where fescue communities were determined to be healthy if they had at least 30% native grass species cover and unhealthy if they had less than 30% native grass species cover. Unhealthy communities are indicated as REC 07a or REC 08a and healthy communities as REC 07b in Appendix F and the 2018 Environmental Alignment Sheets and Project-Specific Mitigation Measures and Notes (see /EPP, Appendix 1Q and 1P, respectively). No REC 08 communities were determined to be healthy, so none are classified as REC 08b.

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4.0 MITIGATION

4.1 MITIGATION STRATEGIES

Mitigation strives to avoid or reduce effects on rare plant species and RECs. When avoidance of rare plants and RECs is not possible given Project design constraints, mitigation planning assesses how best to reduce effects on rare plants and RECs.

Mitigation strategy development included all rare plant species found on or within 30 m of the Project disturbance footprint during the 2008 to 2011,2013 (during surveys for the Energy East Project where the two projects are parallel), 2014 (for the Energy East Project and Vantage Parallel areas), and 2017 surveys.

The mitigation strategy uses a risk-based approach that considers the:

• rarity of the plant or community locally and provincially • threat to the plant or community • biological characteristics of the plant or community • seral stage of the associated plant community • effectiveness of previous mitigation • response to disturbance

The following sections provide mitigation strategies for rare plants (both upland and wetland species) and RECs.

4.1.1 Avoidance of Effects on Rare Plants and Rare Ecological Communities

Avoiding rare plants and RECs is the most effective technique to mitigate Project effects. The avoidance strategy considered the flexibility of the Project footprint and the rarity of the species potentially affected.

4.1.2 Reducing Effects on Rare Plants and Rare Ecological Communities

If avoidance is not feasible, the following range of measures was considered to mitigate effects on rare plant species and RECs:

• reduce the disturbance footprint and the amount of soil stripping and grading • reduce disturbance effects by using geotextiles, soil ramps, swamp mats or silt fencing • implement selective topsoil seedbank salvage (for rare plant sites) • remove grade materials stored on the existing sod layer from the sod prior to the start of the subsequent growing season. This applies to REC 07 and REC 08 areas only • leave topsoil stockpiles in place until final cleanup. This applies to REC 07 and REC 08 areas only.

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• use a combination of prairie protector and prairie sweeper equipment to minimize effects on the sod layer caused from scalping and deposition. This applies to REC 07 and REC 08 areas only • re-establish suitable habitat after construction is complete

Mitigation will be site- and species-specific and will vary depending on seasonal conditions and site conditions as described in the Project Specific Mitigation (Appendix H). Reclamation seed mixes or seeding rates may need to be adjusted to protect rare plants from competition and to facilitate natural recovery from the effects of construction. Re-establishing associated species or abiotic site conditions may be required to reduce the potential for changes in plant community composition.

4.1.3 Species-specific Mitigation Strategies

Species-specific mitigation developed by the Company is based on the species rarity, the nature of predicted effects, the life cycle (annual or perennial), the associated habitat, and also construction engineering constraints, including the need for grading on slopes. Mitigation decisions were made by an interdisciplinary Project team, consisting of a rare plant specialist, construction and environmental personnel, and land managers.

Research was conducted for each rare species that occurs within 30 m of the Project footprint to determine:

• Current taxonomy as determined by ACIMS (2018) and SK CDC (2018) • Provincial rarity rank as determined by ACIMS (2018) and SK CDC (2018) and national rank by NatureServe (2017) (see Appendix A for rarity rank definitions); • Legal listing as determined by legislation (Species at Risk Act, Saskatchewan’s Wildlife Act, and Alberta’s Wildlife Act); • Information on growth habitat, life cycle (i.e. annual, biennial or perennial) and other pertinent information such as limits to reproduction, tolerance to drought, shade, alkalinity etc.; • Propagation methods if reported; and • Associated habitat in Alberta and Saskatchewan, using field data, floras, and records from ACIMS (2018) and SK CDC (2018);

Background information for each rare plant species gathered during literature reviews is presented in Appendix I.

4.1.4 Mitigation Strategies for Rare Plants

4.1.4.1 Upland Rare Plant Species

Upland Vegetation Response to Disturbance

Ecological processes are affected when the soils, vegetation cover, or the hydrologic characteristics of a plant community are disturbed (Gibson 2009, Stringham et al. 2003). This can result in a different set of plant communities establishing on the site once disturbance has ended (Stringham et al. 2003). A disturbed and reclaimed early seral community does not necessarily transition over time to the pre-disturbance plant community (Adams 2009, Desserud 2006). As such, avoiding or minimizing construction-related disturbance to soil structure, soil layers, and surface vegetation is likely to provide

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Mitigation January 2019 the most effective mitigation for most species and communities. For instance, minimal disturbance and reclamation practices were observed to have greater importance in promoting reclamation success in fescue grasslands compared solely to time since disturbance (Desserud et al. 2010). Invasive non-native species have increasing influence on the composition of plant communities responding to disturbance (Gibson 2009).

Species or plant communities naturally associated with exposed substrates or periodic disturbance may be more resilient to construction disturbance effects. For instance, natural recovery of grassland vegetation on pipeline ROWs on sandy soils can be rapid and can result in a community consistent with the surrounding undisturbed grasslands (AXYS Environmental Consulting Ltd. 2003).

Mitigation Strategies for Disturbance-adapted Upland Species

Characteristics for plant species and communities adapted to disturbance include annual life history, primary reproduction by seed, adaptation to sandy, dry or shifting soils and adaptation to low vegetation cover habitats. Mitigation for species and communities adapted to disturbance is guided by the assumption that seed for re-colonization exists naturally in the seed bank, and if this seed bank can be conserved, it will re-establish if suitable site and climate conditions are present. Accurate stripping and replacement of topsoil, erosion control, and use of a nurse crop are appropriate measures to assist natural recovery. Timely replacement of topsoil is beneficial for conserving plant resources in the soil. Stripped topsoil that is stored over the winter and re-handled the following growing season can lead to reduced plant community cover and diversity, compared with topsoil that is replaced immediately after construction (Gramineae Services Ltd. 2008).

Mitigation Strategies for Species Associated with Mid and Late Seral Communities

Mitigation for species or communities associated with mature or mid to late seral vegetation associations has the most variability. However, as with all communities, reducing disturbance by constructing during suitably dry ground conditions will increase the probability of mitigation success.

4.1.4.2 Wetland Rare Plant Species

Wetland Vegetation Response to Disturbance

Wetland vegetation is affected by four main environmental factors: water regime, fertility, salinity, and disturbance (Adams 1988). As with upland native range vegetation communities, measures that avoid or reduce disturbance to soil structure, soil layers, and surface vegetation are likely to provide effective mitigation for species and communities. However, wetlands are typically more resilient to natural and anthropogenic disturbance compared with mid to late seral upland communities. Zonation patterns of wetland vegetation communities occur in response to changing environmental conditions in the wetland (Keddy 2000). Natural disturbances include fire, flood, drought, grazing, trampling, and ice scour. Wetlands contain large sources of buried viable seed capable of responding to disturbance (as summarized in Keddy 2000).

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Barriers to restoration of wetlands include:

• Weed invasion, particularly in the more vulnerable shallow low prairie and wet meadow wetland zones; (Seabloom and van der Valk 2003) • Drought and invasive non-native species, which can affect the post-disturbance community composition (Aronson and Galatowitsch 2008, Cronk and Fennessy 2001) • Flooding of seed or seedlings in the wet prairie and sedge meadow zones, which serve as seed sources, can affect recruitment of plants (Cronk and Fennessy 2001) • Long-term storage of piled topsoils, which can result in seed and propagule mortality (Mackenzie 2013, Alberta Environment and Water 2012)

Mitigation Strategies for Wetland Rare Plants

Due to the scale of the Project, the size of the pipe, and the density of wetlands on the pipeline route, avoiding all wetlands is not feasible. One hundred and forty-two wetlands crossed by the pipeline support rare plants including: one wetland with species ranked S1; 77 with species ranked S2; two with species ranked S2S3; and 62 with species ranked S3. Wetland surveys did not identify any threatened or endangered Schedule 1 SARA-listed plant species within the wetlands traversed by the Project.

Construction mitigation measures for crossing wetlands that support rare plant species are presented in Section 4.2 and in the Comprehensive Wetland Surveys, Wetland Crossing Framework, and Reclamation Monitoring Overview (Condition 10) report pursuant to Condition 10 (filed in September 2018). The Company assessed potential options for avoidance such as trenchless crossings or route changes. The avoidance options were reviewed and considered, along with mitigation measures for locations where the construction footprint intersected wetlands. The Company determined that the additional disturbance footprint and associated workspaces required for avoidance options such as trenchless crossings did not increase the level of environmental protection. Trenchless crossings require pipe lay-up areas, additional access, more equipment; and result in increased traffic and longer duration of work. Therefore, the Company developed site-specific construction mitigation drawings and measures as described in the Comprehensive Wetland Surveys, Wetland Crossing Framework, and Reclamation Monitoring Overview (Condition 10) report (filed in September 2018).

For a description of the 2017 and 2018 wetland survey results and construction mitigation measures for crossing wetlands, see the Comprehensive Wetland Surveys, Wetland Crossing Framework, and Reclamation Monitoring Overview (Condition 10) report pursuant to Condition 10 (filed in September 2018). The guiding assumptions for restoration of rare plant species in wetlands affected by pipeline construction are: if salinity remains stable, fertility is regained over time and the hydrological regime in the wetland is maintained, seed from the wetland seedbank will naturally re-colonize the wetland.

Most of the rare plant species found during the rare plant surveys in wetlands are annual plants that colonize mineral soils exposed by grazing, trampling, or seasonally receding water levels. Stripping and replacing topsoil will help conserve the seedbank of wetland adapted plants. Restoring the pre-construction topography and water flow patterns will re-establish wetland hydrology.

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4.1.4.3 Supplemental Mitigation Strategies for Rare Plants

In addition to construction mitigation measures, supplemental mitigation may be required before construction or during final clean-up to improve the likelihood of restoring populations of rare plants affected by Project construction. Decisions on whether to conduct supplemental mitigation will depend on the seasonal timing of construction and whether the construction footprint will affect rare plant populations.

Selective Topsoil Seedbank Salvage

Selective topsoil stripping will be conducted for one wetland where an S1-listed species, quillwort (Lilaea scilloides), has been documented. Selective topsoil stripping involves removing topsoil in two phases. The top 5 cm is stripped first and then the remainder of the topsoil is stripped in a second lift. The first and second lift materials are place separately in storage areas on the construction footprint. Upon completion of lowering in and back-fill, the two soil layers are replaced in the reverse order.. This technique was used on TransCanada’s Keystone Project in 2009. Post-construction monitoring for that project identified successful re-establishment of SARA-listed slender mouse-ear-cress across the full width of the reclaimed disturbance footprint in areas where this technique was used (TransCanada Keystone Pipeline GP Ltd. 2017 [NEB filing ID: A81553]).

Seed Collection

Replacement of seed rather than propagated seedlings (i.e., transplantation) allows the seed to germinate when site and climate conditions are suitable. Planting propagated seedlings may accelerate re-establishment, but there is also the risk of seedling failure in the harsh conditions of the exposed soils on a newly reclaimed ROW. Therefore, seed collection, was the preferred option for the Project. Transplantation was, however, conducted for one upland, S2-listed plant species, low cinquefoil (Potentilla plattensis), in July 2011.

4.1.5 Mitigation Strategies for Rare Ecological Communities

Caution will be used when seeding areas with RECs to reduce changes in species composition. Seed mixes were discussed with provincial regulatory authorities in 2018, and were revised to remove aggressive species and cultivars which could modify the RECs. Seed mixes are presented in the EPP, Appendix 1M.

4.2 CONSTRUCTION MITIGATION MEASURES

Construction mitigation for rare plants considers legal status, rarity, whether the species is associated with uplands or wetlands, and whether it is adapted to disturbance or associated with an early seral plant community. The proposed construction mitigation for rare plants, developed following regulatory consultation, is provided in the 2018 Environmental Protection Plan and will be implemented by the Company and its’ Contractor.

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4.2.1 Construction Mitigation for SARA-listed Plants

The Project disturbance footprint passes through areas defined as critical habitat for the SARA-listed plants species tiny cryptantha (Cryptantha minima) and slender mouse-ear-cress (Halimolobos virgata) in Alberta and smooth goosefoot (Chenopodium subglabrum) in Saskatchewan. It also directly affects known locations of slender mouse-ear-cress in Alberta. There are no known occurrences of tiny cryptantha or smooth goosefoot directly on the Project footprint; thus no direct effects on any known populations of these species are anticipated.

4.2.1.1 SARA-listed Plant Mitigation Measures

Detailed construction mitigation for occurrences of SARA-listed plant critical habitat and SARA-listed plants are used in combination with the general measures identified above and provided in the Rare Plant and Rare Ecological Community Figures (Appendix G), the Project Specific Mitigation (Appendix H), and the Project-Specific Mitigation Measures located in the 2018 Environmental Protection Plan.

ROW workspace and applicable restrictions are depicted on the construction grade plans. Mitigation must be reviewed and understood by the Contractor as it relates to restrictions associated with occurrences and critical habitat of tiny cryptantha, slender mouse-ear-cress, and smooth goosefoot in the quarter sections provided in Table 4-1.

Table 4-1 Quarter Sections containing Occurrences within 300 m or Critical Habitat crossed by the Project Footprint

Species Common Name Province Quarter Section Cryptantha minima tiny cryptantha Alberta NE 13-22-4-W4 NW 18-22-3-W4 NE 17-22-3-W4 NW 16-22-3-W4 SW 16-22-3-W4 SE 16-22-3-W4 NE 9-22-3-W4 SW 10-22-3-W4

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Table 4-1 Quarter Sections containing Occurrences within 300 m or Critical Habitat crossed by the Project Footprint

Species Common Name Province Quarter Section Halimolobos virgata slender mouse-ear-cress Alberta NE 13-22-4-W4 NW 13-22-4-W4 NW 18-22-3-W4 NE 18-22-3-W4 NW 17-22-3-W4 NE 17-22-3-W4 NW 16-22-3-W4 SW 16-22-3-W4 SE 16-22-3-W4 NE 9-22-3-W4 NE 13-22-3-W4 NE 03-22-3-W4 NW 02-22-3-W4 SE 02-22-3-W4 SE 36-21-3-W4 Chenopodium subglabrum smooth goosefoot Saskatchewan SE 30-12-23-W3 NE 19-12-23-W3 NW 11-14-25-W3 SE 15-14-25-W3 SW 14-14-25-W3 SE 21-14-25-W3 SW 22-14-25-W3

4.2.2 Construction Mitigation for Provincially-listed Rare Plants

Construction mitigation for rare plants ranked by ACIMS and SK CDC considers the proposed timing of construction during a period when predominately dry ground conditions are anticipated. Final clean-up and reclamation seeding will occur during unfrozen ground conditions, apart from one instance where late-fall or winter clean-up may be conducted as part of the prescribed mitigation (see Project-Specific Mitigation Measures and Notes located in the 2018 Environmental Protection Plan). No mitigation measures beyond standard soil handling practices are planned for occurrences of S3-listed species and for that reason they are not shown the 2018 Environmental Alignment Sheets or Project-Specific Mitigation Measures and Notes; however, they are shown on the Rare Plant and Rare Ecological Community Figures (see Appendix G).

Wetland crossing drawings are provided in the Comprehensive Wetland Surveys, Wetland Crossing Framework, and Reclamation Monitoring Overview (Condition 10) report pursuant to Condition 10 (for Condition 10 filed in September 2018) and in Appendix 1D of the Environmental Protection Plan.

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4.2.3 Construction Mitigation for Rare Ecological Communities

The locations of each occurrence from Table 3-4, including construction mitigation measures, are presented in Appendices F and G, and in the 2018 Environmental Protection Plan.

In areas where the Project disturbance footprint parallels the Keystone XL project through a healthy Plains rough fescue – western porcupine community (REC 07b), the Companywill reduce the Project footprint by reducing the distance between the Keystone XL operating pipeline and the proposed Keystone XL pipeline trench. See drawing 1399-03-ML-932 in Appendix 1D of the Environmental Protection Plan.

At the crossing of Bone Creek in Saskatchewan, the Project will avoid the beaked willow/red osier dogwood community (REC 10) by removing the abandoned Foothills pipe section and using this space for placement of the Keystone XL pipeline.

4.3 SUPPLEMENTAL MITIGATION FOR RARE PLANTS

Seed collection has been identified as the primary supplemental mitigation for the Project. Seed collection for a particular rare plant species was dependent on species occurrence based on provincial rarity ranks (ACIMS 2018a and SK CDC 2018), legal status, life cycle, physical characteristics of the plant, and whether it is adapted to disturbance or associated with an early or later seral plant community. Transplantation was identified as secondary supplemental mitigation and was completed for one S2-listed species. Seed collection and transplantation for occurrences of rare plant species is summarized in Tables 4-2 and 4-3. Further information on each species, its occurrence, and location in specific wetlands, and Figures Sheets are presented in Appendices D and G. Further information on the characteristics of each rare plant species potentially affected by the Project is presented in Appendix I.

4.3.1 Rare Plants Associated with Uplands

Responses of upland vegetation to disturbance are discussed in Section 4.1.4.1. Pre-construction mitigation for some species included seed collection, where seed size, timing, and seasonal conditions permited. Mature seed was collected from individual rare plants and will be re-introduced onto the Project disturbance footprint following final clean-up. Location of seed mix application or seeding rates may be adjusted based on site conditions at the time of reclamation.

Table 4-2 lists upland rare plant species ranks for which seed was collected based on rarity rankings and disturbance adaptation.

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Table 4-2 Supplementary Mitigation for Rare Plants Associated with Uplands

Adaptation to Rarity Rank Disturbance Life Cycle Supplementary Mitigation S1 and S1S2 Not adapted to bare Perennial, Seed collected for post-construction re-introduction soils or disturbance; or Biennial or mid to late seral Annual Adapted to bare soils or Perennial, Seed collected for post-construction re-introduction disturbance; or early Biennial or seral Annual S2 and S2S3 Not adapted to bare Perennial, Seed collected for post-construction; whole plant soils or disturbance or Biennial or transplantation (completed for one species at two mid to late seral Annual locations) Adapted to bare soils or Perennial Seed collected for post-construction re-introduction disturbance or early seral Biennial or No mitigation measures are planned beyond Annual standard soil handling practices for native upland areas S3 and S3S4 Disturbance Perennial, No mitigation measures are planned beyond adapted/non-adapted; Biennial or standard soil handling practices for native upland any seral stage Annual areas

4.3.2 Rare Plants Associated with Wetlands

Responses of wetland vegetation to disturbance are discussed in Section 4.1.4.2. A guiding assumption for restoration of rare plant species in wetlands is that seed from the wetland seedbank will naturally be redistributed by water and will re-colonize exposed soils. Most of the rare plant species of concern are annual plants that colonize mineral soils exposed by grazing, trampling, or seasonally receding water levels. Stripping and replacing topsoil and re-establishment of drainage pattern within the wetland basin (e.g., no roach over the pipe) will help conserve the wetland seedbank and permit natural circulation of water and seed in the basin.

Pre-construction mitigation for some species included seed collection. Mature seed collected from individual rare plants will be re-introduced into the wetland during reclamation.

Table 4-3 lists wetland rare plant species ranks for which seed was collected based on rarity rankings and disturbance adaptation

Table 4-3 Supplementary Mitigation for Rare Plants Associated with Wetlands

Adaptation to Rarity Rank Disturbance Life Cycle Potential Supplementary Mitigation S1 and S1S2 Not adapted to bare Perennial Seed collected for post-construction re-introduction soils or disturbance; Biennial or Seed collected for post-construction re-introduction or mid to late seral Annual

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Table 4-3 Supplementary Mitigation for Rare Plants Associated with Wetlands

Adaptation to Rarity Rank Disturbance Life Cycle Potential Supplementary Mitigation Adapted to bare soils Perennial, Seed collected for post-construction re-introduction or disturbance; or Biennial or early seral Annual S2 and S2S3 Not adapted to bare Perennial, Seed collected for post-construction re-introduction soils or disturbance or Biennial or mid to late seral Annual Adapted to bare soils Perennial Seed collected for post-construction re-introduction or disturbance or Biennial or No mitigation measures are planned beyond standard early seral Annual soil handling practices for native wetland areas S3 and S3S4 Disturbance Perennial, No mitigation measures are planned beyond standard adapted/non-adapted; Biennial or soil handling practices for native wetland areas any seral stage Annual

4.3.3 Seed Collection and Transplantation Completed

In 2011 and 2012, seed was collected for three rare plant species including one SARA-listed species in Alberta, and nine rare plant species in Saskatchewan (Table 4-4). Collected seed was placed in cold storage when collected and was tested for viability in 2017. The test results confirmed that a proportion of seeds of all species were viable and that seed from each of the species can be used for rare plant mitigation during reclamation. The seeds collected in 2011 and 2012 will be seeded in the vicinity of the collection location in appropriate habitat on the construction footprint following final clean-up. Individual plants from one upland, S2-listed plant species, low cinquefoil (Potentilla plattensis), were transplated in July 2011 from one location on the Construction footprint to similar habitat nearby outside of the Construction footprint. Seed was collected from individuals of low cinquefoil at other locations and will be seeded in the vicinity of the collection location in appropriate habitat on the construction footprint following final clean-up.

Seed collection for two species was conducted in 2017 in Alberta (slender mouse-ear-cress [Transberingia bursifolia ssp. virgata] and narrowleaf umbrella-wort [Mirabilis linearis]) from locations on the construction footprint (Table 4-4). Additional seed collection was completed in 2018 for narrowleaf umbrella-wort in Alberta due to limited collection in 2017. Seed from two additional species, tumble grass (Schedonnardus paniculatus) and American bugseed (Corispermum americanum) was also collected in Alberta in 2018 (Table 4-4).

In Saskatchewan, seed collection and transplantation are both no longer permissible mitigation options (Government of Saskatchewan 2016, confirmed during consultation with SK MOE (Dillabaugh 2017 pers. comm.; see Section 6.0 and Appendix C)); therefore, no additional 2017 and 2018 seed collection or transplantation was made in Saskatchewan and no transplantation was previously conducted in Saskatchewan. The SK MOE has agreed to allow replacement of the 2011 and 2012 previously collected seed on the reclaimed construction footprint as mitigation for potential effects on those species.

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Table 4-4 Date of Seed Collection and Transplantation for Rare Plant Species

Month and Year Species Common Name Province Pipeline Segment Collected Transberingia bursifolia slender mouse-ear- Alberta Oyen South June 2011, ssp. virgata cress June 2012, July 2017 Lysimachia hybrida lance-leaved Alberta Monitor South, August 2011, loosestrife Hardisty August 2012, September 2012 Potentilla plattensis low cinquefoil Alberta Hardisty July 2011 (both seed collection and transplantation) 1 Mirabilis linearis narrowleaf umbrella- Alberta Hardisty, Oyen August 2017, wort South August 2018 Schedonnardus tumble grass Alberta Bindloss South, August 2018 paniculatus Oyen South Corispermum American bugseed Alberta Lakesend, Hardisty August 2018 americanum Alopecurus Carolina foxtail Saskatchewan Grassy Creek August 2011 carolinianus Astragalus purshii Pursh’s milk-vetch Saskatchewan Grassy Creek July 2011 Astragalus spatulatus tufted milk-vetch Saskatchewan Grassy Creek July 2011, August 2011 Cryptantha celosioides clustered oreocarya Saskatchewan Grassy Creek July 2011 Danthonia californica California wild oat Saskatchewan Grassy Creek, August 2011, grass Piapot August 2012 Danthonia unispicata few-flowered oat-grass Saskatchewan Grassy Creek July 2011 Juncus confusus few-flowered rush Saskatchewan Grassy Creek, August 2011 Piapot Physaria spatulata spatulate bladderpod Saskatchewan Grassy Creek July 2011 Ranunculus heart-leaved buttercup Saskatchewan Piapot July 2011 cardiophyllus NOTE: 1 Transplantation of whole plants was completed for low cinquefoil (Potentilla plattensis) at one location and seed was collected at several locations and will be reseeded in the vicinity of the collection location at final cleanup; for all other species only seed was collected.

4.4 MITIGATION FOR RARE ECOLOGICAL COMMUNITIES

The mitigation goal for RECs is recovery of the pre-disturbance plant community. Native grasslands are complex natural systems and the processes for restoring these ecosystems are not yet well understood. Limited information is available on reclamation success where recent enhanced reclamation criteria have been applied to pipeline reclamation assessments.

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Recovery over a five-year period towards the pre-disturbance plant communities is documented for unstripped spoil storage areas and unstripped travel lanes (AXYS Environmental Consulting Ltd. 2003). Re-establishment of native plant communities on stripped soils is less certain and more challenging. New information from long-term post-construction monitoring of the Express Pipeline 14 years after construction shows the following trends (Kestrel Research Inc. and Gramineae Services Ltd. 2011):

• Some seeded native cultivars, such as green needle grass and northern sand reed grass are persistent and prominent, and do not occur in adjacent areas outside of the disturbance footprint • Other seeded cultivars, such as slender wheatgrass, provided initial cover as planned and are now disappearing from the stand, creating space for native species to move in • The groundcover structural layer is still absent from both seeded and natural recovery reclaimed sites after 14 years of re-growth • Better establishment of key species from the seedbank, such needle-and-thread and western porcupine grass, occurs when soils are not stored over the winter and re-handled the following growing season

Other earlier observations from Express pertinent to designing mitigations for RECs are presented below, including information sourced from the Express Pipeline 5-year monitoring study, the 8-year tour, and the 2010 monitoring study (AXYS Environmental Consulting Ltd. 2003, Gramineae Serviced Ltd. 2008):

• Weed species of concern, present on site or in close proximity prior to disturbance, can influence the outcome of a natural recovery revegetation strategy • Weed control during the first three years post-construction is very important for revegetation success • When constructing in solonetzic soils, changes in vertical and horizontal structure occur after construction, resulting in more vigorous growth and a plant community that may be different from the surrounding plant community • Temporary fencing should not be in place for more than a few growing seasons (fencing and absence of grazing can affect species diversity if the fencing remains in place too long; however, spring and summer grazing on the newly reclaimed RoW in early years can affect the establishment of desirable species) • Use locally developed native plant material, such as native plant cultivars developed by Alberta Research Council and the Ducks Unlimited Ecovar programs

The reclamation strategies most likely to result in restoring RECs are natural recovery and assisted natural recovery, or the inclusion of species in seed mixes that are present in the community prior to disturbance. Persistent reclamation cultivars that are not of similar origin (i.e. provenance) to the REC species may alter the resultant plant community. The use of straw crimping, natural recovery, and local seed materials were considered to promote recovery of RECs. Locally sourced and developed cultivars may be used where the seed bank has already been affected. Natural recovery can be assisted by use of cover crops to control erosion, develop litter, or shade native seedlings. For all RECs, successful mitigation is contingent on replacing topsoil and completing final clean-up under non-frozen ground conditions.

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The following sections describe the approach for each REC found on the Project:

Manitoba Maple / Chokecherry (REC 01)

Currently no effects on this REC are anticipated because it is outside of the Project footprint.

Silver Sagebrush – Needle and Thread (REC 03 and REC 04)

Two similar Silver Sagebrush – Needle and Thread RECs are crossed by the Project footprint:

• Silver Sagebrush / Needle-and-Thread – Sand Grass (REC 03) • Silver Sagebrush / Needle-and-Thread – Western Wheat Grass – Blue Grama (REC 04)

These RECs are found on thin breaks and overflow sites near the Red Deer River and the Frenchman River on steep slopes and also in flatter areas. A recent study indicates that sagebrush re-establishes well after pipeline construction disturbance when allowed to recover naturally (Hickman 2010). The primary mitigation technique for silver sagebrush RECs on flatter areas will be straw crimping or assisted natural recovery with use of an annual cover crop in the first year to limit erosion of surface soils and build litter over time. It will be important to replace topsoil and complete final clean-up under non-frozen ground conditions. On steep slopes, the standard native seed mix for the area will be used due to erosion concerns.

Sand Grass – Needle-and-Thread (REC 05)

The primary mitigation technique for this REC will be assisted natural recovery with an annual cover crop in the first year to limit erosion of surface soils and build litter over time.

Silverberry / Western Wheat Grass Shrubland (REC 06)

This REC was not confirmed in 2017 due to limited land access; however, previously identified occurrences of this REC will be mitigated. Mitigation for this REC will be natural recovery. The use of a cover crop will be considered in subsequent years if erosion or poor vegetation establishment are observed.

Plains Rough Fescue (REC 07a, b and REC 08a)

Two similar Plains Rough Fescue RECs are crossed by the Project footprint:

• Plains Rough Fescue – Western Porcupine Grass (REC 07a, b) • Plains Rough Fescue Grassland (REC 08a)

REC 07 and REC 08 are divided into healthy and unhealthy communities following Alberta Rangeland Health Assessment methods (Adams et al. 2016) whereby fescue communities are determined to be healthy if they have at least 30% native grass species cover and unhealthy if they have less than 30% native grass species cover. Unhealthy communities are indicated as REC 07a or REC 08a, and healthy communities as REC 07b, in Appendix F and the 2018 Environmental Alignment Sheets and

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Project-Specific Mitigation Measures and Notes (see EPP, Appendix 1Q and 1P, respectively) (Environmental Protection Plan).

The mitigation will be to seed plains rough fescue and western porcupine grass using seeds that are local in origin if available.

It is important to be patient when trying to re-establish rough fescue. It is not a pioneer species but has been observed to establish and expand cover between five and 14-year after seeding (AXYS Environmental Consulting Ltd. 2003; Kestrel Research Inc. and Gramineae Services Ltd. 2011). It is also important to manage domestic livestock grazing on reclaiming areas in the first few years, minimizing spring and summer grazing when seedlings are most vulnerable.

Western Wheatgrass – Low Sedge (REC 09)

This REC grows on shorelines of wetlands and seasonally moist basins. Standard wetland crossing methods will be employed for occurrences associated with wetlands. Native Range Topsoil Conservation (see typical drawing 1399-03-ML-050901, Appendix 1D of the Environmental Protection Plan) will be used in upland occurrences. Both western wheatgrass and low sedge are rhizomatous and are expected to recover naturally.

Nuttall’s Salt Meadow Grass (REC 10)

The Nuttall’s salt meadow grass REC is a wetland plant community. Natural recovery will be the primary mitigation strategy.

Greasewood / Salt Grass – Western Wheat Grass (REC 13)

This REC grows on moist to sub-irrigated saline soils. The occurrence is in a saline lowland discharge area south of Highway 13 southwest of Shaunavon. The proposed mitigation is to allow salt grass, western wheat grass and greasewood to re-establish naturally from the seed and propagule bank. It will be important to replace topsoil and complete final clean-up under non-frozen ground conditions to conserve the of these grasses since plant recolonization in saline environments is often slower than in other soil types.

Sand Dropseed Semi-active Dune (REC 14)

Since this plant community relies on sand dune activity, suitable mitigation will be to allow the site to revegetate naturally. However, this approach will need to be balanced against requirements to maintain adequate depth of cover over the buried pipe.

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5.0 ASSESSING MITIGATION SUCCESS

5.1 DETERMINING THE EXTENT OF NON-AVOIDABLE EFFECTS

Certificate OC-56 Condition 9 requires a plan for the provision and implementation of offset measures for all non-avoidable impacts on rare plants (including SARA-listed plants) and RECs. In accordance with Condition 9, post-construction surveys will be conducted to determine the extent of non-avoidable disturbance to rare plants, RECs and their associated habitat, and to monitor post-construction recovery.

The pre-disturbance delineation of occurrences of rare plants and RECs on the Project footprint will serve as the baseline. The finalized boundaries of the construction footprint (i.e., permanent and temporary ROW plus temporary workspace) will be used to define the area within which direct effects on rare plants and RECs will occur during construction.

Monitoring surveys will be conducted through the five-year post-construction environmental monitoring period to assess recovery of rare plants and RECs on the footprint. At the end of the five-year monitoring period, an assessment of non-avoidable effects will be made. The Company will determine the Offset Measures Plan in consultation with provincial auhtorities in accordance with Condition 9.

5.2 POST-CONSTRUCTION MONITORING

Follow-up monitoring provides quantitative data to assess mitigation success, to allow informed choices about future mitigation, and to determine whether offsets are required.

5.2.1 Rationale for Post-Construction Monitoring

Monitoring of reclamation progress over at least five years is necessary for several reasons. On native grassland sites, the initial few years following reclamation typically sees the establishment of a pioneer plant community (Adams 2009, AXYS Environmental Consulting Ltd. 2003). During this time, intervention can be used to modify the pioneering plant community as required (e.g., weed control, re-seeding). Five years or more post-disturbance, a more mature (early to late seral) plant community may establish. This might include more desirable species characteristic of pre-disturbance conditions (Adams 2009, AXYS Environmental Consulting Ltd. 2003, Kestrel and Gramineae 2011). However, early seral communities do not inherently transition over time to restore pre-disturbance plant communities, but instead may result in a quite different plant community, which may be dominated by less desirable species (Adams 2009, Desserud 2006). Rare plant populations or RECs may not recover within the first five years following disturbance. Longer term monitoring may be required (e.g., 10 years+ post-reclamation) to provide evidence of recovery, or the potential for recovery, of rare plants and RECs, or to confirm that recovery is unlikely.

Additional reasons for monitoring rare plant communities for at least five years include:

• Long-term monitoring can document natural fluctuations in rare plant populations

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• Long-term monitoring can account for climatic variability (e.g., perennials can become dormant if climatic conditions are not conducive to growth and seed from annual plants may not germinate in a year with poor conditions) • Re-introduced seed or seed from the seedbank may not germinate until microsite conditions are favorable (e.g., establishment of a shaded overstorey) • Initial re-establishment of individuals may not persist over time as site conditions change

5.2.2 Scope of Post-Construction Environmental Monitoring

SARA, S1, S2and S3-ranked rare plants that will be affected by pipeline construction will be monitored to assess the effectiveness of the mitigation measures employed by the Company. Where more than three occurrences will be affected), a subset of occurrences (applies only to S3 ranked species) representative of soil and moisture conditions of the larger group will be monitored (e.g., rare annuals in wetlands). If inconsistent recovery results occur in the survey subset, monitoring will be expanded to include more occurrences.

Similarly, each REC that will be affected by pipeline construction will be monitored to test the effectiveness of the mitigation measures employed.

5.2.2.1 Documenting Avoidance

The first year of monitoring will include documenting occurrences that were successfully avoided during construction. If no changes have occurred that affect the microhabitat of the rare plant or REC (e.g., alteration of water drainage patterns), these areas will not be included in the remaining four years of monitoring. The NEB, ACIMS, and SK CDC will be notified of their status.

5.2.2.2 Documenting Effects

Occurrences where communities or individuals have been affected by construction will be monitored annually for five years. In a five-year time span, vegetation cover on surface disturbances should reach over 60% cover (or equivalent to off-site cover if off-site cover is less than 60%) on both stripped and unstripped areas. The species composition should be primarily native reclamation cultivars and native species from the seed and propagule bank. A successional transition from a pioneer to an early seral, sustainable native grassland community should be establishing and ecosystem function should be improving. After the five-year post-construction environmental monitoring period, the need for off-sets, as per Certificate OC-56 Condition 9, potentially including longer term monitoring, to provide greater certainty of mitigation success, will be determined in consultation with the appropriate regulatory agencies.

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5.3 POST-CONSTRUCTION MONITORING SURVEY METHODS

5.3.1 Mitigation Area

The mitigation area is where direct effects of the Project disturbance footprint on rare plants or RECs may occur (i.e., at rare plant and REC sites on the Project footprint) and where construction mitigation will be applied. Indirect effects may occur beyond the edge of the disturbance footprint by mechanisms such as dust deposition or overland flow of sediment. Although no mitigation is provided for plants that occur beyond the edge of the footprint, information collected on rare plant species and RECs within 30 m of the footprint will be used as part of post-construction environmental monitoring in a qualitative evaluation of the indirect effects on pipeline construction on rare plants and RECs within this 30 m band.

5.3.2 Rare Plant Monitoring Survey Protocols

Monitoring surveys for rare plant occurrences will be based on recording species presence (i.e., counting numbers of individuals or estimating populations) in a clearly defined mitigation area (following Elzinga et al. 1999) for occurrences that overlap the Project disturbance footprint. Species presence at baseline was determined during pre-construction surveys.

Where necessary, the limits of each mitigation area in upland communities will be permanently marked with metal range pins placed after final clean-up. These pins will define the limits of the monitoring survey area at each mitigation site. The location of each range pin will be recorded using a hand-held GPS to enable accurate relocation. The margins of wetlands will adequately define the limits of the mitigation area without the use of range pins for wetland species occurrences. The monitoring survey will include the full width of the ROW (including the work side, the ditchline, and the spoil storage area), unless site conditions for rare plants change across this distance. Monitoring will include areas of the Project footprint where native seed was collected and reseeded.

There are high number of S3 species and occurrences on the Project disturbance footprint therefore, for for any S3 ranked species with multiple occurrences on the Project disturbance footprint, a subset of occurrences will be identified as representative for monitoring.

The area of the pre-construction occurrence of a rare plant species will be surveyed using parallel transects extending from the disturbance footprint into undisturbed portions of the occurrence. Survey transect width (1 m to 4 m) will depend on the visibility of the plant (Henderson 2009) and will be spaced to search the entire ground surface within the survey area. The number of plants or the percent cover of rhizomatous plants on the disturbance footprint and undisturbed areas will be recorded. If the pre-disturbance occurrence of a rare species extended beyond the disturbance footprint, the undisturbed portion will also be monitored to provide a comparison with species expression on undisturbed areas in any particular year.

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Supporting information collected for the monitoring observations will include:

• Description of the associated plant community through visual estimates of species composition and percentage cover of dominant species, litter, prairie selaginella (Selaginella densa), moss, lichen, dung, and bare soils associated with the occurrence • Abiotic site conditions including soil type, soil moisture, slope, aspect • Photographs of the plant and of the site in relation to the Project footprint • The phenological development state of each occurrence at the time of survey • Presence of any patches of weeds or invasive, non-native plants within 30 m of the occurrence • Observations of other land uses that may influence the site, such as: − Grazing intensity − Industrial and agricultural infrastructure − Fragmentation or adjacent cultivation • Observations on seasonal moisture conditions and any natural disturbances (e.g., fire, grasshopper infestations)

Two rounds of monitoring surveys for rare plants will be conducted per year. An early season survey will be conducted between late May and early June and a late season survey between late July and early August to enable identification of early and late flowering species.

In year five, a comparison of ecosystem function will be made (using range health assessment methods presented in Adams et al. 2016), between the plant community at the rare plant site and the adjacent undisturbed community.

All data will be collected electronically using hand-held dataloggers. Field data will be uploaded to a monitoring database for multi-year comparisons of reclamation progress.

5.3.3 Rare Ecological Community Monitoring Survey Protocols

Monitoring for RECs will be conducted to assess the effectiveness of the mitigation measures employed and to document recovery towards the pre-disturbance plant community. Monitoring surveys for RECs are based on species composition, cover, and range health of each occurrence that overlaps the disturbance footprint. The extent of each REC occurrence on the disturbance footprint was mapped during pre- construction surveys.

The monitoring survey area will include the full width of the ROW (including the work side, the ditchline, and the spoil storage area). The location of each community will be recorded again using a hand-held GPS to enable accurate relocation during follow-up visits. Where multiple occurrences of a REC overlap the Project disturbance footprint, up to three monitoring plots will be established.

Each REC will be characterized by plot sampling, using protocols adapted from the Alberta Conservation Information Center Ecological Community Sampling Guidelines (Allen 2011).

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Monitoring plot sizes will generally be as follows (but may be adjusted to fit the shape of a community):

 For treed communities, such as Manitoba maple / choke cherry, the plot size will be 20 m x 20 m  For shrubland communities, such as silver sagebrush / needle-and-thread, the plot size will be 20 m x 20 m for the description of the shrub structural layer. Daubenmire frames (50 cm x 20 cm) will be inventoried on a 20 m transect through the plot to record herbaceous species richness, foliar cover, and groundcover characteristics.  For herbaceous communities, Daubenmire frames will be inventoried on a 20 m transect to record herbaceous species richness, foliar cover, and groundcover characteristics.

Percent foliar cover values will be recorded for all species, as well as total moss cover, total lichen cover, bare ground, and litter. Data will be collected electronically using hand-held dataloggers and the field data uploaded to a monitoring database for multi-year comparisons of reclamation progress.

Supporting information collected for the monitoring observations will include:

 A range health assessment of the reclaimed disturbance and the surrounding undisturbed areas (using methods presented in Adams et al. 2016)  Photographs of the vegetation community and of the site in relation to the Project footprint  Presence of any weeds or invasive, non-native plants within 30 m of the occurrence  Observations of other land uses that may influence the site, such as:  Industrial and agricultural infrastructure  Fragmentation or adjacent cultivation  Observations on seasonal moisture conditions and any natural disturbances (e.g., fire, grasshopper infestations)

5.3.4 Qualifications of Monitoring Personnel

Surveys will be conducted by rare plant specialists familiar with quantitative grassland vegetation inventory methods, ecosite and plant community classification, and range health assessment protocols.

5.3.5 Monitoring Schedule

Suitable timing for monitoring the indicators of recovery for REC sites (i.e., composition, cover and range health) is when foliage is well developed (mid-summer or later).

Rare plants and RECs will be monitored annually over the five year post-construction monitoring period. Monitoring will begin the year following completion of final clean-up and reclamation and will occur over a five-year period. Year one monitoring will be focused on evaluating initial establishment and identifying any erosion or weed occurrences.

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Assessing Mitigation Success January 2019

Five years is an appropriate time frame to assess rare species and REC establishment and to document succession towards pre-disturbance plant communities for RECs.).

5.3.6 Controls

There are many variables that affect whether rare plant species will germinate, grow, bloom, or set viable seed in any particular year. Pipeline construction and reclamation procedures will be documented; however, there are many uncontrolled variables that may affect rare plant occurrence such as temperature, moisture availability, disease, grazing, fire, or parasites.

To compare rare plant occurrences on and off the Project disturbance footprint, a control will be established outside of the Project disturbance footprint in instances where the pre-disturbance population extends outside of the footprint. This will allow comparison between on and off the disturbance footprint (Travis and Sutter 1986) in the mitigation area. For instance, if a known population of perennial herbs is not observed on either the control plot or the recovering footprint, conditions may not be suitable for the growth of these plants in that year. The presence of a rare species both on and off the Project disturbance footprint will be used as an indicator of mitigation success. Presence of a rare species off but not on the mitigation site would indicate that conditions for growth on the disturbance footprint are not suitable or that the living rare plant material is not present on the disturbance footprint.

Variables such as temperature, moisture availability, disease, grazing, fire, or parasites will not be monitored quantitatively, but observations on these factors will be made at each site during each monitoring year to help inform the understanding of the progress of the mitigation.

5.4 ASSESSING RARE PLANT MITIGATION SUCCESS

Rare plant mitigation techniques can be defined as being successful if the genetic material persists and perpetuates itself over time on the reclaiming Project disturbance footprint. Comparisons of rare plants occurrences before and after construction will be tracked. However, using direct comparisons of abundance may not be appropriate for measuring mitigation success. Populations of rare plants fluctuate naturally as site conditions change. Seasonal climate events such as drought or flooding may affect the surface expression or reproductive success of species that regenerate from the seed bank in any particular year. Populations also fluctuate naturally over time. For example, a species adapted to bare ground (early seral) may produce a large number of plants and seed in the first few years after reclamation and then less in subsequent years as the cover and composition of plants on the site shifts over time to a more mature (mid to late seral) plant community. Disturbance-adapted species may become dormant in the seed bank. Slow growing species such as plains rough fescue or species that benefit from shading or sheltered microsites may establish later in the reclamation process.

An assessment of the success of mitigation for each rare plant occurrence will be documented in a report at the end of the five-year post-construction environmental monitoring period. Occurrences of the rare plant species on the Project footprint after construction can be considered an indicator of mitigation success.

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Assessing Mitigation Success January 2019

5.5 ASSESSING RARE ECOLOGICAL COMMUNITY MITIGATION SUCCESS

The success of mitigation to reclaim a REC will be based on comparing the species composition, cover, and range health of the reclaiming ROW with a control site outside of the disturbance footprint. The successional trajectory of the REC will be assessed over a five year period. The need for further monitoring will be determined at the end of the five-year post-construction environmental monitoring period.

5.6 PLANNING FOR THE PROVISION AND IMPLEMENTATION OF OFFSET MEASURES

Monitoring surveys will be conducted during the five-year post-construction environmental monitoring period to assess recovery of rare plant species and RECs. After this time an assessment of non- avoidable effects following reclamation of the Project will be made to determine if offset measures are appropriate. The Company will determine the Offset Measures Plan in consultation with provincial auhtorities in accordance with Condition 9.

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Assessing Mitigation Success January 2019

5.8

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Regulatory Consultation January 2019

6.0 REGULATORY CONSULTATION

Regulatory consultations are summarized in Table 6-1. Email documentation is provided in Appendix C.

Date Agency Issue Response May 3, 2017 SK MOE – Ken Stantec and the Company met SK CDC sent an email shortly Dillabaugh with SK MOE and SK CDC to after the meeting on May 3, 2017 SK CDC – Sarah discuss rare plant survey effort in requesting data. The Company Vinge-Mazer Saskatchewan. and Stantec provided requested data on May 4, 2017 and May 5, Previous rare plant survey methods were discussed, and it 2017, respectively. was proposed to use the same methods for rare plant surveys in summer 2017. No commitments regarding survey effort were made by SK MOE and SK CDC during the meeting. May 8, 2017 SK CDC – Sarah Email communication from No response. Vinge-Mazer Stantec to the SK CDC with information regarding previously conducted Species at Risk Act surveys between NW 07-015-25 W3M and SE 01-014-25 W3M and between SW 29-013-24 W3M and SW 21-013-24 W3M. May 11, 2017 SK MOE – Ken Email communication between the SK CDC responded on Dillabaugh Company. SK MOE, and SK CDC May 11, 2017 stating that they SK CDC – Sarah regarding rare plant survey effort. have all the information they need. Vinge-Mazer SK MOE responded on May 17 requesting further transects to be completed between NW 07-015- 25 W3M and SE 01-014-25 W3M and between SW 29-013-24 W3M and SW 21-013-24 W3M. SK MOE stated that the remainder of the pipeline route may proceed following survey protocols used in previous vegetation assessments. August 28, SK MOE – Ken A phone call between Stantec and SK MOE indicated that they would 2017 Dillabaugh SK MOE to discuss rare plant discuss continued rare plant seed collection. Specifically, the mitigation with the SK CDC to previously approved rare plant determine if previous methodology seed collection methodology (from would still apply or the need to 2010-2012), noting that the SK look at revising the methodology. Fish & Wildlife Branch Alberta has not changed policy (Government of Saskatchewan concerning mitigation of effects on 2016) has indicated that seed rare plants by means of seed collection is no longer an collection and distribution or approved rare plant mitigation propagule transplantation. methodology.

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Regulatory Consultation January 2019

Date Agency Issue Response August 29, SK MOE – Ken Email communication providing SK MOE called Stantec on 2017 Dillabaugh SK MOE with a list of rare plant October 4, 2017 and indicated species for which Stantec had seed that was previously collected previously proposed seed which was found to be still viable collection (and, in some cases, should be used as part of Project already collected seed from). The reclamation activities. list also included additional species not previously identified during surveys for the Project, but which had been found in 2017. November 24, SK MOE – Ken Phone call between Stantec and No follow up required. 2017 Dillabaugh SK MOE discussing rare plant mitigation. Specifically, SK MOE stated agreement with SK CDC on the following: • Additional seed collection for supplemental rare plant mitigation will not be permitted in Saskatchewan • Previously collected seed to be returned to the Project footprint after construction and reclamation, as previously agreed • Mitigation for rare plants previously agreed is expected to be adhered to and additional or new mitigation will not be required • Mitigation for rare plant species with S-rank changes will follow the new S-Rank • Rare plants within 30 m of the project footprint may require flagging or fencing along the edge of the Project footprint. In addition, SK MOE requested that soils are reclaimed on the Project footprint as soon as possible after construction to retain the seed bank for all native plants, including rare plants.

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Regulatory Consultation January 2019

Date Agency Issue Response December 7, AEP – Sandi Phone call between Stantec and On December 13, 2017, Stantec 2017 Robertson AEP regarding rare plant provided a follow up email occurrences in Alberta. AEP confirming AEP’s request for the indicated that they expect that the updated rare plant data including rare plant mitigation methodology the SARA-listed plant data that would continue as previously will be submitted to ACIMS as well agreed. as the final Project routing for AEP indicated that critical habitat reference. designated in 2012 by ECCC The Company provided links to would need to be reviewed by the Environmental Protection Plan AEP. It was stated that the on the NEB website on Compnay understands the September 10, 2018. importance of and need for Stantec provided SARA-listed mitigation for the two SARA- listed plant data on January 19, 2018. plant species in Alberta including the requirement for a 300 m setback from occurrences (which is what the critical habitat is based on). December 8, SK MOE – Ken Email communication in follow up No response. 2017 Dillabaugh to the phone call held on November 24, 2017. Specifically, a request for additional consultation to determine mitigation for disturbance within 300 m of SARA-listed plant species. As well as, one additional topic for mitigation discussions: wetland mitigation for temporary effects on wetlands. Stantec would like to confirm if all previously proposed mitigation for temporary effects on wetlands should continue to be adhered to and that additional or new mitigation for effects on wetlands would not be required. January 19, AEP – Sandi Email communication between No response 2018 Robertson AEP and Stantec regarding environmental documents and rare plan observations from 2017 surveys. January 19, SK MOE – Ken Email communication between SK No response 2018 Dillabaugh MOE and Stantec regarding the smooth goosefoot occurrence.

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Regulatory Consultation January 2019

Date Agency Issue Response February 22, AEP – Patrick Porter Stantec and the Company met Edits made to report to reflect 2018 and Jason Unruh with AEP to discuss range minor changes to start/end point reference sites and vegetation. location of RECs and updated Rare plant and rare ecological REC names and descriptions. community (REC) surveys conducted in 2017 were discussed and it was agreed that the report will reflect minor changes to start/end point locations and REC names as a result of the surveys. It was also noted that 2017 surveys did not note any occurrences of S1 rare plants on the north end of the Project area. February 28, Alberta Environment Stantec and the Company met The Company will discuss offset 2018 Special Areas Board with plans with AEP and review (Special Areas), AEP Alberta Environment Special mitigation planned for new SARA – Trent Caskey, Areas Board and AEP to discuss plants. Nolan Ball, Joel Species at Risk Act (SARA) Nicholson, Scott Plants mitigation. Stevens, and Sandi Robertson The Compnay, AEP, and Special Areas noted that mitigation for SARA plants used in the past appears to be effective. The Company indicated there were some new observations within the 300 m setback. The Company will review mitigaton planned for those areas and discuss with AEP and Special Areas. March 1, 2018 SK MOE and Stantec and the Company met The Compnay will follow up with Ministry of with SK MOE and the SK MOE to discuss concerns with Agriculture – Ken Saskatchewan Ministry of rare plant mitigations. Dillabaugh and Agriculture to discuss survey Lorne Veitch methodology and rare plants. Updates were provided related to survey methodologies for vegetation, and indication was given that the Company 2017 surveys reflect current requirements as discussed with SK MOE. SK MOE to pass project information including rare plant mitigations on to Sarah Binge-Mazer for review

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Regulatory Consultation January 2019

Date Agency Issue Response June 21, 2018 SK MOE – Ken The Company met with SK MOE The Compnay will follow up with Dillabaugh, Janna to discuss rare plant mitigation SK MOE to discuss concerns with White and critical habitat. rare plant mitigations. Rare plant mitigation for S1 and S2 plants (adapted and not adapted to disturbance) was reviewed and accepted. Smooth goosefoot critical habitat discussed. June 26, 2018 AEP – Scott Stevens The Company met with AEP to AEP to follow up with Nolan and discuss rare plant mitigation for Trent for review of mitigations. S1 and S2 plants June 28, 2018 ECCC – Paul The Companymet with ECCC to Gregoire discuss slender mouse-ear-cress, tiny cryptantha, smooth goosefoot, and provincial listings. Timing restriction discussed – construction to begin post September 1. Smooth goosefoot location where the buffer overlaps the project footprint near Piapot Creek is being reviewed by SK MOE. Rare plant mitigations were explained. Results of rare plant research has shown that mitigation for disturbance adapted rare plants is effective. Provincial resource managers have confidence in our mitigation approach. AEP has requested a proposal for a compensation plan for SARA plants. July 9, 2018 AEP – Sandi The Company met with AEP to The Company to provide Robertson discuss rare plant mitigation for compensation proposal sometime S1 and S2 plants in September. The Company and AEP reviewed ROW widths in drawings 901 and 931 and through cultivated field. AEP agree with the approach to rare plant mitigation. Regarding critical habitat, AEP reviewed construction methods, timing, and current SARA plant areas. Reviewed areas that will be included in compensation proposal.

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KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Regulatory Consultation January 2019

Date Agency Issue Response July 11, 2018 Special Areas – The Company met with Special Nolan Ball, Trent Areas to discuss construction Caskey timing and and rare plant mititgation. Special Areas was consulted about placing fences in rare plant areas. “Drift fences” (in a series) have also been used to manage access near sensitive sites. Clean up of post July 1 is preferred, but early summer (May and June) is acceptable. July 18, 2018 AEP – Pat Porter, The Company met with AEP to Zoey Zapisocki discuss rare plants, RECs, and clearing. It was discussed that soil handling and timing of construction is dependent on whether rare species are adapted to disturbance. Ramps will be used to avoid disturbance to plants. Topsoil and spoil will be removed from the sod layer prior to the next growing season. December 24, SK MOE – Ken Email communication between SK Keystone confirms the smooth 2018 Dillabaugh MOE and TransCanada regarding goosefoot monitoring is included KXL mitigation for rare plants. SK in the 5-year post construction MOE requested TransCanada monitoring commit to smooth goosefoot population assessments in the identified locations of the EPP, during the 5-year post construction monitoring

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KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

References January 2019

7.0 REFERENCES

7.1 LITERATURE CITED

ACIMS (Alberta Conservation Information Management System). 2018. Alberta rare plant tracking list on- line database. Alberta Environment and Parks, Edmonton, Alberta. Available on-line: https://www.albertaparks.ca/albertaparksca/management-land-use/alberta-conservation- information-management-system-acims/. Accessed July 2018.

Adams, B. 2009. Successional changes after pipeline disturbance - presentation. Alberta Sustainable Resource Development – unpublished.

Adams, B.W., G. Ehlert, C. Stone, M. Alexander, D. Lawrence, M. Willoughby, D. Moisey, C. Hincz, A. Burkinshaw, J. Richman, K. France, C. DeMaere, T. Kupsch, T. France, T. Broadbent, L. Blonski and A.J. Miller. 2016. Rangeland Health Assessment for Grassland, Forest and Tame Pasture. Alberta Environment and Parks, Rangeland Resource Stewardship Section. Available at: https://open.alberta.ca/dataset/51cad211-09f6-49bd-86ef-ca3162f2ea7a/resource/2cadf8f4-ef65- 4e48-812e-10f8daf027a8/download/rangelandhealthassessment-2017.pdf. Accessed February 2018.

Adams, G.D. 1988. Wetlands of the prairies of Canada In: Wetlands of Canada. National Wetlands Working Group. Ecological Land Classification Series No. 24, pages 158– 98. Sustainable Development Branch, Environment Canada, Montreal.

Alberta Environment and Water. 2012. Best Management Practices for Conservation of Reclamation Materials in the Mineable Oil Sands Region of Alberta. Prepared by MacKenzie, D. for the Terrestrial Subgroup, Best Management Practices Task Group of the Reclamation Working Group of the Cumulative Environmental Management Association, Fort McMurray, AB. Available at: https://open.alberta.ca/dataset/16628671-0e7d-4a1f-bdf7-db19d8fc1e25/resource/12250234- 4077-472c-8da7-0fbed2de9e48/download/2012-Best-Management-Practices-Conservation- Reclamation-Materials-Alberta-2011-main-report.pdf. Accessed March 2018.

Allen, L. 2011. Alberta Conservation Information Center Ecological Community Sampling Guidelines. Alberta Tourism Parks and Recreation. Edmonton, Alberta. Available at: https://www.albertaparks.ca/media/1365919/ecological_community_sampling_guidelines_2011.p df. Accessed July 2018.

Allen, L. 2014. Alberta Conservation Information Management System Ecological Community Tracking List. Alberta Tourism, Parks and Recreation, Edmonton, Alberta. Available at: https://www.albertaparks.ca/media/3259838/tracked_watched_list_ecological_communities_full_r eport.pdf. Accessed July 2018.

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KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

References January 2019

ANPC (Alberta Native Plant Council). 2012. ANPC Guidelines for Rare Vascular Plant Surveys in Alberta – 2012 Update. Alberta Native Plant Council, Edmonton, AB. Available at: https://anpc.ab.ca/wp- content/uploads/2015/01/Guidelines-For-Rare-Plant-Surveys-in-AB-2012-Update.pdf. Accessed July 2018.

Aronson, M.F.J. and S. Galatowitsch. 2008. Long-Term Vegetation Development of Restored Prairie Pothole Wetlands. Wetlands December 2008: Vol. 28, Issue 4, pp. 883-895.

AXYS Environmental Consulting Ltd. 1997. Express Pipelines Ltd. Environmental Monitoring Report. Prepared for Express Pipeline, a division of Alberta Energy Company Ltd. and TransCanada Pipelines Ltd. 58pp + appendices.

AXYS Environmental Consulting Ltd. 2003. Express Pipeline Ltd. Environmental Monitoring Final Report. Prepared for Terasen Pipelines (Formerly Express Pipeline, a division of Alberta Energy Company Ltd. and TransCanada Pipelines Ltd.).

Corlett, R. T. and D. A Westcott. 2013. Will plant movements keep up with climate change? Trends in Ecology and Evolution. (28): 8.

Cronk, J.K. and M.S. Fennessy. 2001. Wetland Plants: Biology and Ecology. CRC Press, LLC. Boca Raton, Florida.

Desserud, P.A. 2006. Restoration of Rough Fescue Grassland on Pipelines in Southwestern Alberta. Rangeland Management Branch, Public Lands Division, Alberta Sustainable Resource Development, Lethbridge, Alberta. Pub. No. T/121 77 pp. Available at: https://foothillsrestorationforum.ca/wp-content/uploads/2017/10/Rough-Fescue-Restoration-on- Pipelines-Desserud-tech-doc.pdf. Accessed July 2018.

Desserud, P.A., C.C. Gates, B. Adams and R.D. Revel. 2010. Restoration of foothills rough fescue grassland following pipeline disturbance in southwestern Alberta. Journal of Environmental Management 91: 2763-2770.

Elzinga, C.L., D.W. Salzer, and J. Willoughby. 1999. Measuring and Monitoring Plant Populations. Bureau of Land Management. Denver, Colorado, U.S.A. BLM Technical Reference 1730-1. 477pp.

Environment Canada. 2012a. Recovery Strategy for the Slender Mouse-ear-cress (Halimolobos virgata) in Canada. Species at Risk Act Recovery Strategy Series. Environment Canada, Ottawa. v + 45 pp. Available at: https://www.registrelep- sararegistry.gc.ca/virtual_sara/files/plans/rs_slender_mouse_ear_cress_e.pdf. Accessed July 2018.

7.2

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

References January 2019

Environment Canada. 2012b. Amended Recovery Strategy for the Tiny Cryptantha (Cryptantha minima) in Canada. Species at Risk Act Recovery Strategy Series. Environment Canada, Ottawa. vii + 38 pp. Available at: http://www.registrelep- sararegistry.gc.ca/virtual_sara/files/plans/amended_rs_tiny_cryptantha_final_e.pdf. Accessed July 2018.

Environment Canada. 2015. Recovery Strategy for the Smooth Goosefoot (Chenopodium subglabrum) in Canada. Species at Risk Act Recovery Strategy Series. Environment Canada, Ottawa. Vii + 50 pp. Available at: http://www.registrelep- sararegistry.gc.ca/document/default_e.cfm?documentID=893. Accessed July 2018.

Galatowitsch, S. M. 2006. Restoring prairie pothole wetlands: does the species pool concept offer decision-making guidance for re-vegetation. Applied Vegetation Science 9:261–270.

Gibson, D.J. 2009. Grasses and Grassland Ecology. Oxford University Press. Oxford, U.K. 305 pp.+14 plates. Available at: http://www.wzw.tum.de/public- html/lattanzi/Lit/Grasses%20and%20grassland%20ecology.pdf. Accessed July 2018.

Government of Saskatchewan. 2016. Rare Plant Translocation Policy and Guideline F&W 2016-03. Fish and Wildlife Branch. Available at: http://publications.gov.sk.ca/documents/66/89928- Rare%20Plant%20Translocation%20Policy.pdf. Accessed July 2018.

Government of Saskatchewan. 2017. Species Detection Survey Protocols: 20.0 Rare Vascular Plant. April 2017 Update. Saskatchewan Ministry of Environment, Fish, Wildlife and Lands Branch, Regina, Saskatchewan. Available at: http://publications.gov.sk.ca/documents/66/89551- 20.0%20Rare%20Vascular%20Plant%20SP%20April%202017.pdf. Accessed July 2018.

Gramineae Services Ltd. 2008. Field Observations of the Recovery of Native Rangeland Plant Communities on Express Pipeline. Prepared for: The Canadian Energy Pipeline Association. Prepared by: Gramineae Services Ltd. in association with Kestrel Research Inc. and CorPirate Services. Available at: https://www.ceaa.gc.ca/050/documents_staticpost/cearref_15620/814.pdf. Accessed July 2018.

Henderson, D.C. 2009. Occupancy Survey Guidelines for Prairie Plant Species at Risk. Canadian Wildlife Service, Prairie and Northern Region, Saskatoon, SK. Available at: https://www.npss.sk.ca/docs/2_pdf/Rare_Plant_Occupancy_Survey_Guidelines.pdf. Accessed July 2018.

Henderson, D.C. 2011. Activity Setback Distance Guidelines for Prairie Plant Species at Risk. Canadian Wildlife Service, Prairie and Northern Region, Saskatoon, SK. Available at: https://www.registrelep- sararegistry.gc.ca/virtual_sara/files/policies/pg_marges_recul_prairie_plants_1111_eng.pdf. Accessed July 2018.

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KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

References January 2019

Hickman, L.K. September 2010. Reclamation Outcomes on Energy Disturbances in Silver Sagebrush Communities - A Master’s Degree Project Submitted to the Faculty of Environmental Design in Partial Fulfillment of the Requirements for the Degree of Master of Environmental Design (Environmental Science) Faculty of Environmental Design Environmental Science Program, University of Calgary. Calgary, Alberta. Available at: https://dspace.ucalgary.ca/bitstream/handle/1880/48304/2010_Hickman_MEDes.pdf;jsessionid= A4428F48BB0748AB41799EFE0207E3F6?sequence=3. Accessed July 2018.

Keddy, P.A. 2000. Wetland Ecology Principles and Conservation. Cambridge University Press. Cambridge, U.K.

Kemper, J.T. 2009. Alberta Natural Heritage Information Centre Vascular and Non-vascular Plant Tracking and Watch Lists. Alberta Tourism, Parks and Recreation, Parks Division, Edmonton, Alberta.

Kestrel Research Inc. and Gramineae Services Ltd. 2011. Long Term Recovery of Native Prairie from Industrial Disturbance; Express Pipeline Revegetation Monitoring Project 2010 Abridged Version- November 2011. Prepared for: Kinder Morgan Canada, TransCanada PipeLines, ConocoPhillips Canada and Alberta Sustainable Resource Development Public Lands Division. Available at https://foothillsrestorationforum.ca/wp-content/uploads/2017/10/Express-Monitoring-Abridged- November-2011.pdf. Accessed July 2018.

Mackenzie, D. 2013. Oil Sands Mine Reclamation Using Boreal Forest Surface Soil (LFH) in Northern Alberta. Ph.D. Thesis, University of Alberta. Available at: https://era.library.ualberta.ca/files/m613mx79d/MacKenzie_Dean_Winter%202013.pdf. Accessed March 2018.

Master, L., D. Faber-Langendoen, R. Bittman, G. A. Hammerson, B. Heidel, L. Ramsay, K. Snow, A. Teucher, and A. Tomaino. 2012. NatureServe Conservation Status Assessments: Factors for Assessing Extinction Risk. NatureServe, Arlington, VA. Available at: http://www.natureserve.org/sites/default/files/publications/files/natureserveconservationstatusfact ors_apr12.pdf. Accessed July 2018.

NatureServe. 2017. NatureServe Explorer: An online encyclopedia of life [web application]. Version 7.1. NatureServe, Arlington, Virginia. Available at: http://explorer.natureserve.org/. Accessed November 2017.

Seabloom, E.W. and A.G. van der Valk. 2003. Plant diversity, composition, and invasion of restored and natural prairie pothole wetlands: implications for restoration. Wetlands March 2003 : Vol. 23, Issue 1, pp. 1-12.

SK CDC (Saskatchewan Conservation Data Centre). 2018. Saskatchewan Vascular Plant Species List. Regina, Saskatchewan. Available at: http://www.biodiversity.sk.ca/SppList.htm. Accessed January 2018.

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KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

References January 2019

Stringham, T.K., W.C. Krueger and P.L. Shaver. 2003. State and transition modeling: An ecological process approach. Journal of Range Management 56: 106-113. March 2003. Available at: https://www.nrcs.usda.gov/Internet/FSE_DOCUMENTS/nrcs144p2_050801.pdf. Accessed July 2018.

Thorpe, J. 2007. Saskatchewan Rangeland Ecosystems, Publication 1: Ecoregions and Ecosites. Saskatchewan Prairie Conservation Action Plan. Saskatchewan Research Council Pub. No. 11881-1E07.

Thorpe, J. 2014. Saskatchewan Rangeland Ecosystems, Publication 1: Ecoregions and Ecosites. Version 2. Saskatchewan Prairie Conservation Action Plan. Saskatchewan Research Council Pub. No. 11881-1E14. Available at: http://www.pcap- sk.org/rsu_docs/documents/1_ecoregions_and_ecosites6784.pdf. Accessed July 2018.

TransCanada Keystone Pipeline GP Ltd. 2017. Keystone Pipeline Project - 2016 Post-Construction Environmental Monitoring Report. Prepared for: National Energy Board. Available at: https://apps.neb-one.gc.ca/REGDOCS/Item/View/3179680. Accessed July 2018.

Travis J. and R. Sutter. 1986. Experimental Designs and Statistical Methods for Demographic Studies of Rare Plants. Natural Areas Journal Volume 6, Number 3: 3-12.

7.2 PERSONAL COMMUNICATIONS

Dillabaugh, K, Senior Ecological Protection Specialist, Saskatchewan Ministry of Environment, and Vinge- Mazer, S. Botanist with Saskatchewan Conservation Data Centre. 2017, Personal communication, phone call May 3, 2017 and emails May 3, 4, 5, 8, 11, and 17, 2017 discussing survey methodology.

Dillabaugh, K. 2017. Senior Ecological Protection Specialist, Saskatchewan Ministry of Environment. Personal communication, phone call August 28, 2017 and emails August 29 and November 24, 2017 discussing rare plant mitigation.

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References January 2019

7.6

APPENDICES

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Appendix A Definitions January 2019

DEFINITIONS

A.1 WETLAND INDICATOR STATUS

Category Description Obligate wetland plant Almost always occur in wetlands Facultative wetland plant Usually occur in wetlands, but may occur in non-wetlands Facultative plant Occur in wetlands and non-wetlands Facultative upland plant Usually occur in non-wetlands, but may occur in wetlands Obligate upland plant Almost never occur in wetlands Region Great Plains Includes Montana, North Dakoda, South Dakoda and other states (CO, KS, MN, NE, NM, OK, TX, WY) SOURCE: USDA, NRCS 2017

A.2 SPECIES AT RISK ACT (SARA) RANKS

Category Definition Special Concern A species that may become threatened or endangered because of a combination of biological characteristics and identified threats. Threatened A species likely to become endangered if nothing is done to reverse the factors leading to its extirpation or extinction Endangered A species facing imminent extirpation or extinction. SOURCE: Government of Canada 2017

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Appendix A Definitions January 2019

A.3 NATIONAL (N) CONSERVATION STATUS RANKS

Status Definition NX Presumed Extirpated—Species or ecosystem is believed to be extirpated from the jurisdiction (i.e., SX nation or state/province). Not located despite intensive searches of historical sites and other appropriate habitat, and virtually no likelihood that it will be rediscovered. NH Possibly Extirpated— Known from only historical records but still some hope of rediscovery. There is evidence that the species or ecosystem may no longer be present in the jurisdiction, but not enough to state this with certainty. Examples of such evidence include (1) that a species has not been documented in approximately 20-40 years despite some searching or some evidence of significant habitat loss or degradation; (2) that a species or ecosystem has been searched for unsuccessfully, but not thoroughly enough to presume that it is no longer present in the jurisdiction. N1 Critically Imperiled—Critically imperiled in the jurisdiction because of extreme rarity or because of some factor(s) such as very steep declines making it especially vulnerable to extirpation from the jurisdiction. N2 Imperiled—Imperiled in the jurisdiction because of rarity due to very restricted range, very few populations, steep declines, or other factors making it very vulnerable to extirpation from jurisdiction. N3 Vulnerable—Vulnerable in the jurisdiction due to a restricted range, relatively few populations, recent and widespread declines, or other factors making it vulnerable to extirpation. N4 Apparently Secure—Uncommon but not rare; some cause for long-term concern due to declines or other factors. N5 Secure—Common, widespread, and abundant in the jurisdiction. NU Unrankable—Currently unrankable due to lack of information or due to substantially conflicting SU information about status or trends. NNR Unranked—National or subnational conservation status not yet assessed. SNR NNA Not Applicable —A conservation status rank is not applicable because the species or ecosystem is SNA not a suitable target for conservation activities (for example, migrants, hybrids without conservation value, non-native species). SOURCE: NatureServe 2017

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Appendix A Definitions January 2019

A.4 ALBERTA STANDARD SUBNATIONAL CONSERVATION STATUS RANKS

Ranks1 Definition S1 Five or fewer occurrences or very few remaining hectares S2 Six to 20 occurrences or few remaining hectares S3 21 to 80 occurrences. May be rare and local throughout its range or found locally, even abundantly, in a restricted range (e.g. a single western province or a physiographic region in the East). S4 Apparently secure globally (State / Province wide), though it may be quite rare in parts of its range, especially at the periphery. S5 Demonstrably secure globally (State / Province wide), though it may be quite rare in parts of its range, especially at the periphery. SNR Element is not yet ranked SU Unrankable—Currently unrankable due to lack of information or due to substantially conflicting information about status or trends. SNA Not Applicable —A conservation status rank is not applicable because the element is not a suitable target for conservation activities. S#S# Range Rank* —A numeric range rank (e.g., S2S3) is used to indicate any range of uncertainty about the status of the species or community. Ranges cannot skip more than one rank (e.g., SU is used rather than S1S4). Modifiers ? Can be added to any rank to denote an inexact numeric rank (e.g. S1? = Believed to be 5 or less occurrences, but some doubt exists concerning status). NOTE: 1 Ranks can be combined to indicate a range (e.g. S2S3 = May be between 6 to 80 occurrences throughout Alberta, but the exact status is uncertain). Combined ranks indicate a larger margin of error than ranks assigned a "?" qualifier SOURCE: ACIMS 2018

A.5 SASKATCHEWAN SPECIES CONSERVATION RANKS

Ranks1 Definition S1 Critically Imperiled/ Extremely rare. At very high risk of extinction or extirpation due to extreme rarity, very steep declines, high threat level, or other factors. S2 Imperiled/Very rare. At high risk of extinction or extirpation due to a very restricted range, very few populations, steep declines, threats or other factors. S3 Vulnerable/Rare to uncommon. At moderate risk of extinction or extirpation due to a restricted range, relatively few populations, recent and widespread declines, threats, or other factors. S4 Apparently Secure. Uncommon but not rare; some cause for long-term concern due to declines or other factors. S5 Secure/Common. Demonstrably secure under present conditions; widespread and abundant; low threat level. SNR Element is not yet ranked

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Appendix A Definitions January 2019

Ranks1 Definition SU Unrankable—Currently unrankable due to lack of information or due to substantially conflicting information about status or trends. SNA Not Applicable —A conservation status rank is not applicable because the element is not a suitable target for conservation activities. S#S# Range Rank* —A numeric range rank (e.g., S2S3) is used to indicate any range of uncertainty about the status of the species or community. Ranges cannot skip more than one rank (e.g., SU is used rather than S1S4). Modifiers ? Can be added to any rank to denote an inexact numeric rank (e.g. S3? = Believed to be an S3 but there is a chance it could be and S2 or and S4. NOTE: 1 Ranks can be combined to indicate a range. Combined ranks indicate a larger margin of error than ranks assigned a "?" qualifier SOURCE: SK CDC 2018

A.6 REFERENCES

ACIMS (Alberta Conservation Information Management System). 2018. Standard Subnational Conservation Status Ranks. Alberta Environment and Parks, Edmonton, Alberta. Available on- line: https://www.albertaparks.ca/albertaparksca/management-land-use/alberta-conservation- information-management-system-acims/tracking-watch-lists/species-conservation-ranks/. Accessed July 2018.

Government of Canada. 2017. Species at Risk Public Registry. Available at: http://www.sararegistry.gc.ca. Accessed July 2018.

NatureServe. 2017. NatureServe Explorer: An online encyclopedia of life [web application]. Version 7.1. NatureServe, Arlington, Virginia. Available at: http://explorer.natureserve.org/. Accessed: July 2018.

SK CDC (Saskatchewan Conservation Data Centre). 2018. Species Conservation Rankings. Regina, Saskatchewan. Available at: http://www.biodiversity.sk.ca/ranking.htm. Accessed July 2018.

USDA, NRCS (United States Department of Agriculture, Natural Resources Conservation Service). 2018. Wetland Indicator Status definitions. Available at: https://plants.usda.gov/wetinfo.html. Accessed July 2018.

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Appendix B Saskatchewan Field Qualifications January 2019

SASKATCHEWAN FIELD QUALIFICATIONS

Dan Busemeyer Dan has 20 years of experience as a botanist, wetland biologist, environmental planner, and pipeline environmental inspector. He has played an integral role in management and field data collection for numerous environmental assessments, vegetation surveys, vegetation mapping, wetland assessments, and wetland restoration projects for wind power, solar, mining, oil and gas, industrial and residential land, and highway developments. Dan has extensive experience identifying forest, wetland, and grassland plant species (including rare plants), collecting vegetation community data, and conducting statistical analysis. He is an author or quality reviewer of over 180 project reports which have been submitted to multiple industry and government clients. Dan is also a co-author of 14 peer-reviewed publications detailing the findings of wetland, grassland, and forest vegetation inventories and surveys. His recent project experience includes solar energy projects in southern Alberta, wind power projects in Alberta and Saskatchewan, power line projects in Alberta, and pipeline projects anywhere from British Columbia to New Brunswick. EDUCATION Master of Science, University of Cincinnati, Cincinnati, Ohio, 1995 Bachelor of Art, University of Chicago, Chicago, Illinois, 1991

Jane Lancaster Jane Lancaster is a senior vegetation ecologist providing expertise in the areas of vegetation ecology, impact assessment, rare plant inventory, mitigation, reclamation, follow-up and monitoring. Jane has been involved in many development and conservation projects, providing expertise in vegetation, wetland and rare plant ecology; including mapping, inventory, impact assessment, and mitigation. Assessment experience includes research, writing and third party review. Field experience includes grasslands, parklands, mountains, taiga, the arctic and the boreal. Key Projects and sectors encompass pipelines, oil & gas, mining, infrastructure development, transmission lines and land trusts, with extensive hands on experience in inventory, environmental assessment, mitigation, reclamation planning and monitoring. Jane is a registered Professional Biologist through the Alberta Society of Professional Biologists and a member of the Alberta Native Plant Council, the Canadian Land Reclamation Association as well as the Foothill Restoration Forum. EDUCATION Bachelor of Science, University of Calgary, Calgary, Alberta

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Appendix B Saskatchewan Field Qualifications January 2019

Dayle Soppet Dayle is a vegetation ecologist with 18 years’ experience. She is experienced with environmental impact assessments, revegetation, and post development monitoring for oil and gas and other industry and stakeholder clients. Dayle has acted as the lead for the vegetation and wetlands discipline for environmental overviews, vegetation impact assessments, project planning, communication and budgeting, technical reporting, air photo and satellite vegetation and habitat classification and mapping, data management and synthesis, and literature reviews. She designs and implements field surveys for ecological land classification, wetlands classification and mapping, rare plants, reclamation, range management, weeds and monitoring. Dayle is an experienced rare plant field botanist and crew supervisor for large multidisciplinary field programs. She has worked in a variety of geographic locations, including Alberta’s Foothills, Parkland, Prairie, Montane, and Boreal regions, the Tundra and Taiga of the Northwest Territories, and sub-boreal British Columbia, southern Saskatchewan and southeastern Yukon. Dayle is a registered Professional Agrologist through the Alberta Institute of Agrologists and a member of the Alberta Native Plant Council, the Canadian Land Reclamation Association as well as the Foothill Restoration Forum Technical Advisory Committee.

EDUCATION Bachelor of Science, University of Alberta, Edmonton, Alberta, 1997

Ron Linowski Ron is a rare plant botanist with over 30 years of rare plant survey experience in the prairies of southern Alberta and Saskatchewan. He has led rare plant surveys, including survey design methodology, on dozens of proposed oil and gas, national defence, wind, solar, residential and industrial developments including proposed developments in Great Sand Hills, Cypress Hills, Suffield National Wildlife Area, and many other natural areas. His surveys have identified multiple SARA and provincially listed plant species at risk, as well as hundreds of provincially S-ranked species. Ron has proposed and implanted mitigation to avoid or reduce effects on identified plant species at risk and has helped reduce the effects of developments on many hundred rare plant occurrences. EDUCATION M.Sc. Simon Fraser University, 1984 B.Sc. Simon Fraser University, 1975

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Appendix B Saskatchewan Field Qualifications January 2019

Kim Ottenbreit Kim has been conducting rare plant surveys as a contract botanist to government and industry for more than 25 years including hundreds of general and targeted rare plant surveys for pipelines, powerlines, wellsites, industrial facilities. She has created survey methodology and report of rare plant occurrence results for hundreds of rare plant occurrences, along with proposed mitigation to avoid or reduce effects on rare plants, including on many plant species at risk. Kim is a registered Professional Biologist through the Alberta Society of Professional Biologists and is a member of the Alberta Native Plant Council. EDUCATION Master of Science in Botany, University of Manitoba, 1991 Bachelor of Science (4 year) in Biology, University of Winnipeg,1988

Anne Weerstra Anne has worked as a biologist since 1980, specializing in habitat analysis, wildlife research and management, vegetation surveys and biophysical inventories. Her background in both wildlife and botanical studies provides a strong base from which to conduct wildlife habitat evaluations, wildlife and vegetation inventories, vegetation classification, rare plant surveys, plant identification and environmental impact assessments. She has participated in in project design and management, literature reviews, report writing and editing. She has been involved in a variety of projects in Alberta, British Columbia, Saskatchewan, Yukon Territory, the Northwest Territories and Nunavut. Anne is a registered Professional Biologist through the Alberta Society of Professional Biologists and is a member of the Alberta Native Plant Council, the Alberta chapter of the Wildlife Society as well as a member of the Calgary Bird Banding Society.

EDUCATION Master of Environmental Design, University of Calgary, Calgary, Alberta,1986 Bachelor of Science (Honours), University of Western Ontario, London, Ontario,1982

Kristin Hill Kristin Hill is a Vegetation Ecologist with 6 years of experience in consulting. She has participated in rare plant, wetland, and weed surveys in the boreal and prairie regions of Alberta and has assisted with field surveys in British Columbia, Saskatchewan and Manitoba. Kristin has planned and carried out vegetation surveys for species of management concern including rare plants, rare ecological communities and noxious and prohibited noxious weeds. Kristin has prepared biophysical impact assessment reports for urban development projects, Water Act applications, and environmental monitoring reports. She has experience providing consulting services for a variety of clients for renewable energy, electrical transmission, oil and gas, oil sands, rail, and municipal projects. EDUCATION Bachelor of Science (Honours) in Environmental Science, University of Calgary, Calgary, Alberta, 2012

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Appendix B Saskatchewan Field Qualifications January 2019

Elena Farries Elena has worked in the consulting industry since 2013. During this time, she has worked with several clients in Oil and Gas, Transmission Projects and Renewable Resources. She has several years of experience with wetland mapping, desktop reviews, writing reports and conducting field surveys in the boreal and prairie regions of British Columbia, Alberta, Saskatchewan and Manitoba. Elena has a broad range of survey experience including rare plant, wetland, monitoring, ecological land classification (ELC), weed, and amphibian surveys. Her work helps clients ensure compliance with several legislative requirements such as the Water Act, Weed Control Act, Species at Risk Act, Public Lands Act, and the Alberta Wildlife Act. Elena graduated from the University of Calgary with a B.Sc. in Biology (2013), where she gained a strong passion for botanical studies and reclamation and restoration work. She completed her undergraduate research on species biodiversity and biomass production within a restored fen in St. Fabien, Quebec.

EDUCATION Bachelor of Science in Biology, University of Calgary, Calgary, Alberta, 2013

Andrea Dechene Andrea is a Vegetation Ecologist with Stantec’s Vegetation and Wetlands Group and has over ten years of field and reporting experience including acting as vegetation and wetland lead for a number of developments across Alberta. Andrea has led biophysical baseline studies, long-term monitoring projects, pre-disturbance assessments, environmental impact assessments, ecological land classification and vegetation and wetland mapping projects in the Boreal, Parkland, Grassland and Canadian Shield Natural Regions of Alberta. She is familiar with relevant legislation for vegetation, wetlands and rare plants as well as reporting requirements. Recent experience with the Alberta Wetland Policy has resulted in the successful submission of several Water Act applications. Andrea’s skills include air photograph and satellite imagery interpretation, ecological land classification, wetland inventory and impact assessment, vascular plant and bryophyte identification, post-construction monitoring and analysis and conducting statistical analysis. EDUCATION M.Sc., Natural Resource Sciences, McGill University, Natural Resource Sciences, Montreal, Quebec, 2008 B.Sc., Biological Sciences (Honors), University of Alberta, Biological Sciences, Edmonton, Alberta, 2005

Josh Boisse Josh has three years of experience working as a vegetation ecologist with Stantec. His primary focus has been on midstream projects with oil and gas pipelines. He has also worked on projects in transmission and distribution, oil sands mining and wind power. Josh has past experience with a variety of vegetation field assessments including: species at risk, rare plants, wetlands for Water Act or code of practice, rangeland health and invasive species.

EDUCATION Bachelor of Science, University of Calgary, Calgary, Alberta, 2012

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Appendix B Saskatchewan Field Qualifications January 2019

Dmitry Petelin Dmitry has been working at Stantec since 2011, as a technical expert in various aspects of vegetation surveys and reporting. He is involved in writing the vegetation sections of environmental assessment reports and authoring Technical Data and TEM reports. In addition, he has completed 15 field shifts (in TEM and rare plant disciplines) with Stantec. Dmitry’s pre-Stantec work included both academic and industrial experience. For more than 20 years (1979-2001) he worked in the vegetation science department of the Moscow State University, where he earned his PhD degree in Biology for developing classification and studying the ecology and dynamics of boreal forests of Pacific Russia; he also participated in academic and conservation (WWF) projects in the Russian Far East, the Altai Mountains, the Caucasus, and Africa (Ethiopia). He completed postdoctoral fellowships at the Vegetation Science Institute of the ETH (Zurich) and at the Royal Botanic Gardens (Kew, UK). From 2001 to 2011, Dmitry gained his industrial experience within oil & gas by working as part of a biodiversity team. He was a project manager for environmental baseline, monitoring and conservation surveys and initiatives aimed at assessing environmental effects and mitigations of adverse effects.

EDUCATION Ph.D., Moscow State University, Moscow, Moscow, 1985 B.Sc., Moscow State University, Moscow, Moscow, 1979

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Appendix B Saskatchewan Field Qualifications January 2019

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Appendix C Regulatory Consultation Documentation January 2019

REGULATORY CONSULTATION DOCUMENTATION

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Appendix C Regulatory Consultation Documentation January 2019

C.2

From: Busemeyer, Dan To: [email protected] Subject: Keystone XL links to Environmental Alignment Sheets, Resource Specific Mitigation Tables Date: Friday, January 19, 2018 12:31:00 PM Attachments: AllSpeciesDataList_20180118.xlsx

Good morning Sandi,

I’m following up on our discussion this past December, where you requested environmental documents for the Keystone XL Project.

Here is a Link to the National Energy Board files for the Keystone XL Environmental Protection Plan, Rare Plant Resource Specific Mitigation Tables, and Environmental Alignment Sheets are here: https://apps.neb-one.gc.ca/REGDOCS/Search?loc=609772&txthl=alignment&sr=1

Specifically, the Environmental Protection Plan is here: Attachment 1-KXL - EPP Environmental Protection Plan - A3W1E5 Rare Plant records for the Project identified in 2012 or prior are here: A3H9H7 - Appendix A -Resource Specific Mitigation MeasuresTable A-1a 1b 1c

Environmental Alignment Sheets are in separate files by Construction Spread, specifically: Hardisty, Lakesend East, Monitor, Oyen South, and Bindloss here: A3H9L2 - Appendix U -Environmental Alignment Sheets - Hardisty A3H9K8 - Appendix U - Environmental Alignment Sheets - Lakesend East Section A3H9L1 - Appendix U - Environmental Alignment Sheets - Monitor A3H9K9 - Appendix U - Environmental Alignment Sheets - OyenSouth A3H9L0 - Appendix U - Environmental Alignment Sheets -Bindloss

Other environmental information is also located in the same folder on the NEB website including information for Saskatchewan spreads. All of these documents are in the process of being reviewed and updated as required, but won’t be ready for an unknown amount of time, so for now, please use the filed versions.

I’ve also attached on excel file of rare plant observations made for the Project during rare plant surveys in 2017. Slender mouse-ear-cress (Transberingia bursifolia ssp. virgata, formerly known as Halimolobos virgata), which is listed as Endangered under the Wildlife Act, was observed in 2017. The occurrences of slender mouse-ear-cress are included in the attached excel file. Occurrences of tiny cryptantha (Cryptantha minima) were identified in 2007, and have not found since that year. Smooth goosefoot (Chenopodium subglabrum) is historically known from Suffield base but has not been found in any of the Project areas. We have found smooth goosefoot in Saskatchewan.

I would be happy to discuss any of this Keystone XL information. Please call or email me if you would like to discuss anything. Regards,

Dan Busemeyer, M.Sc., P.Biol. Senior Vegetation Ecologist Stantec Phone: 403-441-5103 Cell: 403-923-8927 [email protected]

The content of this email is the confidential property of Stantec and should not be copied, modified, retransmitted, or used for any purpose except with Stantec's written authorization. If you are not the intended recipient, please delete all copies and notify us immediately.

Please consider the environment before printing this email. ü

From: Busemeyer, Dan To: [email protected] Subject: Keystone XL smooth goosefoot occurrence data collected in 2017 Date: Friday, January 19, 2018 12:41:00 PM Attachments: smooth_goosefoot_occurrences_observed_in_2017_KeystoneXL_Project.xlsx

Good afternoon Ken,

I’m sending you the smooth goosefoot (Chenopodium subglabrum) occurrence information for Keystone XL which we discussed over the phone. The occurrences were found during rare plant surveys for Keystone XL and are overlapping or close to the critical habitat for smooth goosefoot which was designated by Environment and Climate Change Canada in 2015. Keystone XL is crossing a portion of two critical habitat polygons, but is not directly crossing any known occurrences of this species. Please let me know if you would like to discuss this or any other Keystone XL topics.

Thanks again, Dan Busemeyer, M.Sc., P.Biol. Senior Vegetation Ecologist Stantec Phone: 403-441-5103 Cell: 403-923-8927 [email protected]

The content of this email is the confidential property of Stantec and should not be copied, modified, retransmitted, or used for any purpose except with Stantec's written authorization. If you are not the intended recipient, please delete all copies and notify us immediately.

ü Please consider the environment before printing this email.

KXL1399-TCP-XX-MOM-XXXX MINUTES OF MEETING

MEETING SUBJECT: Project and Mitigation Update- Alberta Sections

PROJECT: Keystone XL

LOCATION: Alberta Environment and Parks, Wainwright AB

DATE/TIME: 22 February 2018, 9am to 12pm

PREPARED BY: Jennifer Barker

ATTENDEES: • Patrick Porter AEP, Land Management, Wainwright • Jason Unruh AEP Fish and Wildlife, Red Deer • Jennifer Barker, TransCanada • Darwin McNeely, TransCanada

• Albert Lees, Stantec

MINUTES OF MEETING

No. Activities/Action Items Comments Due Date Responsible

• Ensure you have the relevant travel Safety Moment insurance documents while travelling to other countries. • Pat noted that there are now local seed sources that may be more 1 Seed Mixes appropriate for use on KXL. Pat will March 15 Pat Porter review the current list and provide comments on seed mixes #3 and #4 • Pat provided the list of locations for the Range Reference sites to complare the conditions of the Rare Ecological Communities found along the KXL footprint.. Stantec will review. • Keystone noted that rare plant and rare ecological community (REC) 2 Range Reference Sites; Vegetation surveys were conducted in 2017. The Stantec report will reflect some minor changes to start/ end points locations and REC names as a result of the surveys. • 2017 surveys did not note any occurances of S1 rare plants on the north end of the project area (within MD Provost) • During the discussion of winter clearing prior to the Migratory bird window, Pat raised concerns about burning slash in the winter. Please ensure all brush piles are completely 3 Winter burning of slash After clearing TransCanada extinguished to reduce fire risk. Pat asked about the method of woody debris disposal. Keystone clarified that mulching or chipping would be conducted where possible, however

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burning of timber (ie: non- merchantable trees, limbs, tops) will be required to address the depth and concentration of material for reclamation. To align with directive ID 2009-01 Management of Wood Chips on Public Land, the mulch/ chipped material will not be spread to a depth greater than five (5) cm. • Jason requested a copy of the current version of the plan. • Jason asked a question regarding frequency of raptor nest monitoring during construction. Keystone noted that the raptor nest monitoring protocol will be used as a guideline for the monitor to determine if mitigation is 4 Breeding Bird Management Plan effective or it alterations to February 26 TransCanada construction scheduling on a day to day basis is required to avoid stress to the raptors. • Keystone noted the current plan will be replaced with a newer version titled Breeding Bird and Nest Management Plan, which is utilized on other TransCanada projects. • Jason requested a copy of the current version of the plan. • Short discussion on high level mitigation such as exclusion fencing, reviewed example photos in current plan. No concerns noted. • Keystone noted that most observations were Canadian Toad and Plains Spadefoot toad. 5 Amphibian Management Plan February 26 TransCanada • Keystone noted the current plan will be replaced with a newer version that includes minor updates to reflect measures utilized on other TransCanada projects • Keystone noted that some wetland surveys were conducted in 2017, and additional areas will be surveyed in 2018 • Pat suggested that KXL intiate conversations with the MDs to get information about clubroot locations. 6 Clubroot James Schwendt is the contact out of March 2 Pat Porter Wainwright and Pat will provide contact information for James and the contact for the MD of Provost. • The Weed Management Plan was explained and discussed • Pat noted that Absinthe, leafy spurge and spotted knapweed were becoming an increased concern in the KXL project area and recommended to use caution During 7 Weeds TransCanada • Noted and recognized that invasive construction plants on the landscape such as Kentucky bluegrass and smooth brome may not be able to be controlled. Review seed mixes and avoid those with those invasives to the extent possible.

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• One nest is within 500m of the Oyen pump station footprint. Proposed mitigation is to monitor the nest if construction takes place during the restricted activity period. Jason requested that TransCanada checks to see if there is line of sight between the nest and construction area. 8 Ferruginous Hawk nests; Other Wildlife • TransCanada will do a site visit on March 9 TransCanada/Stantec February 28 and report to AEP • Keystone noted that sharp tailed grouse lek surveys will be conducted in Spring 2018. • Keystone noted that Ribstone Creek will be crossed using an isolated opencut technique if there is water present, consistent with current plans. • The process to update the EFR information under the existing dispositions is unclear. Pat Porter to 9 Disposition Updates March 2 Pat Porter provide contact information for his liaison in Edmonton.so that KXL can inquire about the process. • Keystone noted that regulatory clearances are in place, however current historical resources information will be reviewed to 30 days prior to 10 Historical Resources TransCanada/Stantec determine if field work is required as a construction result of other projects crossing or working parallel to Keystone in recent years. • Crown dispositions were previously approved and remain in effect. • Keystone noted there are new Crown land occupants on six tracts of land. During 11 other • TransCanada Keystone noted the plan for construction addressing Brine Impacted Groundwater adjacent to Shorncliffe Lake, as approved by Alberta Environment will be implemented.

Please advise of any errors or omissions.

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KXL1399-TCP-XX-MOM-XXXX MINUTES OF MEETING

MEETING SUBJECT: Project and Mitigation Update- Alberta Sections

PROJECT: Keystone XL

LOCATION: Alberta Environment Special Areas Board, Oyen AB

DATE/TIME: 28 February 2018, 11am to 230pm

PREPARED BY: Jennifer Barker

ATTENDEES: • Trent Caskey, Special Areas • Nolan Ball, Special Areas, Hanna • Joel Nicholson, Fish and Wildlife, Medicine Hat • Scott Stevens, Fish and Wildlife, Red Deer

• Sandi Robertson, Fish and wildlife, Medicine Hat • Jennifer Barker, TransCanada, Calgary • Darwin McNeely, TransCanada, Calgary • Albert Lees, Stantec, Calgary

MINUTES OF MEETING

No. Activities/Action Items Comments Due Date Responsible

• Ensure you have the relevant travel Safety Moment insurance documents while travelling - - to other countries. • Sandi knows of observations on the roads on the west side of the SSR, such as TWP Road 21-0. Albert confirmed that those roads were 1 Kangaroo Rats surveyed in 2017 (TWP Road 20-4 March 30 Stantec between RR 21 and 22) and none were observed at the time. • Stantec to check FWMIS observations • FEHA location near the Oyen pump station was observed to be out of the line of sight of the construction area, in a lowland treed area. • Timing restriction will largely be adhered to during construction, but if activities do occur during the RAP 2 Ferruginous Hawk then birds and nests within 500 m will March 30 Special Areas be monitored for signs of stress • Stantec is to update monitoring criteria to those provided by SAR Specialist, Brandy Downey. • AEP will provide the hawk nest monitoring criteria to KXL and Stantec

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• Original construction timing scheduled to be in the summer months (June 1 to Sept 1) so that snakes have the opportunity to escape disturbances; installation of exclusion fencing; reducing speed limits to prevent road mortality • Sandi/Joel/Scott all noted that winter construction is preferrable because vibrations will be an issue for the rookeries in the summer and not an issue for the hibernaculum in the winter. Traffic mortality was identified as a greater risk during a earlier contruction time. • A Sept 30 to Oct 15 start would eliminate the majority of the risk (dependant on migration timing) and Special Areas recommended to adjust the construction schedule to avoid times of year when snakes would be moving. • AEP recommended that clean up Snake Mitigation (Hibernacula and 3 occurs after snake movement in the March 30 TransCanada Rookeries) spring (April/May) but ideally while snakes are in the hibernacula • KXL will require access to the rivers for diversion of water to facilitate hydrostatic testing of the pipeline, which is planned during higher water flows in the Spring/ Summer months. • KXL suggested that road monitoring and traffic marshalling could be added as a mitigation to reduce the risk of road mortality • KXL will continue to implement speed restrictions for project activities in the areas planned during the summer months, as noted in current EPP commitments. • Sandi asked that snake hibernacula monitoring be part of the post construction monitoring activities • KXL will have to review the construction execution plan and follow up with AEP and Special Areas • KXL, AEP and Special Areas noted that mitigation used in the past appears to be effective and support the current mitigations suggested based on the results of U of A research • KXL indicated there were some new observations within the 300m setback. KXL will review mitigaton planned for those areas and discuss with AEP and 4 SARA Plants Mitigation March 30 TransCanada Special Areas. Construction mitigation may not need to change significantly in light of research conducted by U of A indicating plants do not appear to be affected by soil disturbance. • Joel would like to review the original offset plans that were agreed to at the start of the Project • KXL to send Joel the offset plans previously developed

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• Keystone noted that offset plans included areas intersected by both the Keystone Project (2008-09) and KXL. • Discussed currently proposed mitigation (time of day restrictions; removing soil piles) • Additional site specific mitigation will be developed based on the results of the 2018 surveys • Scott suggested that since some construction will be occuring during lekking that the time of day restrictions 5 Grouse Lek Mitigation may not be sufficient for leks within a April 30 TransCanada close proximity. Recommended a later construction timing in these areas to avoid the lekking period • KXL to follow up with AEP after the 2018 surveys are completed to review appropriate mitigation options based on proximity and location of leks and time of year restrictions. • Trent noted that there is an observation in Special Areas 3 (west of the project) • Trent committed to checking with the Agricultural Services Board for 6 Clubroot detailed and current information on March 30 Trent Caskey obsservations within Special Areas. • KXL is formulating a plan/protocol based on feedback from landowners/municipality, and will be conducting a sampling program • Natural recovery or assissted natural recovery is the preferred method for reclamation. Noted that KXL would likely not fit this approach as it is a much larger project with associated wider disturbances required to construct the pipeline. • Seed Mixes 5 to 7 are relevant to Special Areas • KXL noted that the seed mixes were approved in 2010, however there may be adjustments required due to 7 Seed Mixes March 30 TransCanada availability and quantity of species. • Nolan suggested that KXL use the recommendations provided by Marilyn Neville • AEP requested that there be no substitutions for Plains Rough Fescue and reduce the overall use of wheat and rye grasses in the mix • KXL to follow up with Nolan after consultation with Innotech • Nolan Ball will review the mixes and make suggestions if required • The ROW is still fenced with posts and barbed wire; some wire has been removed During 8 Fencing • If installing new fencing or replacing TransCanada construction the wires, make the fences wildlife compatible by making the bottom strand smooth wire so antelope and

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other wildlife can cross under the fence without harm • KXL plans to keep fencing in place during reclamation to protect from grazing. • Nolan recommended that areas be opened to grazing after 3 years to enhance weed control • Crown dispositions for the KXL pipeline remain in effect. Should 9 Disposition Updates temporary workspace be required, - - consent and approvals will be required by the occupants and Special Areas. • Keystone noted that regulatory clearances are in place, however current historical resources information will be reviewed to 30 days prior to 10 Historical Resources TransCanada/Stantec determine if field work is required as a construction result of other projects crossing or working parallel to Keystone in recent years. • KXL will provide specific mitigation for 11 other SAR for review and comment by - - ECCC

Please advise of any errors or omissions.

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KXL1399-TCP-XX-MOM-XXXX MINUTES OF MEETING

MEETING SUBJECT: Project and Mitigation Update- Alberta Sections

PROJECT: Keystone XL

LOCATION: Saskatchewan Environment, Regina SK

DATE/TIME: 1 March 2018, 12 noon to 245 pm

PREPARED BY: Jennifer Barker

ATTENDEES: • Ken Dillabaugh, Sask Env, Regina (Swift Current) • Lorne Veitch, Ministry of Agriculture, Swift Current • Jennifer Barker, TransCanada, Calgary • Darwin McNeely, TransCanada, Calgary

• Albert Lees, Stantec, Calgary

MINUTES OF MEETING

No. Activities/Action Items Comments Due Date Responsible

• Ensure you have the relevant travel Safety Moment insurance documents while travelling - - to other countries. • Discussed the location of the dens found in 2017 • Stantec to detemine the soil type in that area • Discussed the informal disussions with ECCC about relocating the individuals 1 Black-tailed Prairie Dog Mitigation in the colony. SKENV surprised that April 15 ALL ECCC would suggest relocation. • Ken D. would like to participate in the spring confirmatory BTPD survey • Follow up meeting is required to discuss BTPD mitigations after the spring survey • Provided updates related to survey methodologies for vegetation and wildlife, and indicated that KXL 2017 Methodologies and results of 2017 and 2018 surveys reflect current 2 - - surveys and 2018 survey plans requirements as discussed with SK Envi. • Provided update on the 2017 field surveys for wildlife and vegetation. • Some of the community pastures previously under PFRA are managed by “patron” companies comprised of landowners. Bigstick pasture will 3 Community Pastures revert to private ownership as of April - - 1, 2018. • There are some areas added by the federal government (non-reversionary) and added to the pastures

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• If crossed by KXL they will require federal permits. Keystone update: Majority of the PFRA tracts in Val Marie and Masefield will transfer to SK Lands Branch by April 1, 2018, with all tracts being transferred by April 1, 2019. After that there will be no federal tracts intersected by the project. • Discussed the current construction schedule and confirmed most of the pipe will be installed in the first year 4 Construction Schedule - - • Similar mitigations will be implemented during the second year construction and final clean up • Discussed construction techniques and mitigations through wetlands • Wetlands will be monitored for function during the 5 year post construction monitoring period • As part of the updates to wetlands on the project footprint, KXL will be reviewing the wetland crossing typical drawings and streamlining the number of drawings where possible to avoid 5 Wetlands and Amphibians confusion by KXL contractors and to March 30 TransCanada ensure understanding of the requirements. • Discussed Amphibian Exclusion fencing and Ken D recommended that amphibians be placed back into wetlands no more than 50 m away from the ROW • KXL will update the Amphibian Management Plan as per the recommendation • Ken requested that rare plants and wetlands be part of the post 6 Monitoring - - construction monitoring plans if not already in place • Stantec needs to update the survey protocol • Stantec will contact the provincial specialist Beatriz Prieto Diaz to obtain 7 Sage Grouse the appropriate survey methods prior April 30 TransCanada to spring 2018 surveys • KXL will follow up with Sask Env after survey results have been compiled. • Reviewed the seed mixes and indicated that KXL will be working to update the lists based on availability of seed • Seed previously collected for rare 8 Seed Mixes plants will be reseeded but no - - additional seed will be collected in Saskatchewan • Lorne requires that he obtains the individual seed certificates prior to mixing the seed mix • Discussed that the locations of the cleaning stations will need to be reviewed based on the direction of 9 Weeds April 15 TransCanada construction, especially in and around community pastures. Cleaning station locations and types adjacent to the

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Bigstick, Val Marie and Masefield community pastures may be altered, moved or deleted, as they were not always sited due to weed issues. • KXL will review locations of cleaning stations • KXL will need to consult with the Rural Municipalities for clubroot information • Ken expects that equipment will arrive clean into Saskatchewan, even if a wash station has to be relocated near the border to accommodate this request 10 Clubroot March 30 TransCanada • Ken stated that KXL should consider Enbridge’s Line 3 Clubroot mitigation plan and the frequency of cleaning equipment, as a model • KXL will review this plan during the development of its clubroot management plan for the project • Discussed crossing methods for Sask water crossings • Originally it was agreed to by DFO that Swift Current Creek could be an isolated open cut despite being fish bearing and a source of drinking water. Documentation on file from the project review by Fisheries and Oceans Canada indicates Swift Current Creek can be crossed with an 11 Watercourse Crossings isolated open-cut trench. April 15 TransCanada • Ken would prefer that bridges are used where ever possible to avoid the removal and replacement of ramp and culvert crossings between construction and clean up. This will minimize the disturbances to the watercourse • KXL will review the crossing methods and the crossing profiles to evaluate where bridges can be used • Ken will pass project information including rare plant mitigations on to Sarah Vinge-Mazer for review 12 Rare Plants March 30 TransCanada • KXL will follow up with Sarah to discuss any concerns with rare plant mitigations. • There are many areas of critical habitat crossed by the Project • KXL noted the project route was approved in advance of critical habitat areas placed and intersecting with the project footprint. 13 Critical Habitat April 30 TransCanada • South of the Divide – Ken will have some internal discussions on how to manage mitigations in areas of critical habitat • KXL will have follow up discussions with SKENV on critical habitat • Aquatic Habitat Protection Permits for wetlands and watercourses and Wildlife Habitat Protection Permits (for Construction permits from SK 14 applicable lands) will be required. SK - - Environment Envi recommended permit applications for approval be sent in 90 days in advance of construction.

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Please advise of any errors or omissions.

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KXL1399-TCP-XX-MOM-XXXX KEYSTONE XL PROJECT AGENDA – MEETING MINUTES

MEETING AGENDA AND MINUTES

MEETING SUBJECT: KXL Environmental Mitigation Plans DATE/TIME/LOCATION: Date & Time: 21 June 2018; 12 noon

Location: Government of Saskatchewan, 3211 Albert Street, Regina

CHAIR: Jennifer Barker

MINUTES PREPARED BY: Jennifer Barker

ATTENDEES: Darwin McNeely, Dale Kaczmar, Ken Dillabaugh (SK), Janna White (SK)

AGENDA

Item Agenda / Notes Actions / Results

Safety Moment: Pay particular attention to children around water, always within arm’s 1 • Water Safety reach; floatation devices should always be used; obtain proper training for motorized watercraft

Redeploy cameras (1 month) HD Bore as a back-up plan if there are Prairie Dogs: positive observations How many photos in the sample? 108 2 • Memo review If geotech is required there likely will • Proposed plan –construction with standard mitigations not be a permit required unless wetlands are impacted. Follow timing windows.

Sage grouse: Time of day restrictions apply just for lekking period (April 15 to June 15) • Within the 3.2 km buffer, no go between April 15 – July 15 3 • Year 2 clean-up and hydrotesting along cultivated field. ECCC found 5 sage grouse in the Masefield pasture (Ken will advise • Do time of day restrictions apply for construction during nesting? further)

Sharp tailed grouse: Confirmed acceptable mitigation

4 • Review mitigations (close and far proximity) Adhere to time of day restrictions if marshalling equipment through during • One lek within 75 m of ROW RAP.

Amphibians: 5 Field fit exclusion fencing starting at 50 m buffer from amphibian wetland

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• Review silt fence mitigation plan (diagram reviewed). Resource specialist on site to determine appropriate mitigation.

Leopard frogs – translocation guidelines in Saskatchewan (no further than 50 m) Ken to provide

Ken will determine if permits are required for amphibian handling

Critical Habitat: Smooth Goosefoot – construction timing post 1 Aug (forward • Smooth Goosefoot construction footprint to Ken for • Sprague’s pipit – none observed consultation with Sarah); determine the extent of the population (Stantec) • Chestnut collared Longspur – none observed and send to Ken. Sent. • Swift Fox – none observed 6 Other species if observed will be • Burrowing Owl – same location as previous covered by our Wildlife Discovery • Greater Sage grouse – none observed Contingency plan

• Mountain Plover – none observed Monitoring – min 5 years – consider • Blacktailed prairie dog – same location as previous longer monitoring around Leks, • Loggerhead Shrike – none observed goosefoot, BTPD, owls to confirm if mitigations are successful.

Remove straw crimping (imported straw – native hay from adjacent fields Great Sandhills Reclamation Plan: is acceptable) as a restoration measure; confirm the seed mix for 7 • Feedback sandy areas (different than previous) Lorne to approve; Janna to send over recently approved seed mix for sandy areas.

Rare Plant Mitigation:

8 • S1 and S2 (adapted and not adapted to disturbance) Reviewed and accepted • Drawings 901 and 931

Watercourse Crossings: Reviewed and Swift Current Creek crossing appears acceptable due to 9 • Review Saskatchewan crossing methods gentle contours. Sent Crossing table to Ken for review.

Hydrotest locations: Send Ken the FEHA monitoring 10 • Review constraints of proposed locations protocols for review. Sent

General Soil Handing Procedures: 11 Reviewed and accepted. • Review

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Clubroot update:

• Testing in progress to site cleaning station locations Review cleaning station locations when 12 available. • Policy development

Archaeological Update 13 Reviewed • Two shovel test sites

Review of Action Items:

• Adjourn. 1411. Next meeting after Prairie Dog Camera data is 14 available (August)

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KXL1399-TCP-XX-MOM-XXXX KEYSTONE XL PROJECT AGENDA – MEETING MINUTES

MEETING AGENDA AND MINUTES

MEETING SUBJECT: KXL Environmental Mitigation Plans DATE/TIME/LOCATION: Date & Time: 26 June 2018; 10 am

Location: Alberta Environment, Red Deer

CHAIR: Jennifer Barker

MINUTES PREPARED BY: Jennifer Barker

ATTENDEES: Darwin McNeely, Scott Stevens (AEP)

AGENDA

Item Agenda / Notes Actions / Results

Safety Moment: Pay particular attention to children around water, always within arm’s 1 • Water Safety reach; floatation devices should always be used; obtain proper training for motorized watercraft Exclusion fencing, monitoring and relocating snakes as required. Post Oct Snakes: 1 start as per direction of AEP 2 • Proposed construction timing and clean up mitigations depending on conditions and snake activity. Follow up with Sandi to confirm mitigation is appropriate. Sandi advised Stantec to complete Kangaroo Rats: 2018 reconnaissance along the access 3 road. No evidence of activity on the • Survey results and proposed mitigation high grade gravel road during the survey.

Mitigation appropriate as presented. Confirm lek activity in year of construction and clean up to determine appropriate mitigation. Sharp tailed grouse: Consider that topsoil piles may be in a position to act as a perch for predators 4 • Review mitigations (close and far proximity) or as a line of sight break depending on the site conditions and the proximity to the lek. Year of clean-up is of the most concern for activities as construction will take place in the fall outside of the breeding and nesting period.

Amphibians: 5 Year 1 – set up exclusion fencing prior to construction and it should remain in

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• Review silt fence mitigation plan place for the clean-up activities in the spring/summer. Start installation of the silt fencing post August 1 in fully wetted wetland (open water) to minimize impacts to metamorphosing amphibians. Resource biologists to delineate the location of exclusion fencing prior to construction.

FEHA monitoring as per protocol provided for active nests within the Raptors: 500 m buffer. AEP to advise on monitoring requirements for other 6 • Locations and proposed mitigation raptors if active nests are located • Confirm monitoring requirements within the provincial setbacks during construction and clean up. Consult with AEP on active nests within restricted buffer.

Critical Habitat: Reviewed. Negotiations ongoing with 7 • Slender mouse eared cress Joel Nicholson and KXL will provide a • Tiny cryptantha proposal.

Rare Plant Mitigation:

Follow up with Nolan and Trent for • S1 and S2 (adapted and not adapted to disturbance) 8 review of mitigations. • Drawings 901 and 931

Watercourse Crossings: Timing of crossing will occur as described. If activity is to occur within 9 • Review Alberta crossing methods RAP KXL must consult with Angela Fulton.

Test point 3 – STGR - adhere to 10-4pm timing restriction preferably, however the point is close to 500 m away from lek. Prefer discharge north of road to avoid potential impacts to the lek.

Test Point 11 – Snakes - implement speed limits, exclusion fencing and Hydrotest locations: daily monitoring to relocate snakes if 10 required. Follow up with Sandi to • Review constraints of proposed locations review mitigation.

Test point 12 – Shrikes – test location is acceptable as provincial setbacks are 100 m. KXL will close access past the active nests during the RAP.

Test point 15 and 16 - Snakes - implement speed limits, exclusion fencing and daily monitoring to

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relocate snakes if required. Follow up with Sandi to review mitigation.

General Soil Handing Procedures: Follow up with Nolan and Trent for 11 • Review review of mitigations.

Clubroot update:

Follow up with Nolan, Pat and Trent to • Testing in progress to site cleaning station locations 12 advise on current plans. • Policy development

Archaeological Update 13 Reviewed and will provide updates. • 5 excavation test sites

Other Items:

14 • Shrike nest at Oyen 33 – 100 m AEP setback and close access during Agreed to mitigation. nesting and use ROW only for construction access.

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KXL1399-TCP-XX-MOM-XXXX KEYSTONE XL PROJECT AGENDA – MEETING MINUTES

MEETING AGENDA AND MINUTES

MEETING SUBJECT: KXL Environmental Mitigation Plans DATE/TIME/LOCATION: Date & Time: 28 June 2018; 1 pm

Location: Environment and Climate Change Canada, Edmonton

CHAIR: Jennifer Barker

MINUTES PREPARED BY: Jennifer Barker

ATTENDEES: Darwin McNeely, Paul Gregoire (ECCC)

AGENDA

Item Agenda / Notes Actions / Results

Safety Moment: 1 - • Reviewed emergency exits to the East Gate Offices.

Review of project and schedule. Reviewed North and South spread 2 construction sequencing. Timing restriction – construction to begin post September 1. Plants: Smooth goosefoot location where the buffer overlaps the project footprint • Slender mouse eared cress (AB) near Piapot Creek is being reviewed by Sask Ministry of Environment. • Tiny cryptantha (AB) Rare plant mitigations were explained. 3 • Smooth goosefoot (Sask) Results of rare plant research has shown that mitigation for disturbance • Provincial Listings adapted rare plants is effective. S1 and S2 (adapted and not adapted to disturbance) Provincial resource managers have o confidence in our mitigation approach. o Drawings 901 and 931 Alberta Environment has requested a proposal for a compensation plan for SARA plants. Reviewed exclusion fencing, Snakes: monitoring, speed limits and

• Mitigation review construction timing (post October 1) as requested by Alberta Environment. Clay coloured and savannah sparrow Birds: nests are often found nesting in grasslands and pastures. May be • Migratory Bird Conservation encountered during construction if 4 • Mapped Critical Habitat within the migratory bird window. Ask Stantec to review candidate high • Results of surveys density nesting areas, and plan to • Raptors (ferruginous hawk, burrowing owl) preclear or use nesting deterrent (metallic reflective tape on 1 m posts)

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Reviewed the status of the potential Mammals: new BTPD location. KXL to update Paul on results of July remote camera 5 • Black-tailed prairie dogs survey. • Swift fox There were no swift fox observed during the 2017 surveys.

Amphibians: Reviewed silt fence plan for amphibian breeding wetlands. 6 • Northern Leopard Frog Stantec did not find salamanders • Review silt fence mitigation plan during the amphibian survey.

Watercourse Crossings: Reviewed crossing methods and timing 7 • Review crossing methods restrictions

Test point 3 – STGR - adhere to 10-4pm timing restriction preferably, however the point is close to 500 m away from lek. Prefer discharge north of road to avoid potential impacts to the lek.

Test Point 11 – Snakes - implement speed limits, exclusion fencing and daily monitoring to relocate snakes if Hydrotest locations: required. Follow up with Sandi to 8 review mitigation. • Review constraints of proposed locations Test point 12 – Shrikes – test location is acceptable as provincial setbacks are 100 m. KXL will close access past the active nests during the RAP.

Test point 15 and 16 - Snakes - implement speed limits, exclusion fencing and daily monitoring to relocate snakes if required. Follow up with Sandi to review mitigation.

Document (condition report review) Asked Paul to expect a document review during August 2018.

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KXL1399-TCP-XX-MOM-XXXX KEYSTONE XL PROJECT AGENDA – MEETING MINUTES

MEETING AGENDA AND MINUTES

MEETING SUBJECT: KXL Environmental Mitigation Plans DATE/TIME/LOCATION: Date & Time: 9 July 2018; 1030 am

Location: Alberta Environment, Medicine Hat

CHAIR: Jennifer Barker

MINUTES PREPARED BY: Jennifer Barker

ATTENDEES: Darwin McNeely, Sandi Robertson (AEP)

AGENDA

Item Agenda / Notes Actions / Results

Safety Moment: 1 - • Identified tripping hazards in the conference room. Cords etc. Rare Plant Mitigation: Reviewed ROW widths in drawings 901 and 931 and through cultivated fields. • S1 and S2 (adapted and not adapted to disturbance) 2 Accepted. AEP agreed with the • Drawings 901 and 931 approach to rare plant mitigation.

Reviewed construction methods, timing, and current SARA plant areas. Critical Habitat: Reviewed areas that will be included in compensation proposal. KXL will provide sometime in September. • Construction methods and sequencing • Past proposal and compensation Some areas on the ROW are not fenced 3 and the project may attempt to • Current rare plant areas conduct early cleanup to reduce the • Slender mouse eared cress need for fencing.

• Tiny cryptantha ROWs are being shared as much as practical between operators in the corridor to reduce total footprint through the area.

Treat all features (hibernacula and Snakes: rookeries) as active regardless of recent activity observations. 4 • Proposed construction timing and clean up mitigations, including Start construction activities after hydrotest locations (11, 15 and 16) October 1 upon consultation with AEP. Non-construction activities could

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happen prior to October 1 (eg., survey staking). Implement additional mitigation during clean up and hydrotesting: speed limit restrictions, exclusion fencing, monitoring and snake relocation. Prior to construction and clean up check activity of features west of the South Saskatchewan River. AEP has requested that KXL implement snake monitoring using pit taggers and remote scanners in fall of 2019, and in spring 2020. Monitoring should aim to determine if project mitigations for snakes are effective. AEP to advise on monitoring protocol. AEP advised that kangaroo rats could Kangaroo Rats: be observed at any time throughout 5 various habitats. Implement wildlife • Survey results and proposed mitigation discovery contingency plans and advise AEP if Kangaroo rats are observed.

KXL will use straw crimping in erosion prone soils. Past use has demonstrated minimal weed issues.

Burrowing owls – Calgary Zoo released Burrowing owls near Suffield Base. There is potential for the owls to migrate into the construction area. Other Business Implement wildlife discovery 6 contingency plans and advise AEP if owls are observed.

Hognose snakes – have been observed in the Remount pasture and on Minor Ranch. They will occupy old burrows in sandy soils. Implement wildlife discovery contingency plans and advise AEP if hognose snakes are observed.

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KXL1399-TCP-XX-MOM-XXXX KEYSTONE XL PROJECT AGENDA – MEETING MINUTES

MEETING AGENDA AND MINUTES

MEETING SUBJECT: KXL Environmental Mitigation Plans DATE/TIME/LOCATION: Date & Time: 11 July 2018; 1 pm

Location: Special Areas, Oyen

CHAIR: Jennifer Barker

MINUTES PREPARED BY: Jennifer Barker

ATTENDEES: Darwin McNeely, Nolan Ball, Trent Caskey

AGENDA

Item Agenda / Notes Actions / Results

Hazards such as farm equipment, improperly loaded and wide load Safety Moment: vehicles can delay traffic and cause 1 • Driving on remote highways and working alone. hazards. Call in and check in schedules are a requirement for working in remote locations when working alone.

Consult with Special Areas when Rare Plant Mitigation: placing fences in rare plant areas. “Drift fences” (in a series) have also • Construction timing (fall and spring) been used to manage access near 2 • S1 and S2 (adapted and not adapted to disturbance) sensitive sites. Clean up of post July 1 is preferred, but early summer (May and • Drawings 901 and 931 June) is acceptable.

KXL explained that geotextile is normally not used under spoil piles and prairie sweepers and other low impact equipment is used to protect the General Soil Handing Procedures: surface layer. 3 REC 7/8 areas – timing for construction • Drawings for native range soil handling procedures is post July 15. KXL will be narrowing up construction footprint as much as possible and workspaces will be removed.

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Special Areas asked KXL to consider the use of fescue plugs for site restoration.

Special Areas asked KXL to consider wild seed harvesting for restoration of native range.

Seed mixes are acceptable as presented by Innotech Native seed mix update: Straw crimping is acceptable as well as 4 • Innotech study results mixing in straw to increase the effectiveness of revegetation.

Lessons learned from Keystone Base – weeds can become predominant if fencing is left up too long and grazing is prevented. Grazing assists the recovery of native range and should be opened to grazing after 2 to 3 years of seedling growth.

Special Areas noted that blueweed has Equipment Cleaning Stations: been observed and is being treated near Lakes End section KP28, in the 5 • Locations in Special Areas road ditches. Locations of cleaning stations have not changed from the last submission.

Clubroot update: Special Areas would like to be advised if there are positive hits of clubroot in 6 • Testing in progress to site cleaning station locations their regions of jurisdiction. KXL will • Policy development consult with the landowners on confidentiality requirements.

Other items:

• Camps Provide Special Areas with an update 7 on camp locations.

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KXL1399-TCP-XX-MOM-XXXX KEYSTONE XL PROJECT AGENDA – MEETING MINUTES

MEETING AGENDA AND MINUTES

MEETING SUBJECT: KXL Environmental Mitigation Plans DATE/TIME/LOCATION: Date & Time: 18 July 2018; 9 am

Location: Alberta Environment and Parks, Wainwright, AB

CHAIR: Jennifer Barker

MINUTES PREPARED BY: Jennifer Barker

ATTENDEES: Darwin McNeely, Richard Bauer, Pat Porter (AEP), Zoey Zapisocki (AEP)

AGENDA

Item Agenda Notes

Safety Moment: • Driving and working alone – SPOT devices are 1 used • Aggrieved landowners coming into the office

Timing will be dependent on time of clean up but likely will complete fall seeding to increase success. A cover crop will be used in erosion Seed Mixes: prone areas. 2 Seed mix review completed with feedback. Waiting for landowner • Innotech report preferences to order seed and stockpile for future use.

Seed Mix 4 most abundant in this area.

Seed mixes will be identified in the EFRs.

Clearing scheduled for mid-January to 1 March 2019, primarily mulching and burning excess material. Beware of fire hazards and monitor burn piles until extinguished. Sloops or sleds are used, or burning will be done on subsoil. If landowners don’t want the wood, Vegetation: KXL will donate bucked wood to MDs or Provincial campgrounds. 3 Contact Marty Biro (maintenance and roads) for more information. • Clearing, RECs, rare plants AEP will be invited to the kickoff meeting prior to clearing.

Rare plants - Soil handling and timing of construction is dependent on whether rare species are adapted to disturbance. Ramps will be used to avoid disturbance to plants. Topsoil and spoil will be removed from the sod layer prior to the next growing season.

Breeding Birds: Construction will likely be later in the nesting season by the time we 4 get to the north part of the north spread. KXL will sweep for nests

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• Management Plan and establish an appropriate setback. In addition, trees will be cleared in the winter and should reduce the possibility of raptor nests being disturbed. AEP would like KXL to report all sightings of turkey vultures. Sharptail grouse leks – construction will not start until July 15. For cleanup, activities will adhere to a daily timing restriction if within lekking period.

No leopard frogs observed in this region. Amphibians: Canadian toads, plains spadefoot were observed. 5 • Management and exclusion fencing Exclusion fencing will be used as the main mitigation to protect amphibians and the breeding wetlands. Canada thistle, spurge, sow thistle are primary weeds of concern along the ROW in addition to Downy brome in small amounts. Scentless chamomile has been observed in small amounts on Keystone Base. Weeds and Clubroot: AEP advised that Toadflax may be present. Hoary allysium has been 6 found along rail line at Hardisty, south of Ribstone along the • Update on surveys highway. Spotted knapweed observed on the army base. Absinthe is becoming a nuisance weed but has not be acknowledged by the Alberta Weed Control Act. KXL to beware and make note of any observations. Clubroot surveys underway with no positive occurrences to date. The 5 PLAs that are in place, submitted in 2011, include Ribstone Creek Disposition Updates: EFRs will be updated and submitted end of September 2018 directly 7 • Timing and method to Pat Porter’s email. KXL Land group is talking to grazing lease holders about seed, water pumping, soil handing, erosion control.

Historical Resources: KXL provided an update that 5 sites are in the process of being 8 • Summer activities excavated in Alberta. Techniques and construction timing were reviewed. Mainline Soil Handling: construction is scheduled to occur late summer and fall 2019 (unfrozen conditions). Clean up will occur the following 9 • range stripping spring/summer 2020 to ensure trench spoil is not frozen prior to compaction. • cultivated and hay lands Hay and cultivated lands will be full ROW stripping up to 32 m. Extra work space will be obtained for soil storage and tie ins.

Innotech research plots and scope – what is the plan for further Other Business 10 study for native range restoration? KXL to provide update in September.

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From: Dillabaugh, Ken ENV To: Jennifer Barker; Veitch, Lorne AG Cc: Darwin McNeely Subject: [EXTERNAL] RE: Keystone XL Mitigation Date: Monday, December 24, 2018 2:53:01 PM

The Ministry of Environment (ENV) is satisfied with the mitigation proposed for the Keystone XL project. With regards to smooth goosefoot ENV is recommending that TransCanada commit to population assessments, in the identified locations of the EPP, during the 5-year post construction monitoring. The mitigation for the crossing of Bone Creek is accepted. There is a large population of noxious weeds located in the right of way at Bone Creek. TransCanada will be required to put a concerted effort to remove and manage the weed population at this crossing during the 5-year post construction monitoring.

Ken Dillabaugh Government of Saskatchewan Senior Ecological Protection Specialist Fish,Wildlife and Lands, Ministry of Environment #516, 350 Cheadle Street West Swift Current, Canada S9H 4G3 Bus: 306-778-8260 Cell: 306-741-8270 Fax: 306-778-8212

From: Jennifer Barker Sent: Thursday, December 20, 2018 3:50 PM To: Dillabaugh, Ken ENV ; Veitch, Lorne AG Cc: Darwin McNeely Subject: Keystone XL Mitigation

Good day Ken and Lorne,

Please find attached a summary of Keystone’s proposed mitigations for the Keystone XL project, as discussed with you throughout 2018. Please confirm that you are satisfied with all the mitigations proposed by Keystone, specifically with regards to: - SARA species o Blacktailed Prairie Dog Mitigation and Traffic Management Plans (that include burrowing owls, and ferrets), o Northern Leopard frogs and the Amphibian Management Plan, o the Greater sage grouse mitigation measures, and o smooth goosefoot mitigation measures. - Soil handling in native range - Amendments to the Great Sand Hills Restoration Plan that include the removal of straw crimping and the addition of soil tackifier to the restoration measures. In addition, please confirm that no further consultation is required with the Great Sand Hills Planning Commission or the Rural Municipality of Piapot.

In addition, please confirm you are satisfied with the planned mitigation at the Bone Creek crossing in SW 14-10-21-W3M:

- The Keystone XL Project is planning to remove an abandoned section of the Foothills Pipeline through Bone Creek, and place the proposed KXL pipeline in the same location. The construction footprint is adjacent to but not within a rare ecological community (beakedwillow/red osier plant community). Foothills has applied to the NEB for removal and decommissioning of the Foothills pipeline section. - In the event that approval is not granted to Foothills, KXL proposes to place the new pipeline within the same construction footprint (including permanent and temporary workspaces) as planned for the Foothills pipeline decommissioning, as currently indicated in the Keystone XL EPP . The centerline of the proposed Keystone XL pipeline section would be moved away from the abandoned Foothills pipeline section, adjusted accordingly and placed to fit within the confines of the KXL permanent easement. The current construction footprint has been configured to avoid the beaked willow/red osier dogwood community. Equipment and vehicle access, along with pipe and soil placement may require adjustments to allow for a safe execution of the work. - There would be no change to the method of pipeline installation through Bone Creek as indicated in the EPP. All construction will occur within the currently approved construction footprint, would not require any additional construction footprint, therefore the beakedwillow/red osier plant community will continue to be avoided. Relevant general mitigation measures (eg. sediment and erosion controls) as proposed in the EPP will continue to be implemented as required.

Many thanks for your co-operation and support throughout the year, and for your prompt response. Please have a safe and peaceful holiday season.

Regards, Jennifer

Jennifer Barker M.Sc., P.Biol. Senior Environmental Advisor Environment, Land and Indigenous Relations [email protected]

450 – 1st. Street S.W. Calgary, Alberta Canada T2P 5H1

Tel: 587.933.3728 Cell: 403.437.4905

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KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Appendix D Rare Plant Records on the Construction Footprint January 2019

RARE PLANT RECORDS ON THE CONSTRUCTION FOOTPRINT

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Appendix D Rare Plant Records on the Construction Footprint January 2019

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Appendix D Rare Plant Records on the Construction Footprint January 2019

D.1

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Appendix E Rare Plant Records within 30 m of the Construction Footprint January 2019

RARE PLANT RECORDS WITHIN 30 M OF THE CONSTRUCTION FOOTPRINT

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Appendix E Rare Plant Records within 30 m of the Construction Footprint January 2019

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Appendix E Rare Plant Records within 30 m of the Construction Footprint January 2019

E.1

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Appendix F Rare Ecological Communities within the Construction Footprint January 2019

RARE ECOLOGICAL COMMUNITIES WITHIN THE CONSTRUCTION FOOTPRINT

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Appendix F Rare Ecological Communities within the Construction Footprint January 2019

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Appendix F Rare Ecological Communities within the Construction Footprint January 2019

Table F-1 Locations of Rare Ecological Communities by Pipeline Segment, Areas within Disturbance Footprint and Construction Mitigation for Alberta

REC Construction KP Length RoW TWS TF PDA Latin Name Common Name Unique ID Mitigation Map Sheet Segment Name Start KP End KP (m) (ha) (ha) (ha) (ha) Festuca hallii grassland Plains rough fescue REC-01-AB EC-01a 4351-09-PL-03-003 Hardisty Ditchline 6+500 7+300 714.5 1.39 2.35 0.00 3.74 grassland Festuca hallii grassland Plains rough fescue REC-02-AB EC-01a 4352-09-PL-03-003 Lakesend East Ditchline 8+100 8+900 817.7 0.00 0.00 4.09 4.09 grassland Elaeagnus commutata / silverberry / western REC-03-AB EC-01 4352-09-PL-03-005 Lakesend East Ditchline 13+900 13+900 73.2 0.00 0.00 0.19 0.19 Pascopyrum smithii Shrubland wheat grass shrubland Festuca hallii grassland Plains rough fescue REC-04-AB EC-01a 4352-09-PL-03-007 Lakesend East Ditchline 22+500 24+200 1640.2 0.00 0.00 8.23 8.23 grassland Festuca hallii - Hesperostipa plains rough fescue - REC-05-AB EC-01a 4352-09-PL-03-008 Lakesend East Ditchline 24+400 24+600 198.6 0.00 0.00 1.16 1.16 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-06-AB EC-01a 4352-09-PL-03-008 Lakesend East Ditchline 25+100 25+100 54.0 0.00 0.00 0.19 0.19 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-07-AB EC-01a 4352-09-PL-03-008 Lakesend East Ditchline 25+300 25+600 266.3 0.00 0.00 1.15 1.15 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-08-AB EC-01a 4352-09-PL-03-009 Lakesend East Ditchline 28+000 28+000 47.3 0.00 0.00 0.15 0.15 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-09-AB EC-01a 4352-09-PL-03-009 Lakesend East Ditchline 28+000 28+100 60.9 0.00 0.00 0.10 0.10 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-10-AB EC-01a 4352-09-PL-03-009 Lakesend East Ditchline 28+100 28+200 28.2 0.00 0.00 0.06 0.06 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-11-AB EC-02 4352-09-PL-03-010 Lakesend East Ditchline 31+000 31+300 329.9 0.00 0.00 1.36 1.36 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-12-AB EC-02 4352-09-PL-03-010 Lakesend East Ditchline 31+300 31+500 123.1 0.00 0.00 0.49 0.49 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-13-AB EC-02 4352-09-PL-03-010 Lakesend East Ditchline 31+500 31+600 104.7 0.00 0.00 0.40 0.40 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-14-AB EC-02 4352-09-PL-03-010 Lakesend East Ditchline 31+700 31+800 80.9 0.00 0.00 0.26 0.26 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-15-AB EC-02 4352-09-PL-03-010 Lakesend East Ditchline 31+800 31+900 67.1 0.00 0.00 0.28 0.28 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-16-AB EC-02 4352-09-PL-03-010 Lakesend East Ditchline 32+000 32+000 62.9 0.00 0.00 0.28 0.28 curtiseta grassland western porcupine grass grassland

F.1

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Appendix F Rare Ecological Communities within the Construction Footprint January 2019

Table F-1 Locations of Rare Ecological Communities by Pipeline Segment, Areas within Disturbance Footprint and Construction Mitigation for Alberta

REC Construction KP Length RoW TWS TF PDA Latin Name Common Name Unique ID Mitigation Map Sheet Segment Name Start KP End KP (m) (ha) (ha) (ha) (ha) Festuca hallii - Hesperostipa plains rough fescue - REC-17-AB EC-02 4352-09-PL-03-010 Lakesend East Ditchline 32+100 32+300 260.5 0.00 0.00 1.14 1.14 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-18-AB EC-02 4352-09-PL-03-010 Lakesend East Ditchline 32+400 32+500 96.4 0.00 0.00 0.33 0.33 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-19-AB EC-02 4352-09-PL-03-010 Lakesend East Ditchline 32+600 32+700 99.0 0.00 0.00 0.40 0.40 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-20-AB EC-01a 4352-09-PL-03-011 Lakesend East Ditchline 33+100 33+100 88.3 0.00 0.00 0.30 0.30 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-21-AB EC-02 4352-09-PL-03-013 Lakesend East Ditchline 39+800 39+900 131.1 0.00 0.00 0.69 0.69 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-22-AB EC-02 4352-09-PL-03-013 Lakesend East Ditchline 40+000 40+000 57.6 0.00 0.00 0.14 0.14 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-23-AB EC-02 4352-09-PL-03-013 Lakesend East Ditchline 40+000 40+100 69.8 0.00 0.00 0.30 0.30 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-24-AB EC-02 4352-09-PL-03-013 Lakesend East Ditchline 40+100 40+200 44.9 0.00 0.00 0.18 0.18 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-25-AB EC-02 4352-09-PL-03-013 Lakesend East Ditchline 40+200 40+300 94.0 0.00 0.00 0.39 0.39 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-26-AB EC-02 4352-09-PL-03-013 Lakesend East Ditchline 40+500 40+600 84.6 0.00 0.00 0.33 0.33 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-27-AB EC-02 4352-09-PL-03-013 Lakesend East Ditchline 40+700 41+000 341.2 0.00 0.00 1.70 1.70 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-28-AB EC-02 4352-09-PL-03-013 Lakesend East Ditchline 41+100 41+300 191.7 0.00 0.00 0.74 0.74 curtiseta grassland western porcupine grass grassland Puccinellia nuttalliana Nuttall's salt-meadow REC-29-AB EC-01 4352-09-PL-03-016 Lakesend East Ditchline 49+400 49+700 333.5 0.00 0.00 1.54 1.54 community grass community Festuca hallii - Hesperostipa plains rough fescue - REC-30-AB EC-02 4353-09-PL-03-002 Monitor South Ditchline 5+400 5+700 304.7 0.00 0.00 1.19 1.19 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-31-AB EC-02 4353-09-PL-03-002 Monitor South Ditchline 5+800 5+900 99.3 0.00 0.00 0.39 0.39 curtiseta grassland western porcupine grass grassland

F.2

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Appendix F Rare Ecological Communities within the Construction Footprint January 2019

Table F-1 Locations of Rare Ecological Communities by Pipeline Segment, Areas within Disturbance Footprint and Construction Mitigation for Alberta

REC Construction KP Length RoW TWS TF PDA Latin Name Common Name Unique ID Mitigation Map Sheet Segment Name Start KP End KP (m) (ha) (ha) (ha) (ha) Festuca hallii - Hesperostipa plains rough fescue - REC-32-AB EC-02 4353-09-PL-03-002 Monitor South Ditchline 5+900 6+100 200.0 0.00 0.00 0.43 0.43 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-33-AB EC-02 4353-09-PL-03-002 Monitor South Ditchline 6+400 6+500 89.4 0.00 0.00 0.26 0.26 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-34-AB EC-02 4353-09-PL-03-002 Monitor South Ditchline 6+600 6+600 33.3 0.00 0.00 0.11 0.11 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-35-AB EC-02 4353-09-PL-03-002 Monitor South Ditchline 6+700 6+700 89.8 0.00 0.00 0.31 0.31 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-36-AB EC-02 4353-09-PL-03-002 Monitor South Ditchline 6+800 6+800 38.0 0.00 0.00 0.06 0.06 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-37-AB EC-02 4353-09-PL-03-002 Monitor South Ditchline 6+900 7+000 124.9 0.00 0.00 0.70 0.70 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-39-AB EC-02 4353-09-PL-03-003 Monitor South Ditchline 7+300 7+400 136.2 0.00 0.00 0.32 0.32 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-38-AB EC-02 4353-09-PL-03-003 Monitor South Ditchline 7+400 7+600 171.3 0.00 0.00 0.60 0.60 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-40-AB EC-02 4353-09-PL-03-003 Monitor South Ditchline 7+900 8+200 350.7 0.00 0.00 1.49 1.49 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-41-AB EC-02 4353-09-PL-03-003 Monitor South Ditchline 8+300 8+400 144.7 0.00 0.00 0.71 0.71 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-42-AB EC-02 4353-09-PL-03-003 Monitor South Ditchline 8+500 8+600 131.5 0.00 0.00 0.57 0.57 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-43-AB EC-02 4353-09-PL-03-003 Monitor South Ditchline 8+700 8+800 84.8 0.00 0.00 0.21 0.21 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-44-AB EC-02 4353-09-PL-03-003 Monitor South Ditchline 9+100 9+300 235.7 0.00 0.00 0.85 0.85 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-45-AB EC-02 4353-09-PL-03-003 Monitor South Ditchline 9+400 9+600 111.3 0.00 0.00 0.43 0.43 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-46-AB EC-02 4353-09-PL-03-003 Monitor South Ditchline 9+600 9+700 91.4 0.00 0.00 0.45 0.45 curtiseta grassland western porcupine grass grassland

F.3

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Appendix F Rare Ecological Communities within the Construction Footprint January 2019

Table F-1 Locations of Rare Ecological Communities by Pipeline Segment, Areas within Disturbance Footprint and Construction Mitigation for Alberta

REC Construction KP Length RoW TWS TF PDA Latin Name Common Name Unique ID Mitigation Map Sheet Segment Name Start KP End KP (m) (ha) (ha) (ha) (ha) Festuca hallii - Hesperostipa plains rough fescue - REC-47-AB EC-02 4353-09-PL-03-003 Monitor South Ditchline 9+700 9+800 43.4 0.00 0.00 0.21 0.21 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-48-AB EC-02 4353-09-PL-03-003 Monitor South Ditchline 9+800 9+900 38.1 0.00 0.00 0.05 0.05 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-49-AB EC-02 4353-09-PL-03-003 Monitor South Ditchline 9+900 10+000 135.7 0.00 0.00 0.46 0.46 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-50-AB EC-02 4353-09-PL-03-003 Monitor South Ditchline 10+000 10+100 45.8 0.00 0.00 0.10 0.10 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-51-AB EC-02 4353-09-PL-03-003 Monitor South Ditchline 10+100 10+200 65.0 0.00 0.00 0.19 0.19 curtiseta grassland western porcupine grass grassland Pascopyrum smithii - Carex western wheat grass - REC-52-AB EC-01 4353-09-PL-03-009 Monitor South Ditchline 28+500 28+700 191.9 0.00 0.00 0.76 0.76 duriuscula meadow low sedge meadow Festuca hallii - Hesperostipa plains rough fescue - REC-53-AB EC-02 4353-09-PL-03-012 Monitor South Ditchline 39+900 40+000 53.5 0.00 0.00 0.13 0.13 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-54-AB EC-02 4353-09-PL-03-012 Monitor South Ditchline 40+100 40+200 131.7 0.00 0.00 0.50 0.50 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-55-AB EC-02 4353-09-PL-03-013 Monitor South Ditchline 44+400 44+500 109.7 0.00 0.00 0.33 0.33 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-56-AB EC-02 4353-09-PL-03-013 Monitor South Ditchline 44+600 44+700 81.0 0.00 0.00 0.27 0.27 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-57-AB EC-02 4353-09-PL-03-014 Monitor South Ditchline 44+800 44+800 46.9 0.00 0.00 0.14 0.14 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-58-AB EC-02 4353-09-PL-03-014 Monitor South Ditchline 44+900 45+000 124.8 0.00 0.00 0.47 0.47 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-59-AB EC-02 4353-09-PL-03-014 Monitor South Ditchline 45+000 45+100 99.3 0.00 0.00 0.14 0.14 curtiseta grassland western porcupine grass grassland Festuca hallii - Hesperostipa plains rough fescue - REC-60-AB EC-02 4353-09-PL-03-014 Monitor South Ditchline 45+200 45+200 55.8 0.00 0.00 0.19 0.19 curtiseta grassland western porcupine grass grassland Pascopyrum smithii - Carex western wheat grass - REC-61-AB EC-01 4354-09-PL-03-015 Oyen South Ditchline 45+800 46+000 195.2 0.00 0.00 0.58 0.58 duriuscula meadow low sedge meadow Pascopyrum smithii - Carex western wheat grass - REC-62-AB EC-01 4354-09-PL-03-015 Oyen South Ditchline 47+500 47+500 55.6 0.00 0.00 0.11 0.11 duriuscula meadow low sedge meadow

F.4

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Appendix F Rare Ecological Communities within the Construction Footprint January 2019

Table F-1 Locations of Rare Ecological Communities by Pipeline Segment, Areas within Disturbance Footprint and Construction Mitigation for Alberta

REC Construction KP Length RoW TWS TF PDA Latin Name Common Name Unique ID Mitigation Map Sheet Segment Name Start KP End KP (m) (ha) (ha) (ha) (ha) Artemisia cana/Hesperostipa silver sagebrush / REC-63-AB EC-01 4354-09-PL-03-017 Oyen South Ditchline 52+600 54+000 1331.5 0.00 0.00 6.33 6.33 comata - Calamovilfa longifolia needle-and-thread - shrub herbaceous sand grass shrub herbaceous Artemisia cana/Hesperostipa silver sagebrush / REC-64-AB EC-01 4354-09-PL-03-018 Oyen South Ditchline 56+800 57+200 379.6 0.00 0.00 1.46 1.46 comata - Calamovilfa longifolia needle-and-thread - shrub herbaceous sand grass shrub herbaceous Pascopyrum smithii - Carex western wheat grass - REC-65-AB EC-01 4354-09-PL-03-020 Oyen South Ditchline 62+500 62+900 322.2 0.00 0.00 0.72 0.72 duriuscula meadow low sedge meadow Pascopyrum smithii - Carex western wheat grass - REC-66-AB EC-01 4354-09-PL-03-020 Oyen South Ditchline 63+700 64+000 263.8 0.00 0.00 1.19 1.19 duriuscula meadow low sedge meadow Pascopyrum smithii - Carex western wheat grass - REC-67-AB EC-01 4354-09-PL-03-020 Oyen South Ditchline 64+200 64+600 394.0 0.00 0.00 0.92 0.92 duriuscula meadow low sedge meadow

F.5

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Appendix F Rare Ecological Communities within the Construction Footprint January 2019

Table F-2 Locations of Rare Ecological Communities by Pipeline Segment, Areas within Disturbance Footprint and Construction Mitigation for Saskatchewan

Construction KP Length RoW TWS TF PDA Latin Name Common Name REC Unique ID Mitigation Map Sheet Segment Name Start KP End KP (m) (ha) (ha) (ha) (ha) Calamovilfa longifolia - sand grass - needle- REC-70-SK EC-01 4356-09-PL-03-007 Fox Valley Ditchline 19+300 19+500 169.2 0.00 0.00 0.43 0.43 Hesperostipa comata and-thread grassland Grassland Calamovilfa longifolia - sand grass - needle- REC-71-SK EC-01 4356-09-PL-03-009 Fox Valley Ditchline 26+200 26+400 161.7 0.00 0.00 0.54 0.54 Hesperostipa comata and-thread grassland Grassland Calamovilfa longifolia - sand grass - needle- REC-72-SK EC-01 4356-09-PL-03-009 Fox Valley Ditchline 26+400 27+600 1235.6 0.00 0.00 3.40 3.40 Hesperostipa comata and-thread grassland Grassland Calamovilfa longifolia - sand grass - needle- REC-73-SK EC-01 4356-09-PL-03-009 Fox Valley Ditchline 27+700 28+500 749.6 0.00 0.00 2.84 2.84 Hesperostipa comata and-thread grassland Grassland Sporobolus cryptandrus semi- Sand dropseed REC-74-SK EC-01 4356-09-PL-03-010 Fox Valley Ditchline 31+400 31+500 68.0 0.00 0.00 0.13 0.13 active dune Semi-active dune Calamovilfa longifolia - sand grass - needle- REC-75-SK EC-01 4356-09-PL-03-011 Fox Valley Ditchline 33+200 33+500 293.0 0.00 0.00 1.00 1.00 Hesperostipa comata and-thread grassland Grassland Artemisia cana/Hesperostipa silver sagebrush / REC-76-SK EC-01 4356-09-PL-03-013 Fox Valley Ditchline 41+000 41+600 599.1 0.00 0.00 1.57 1.57 comata - Calamovilfa longifolia needle-and-thread - shrub herbaceous sand grass shrub herbaceous Artemisia cana/Hesperostipa silver sagebrush / REC-77-SK EC-01 4356-09-PL-03-016 Fox Valley Ditchline 51+000 51+700 684.0 0.00 0.00 2.72 2.72 comata - Calamovilfa longifolia needle-and-thread - shrub herbaceous sand grass shrub herbaceous Puccinellia nuttalliana Nuttall's salt-meadow REC-78-SK EC-01 4356-09-PL-03-017 Fox Valley Ditchline 52+400 52+500 27.5 0.00 0.00 0.07 0.07 community grass community Puccinellia nuttalliana Nuttall's salt-meadow REC-79-SK EC-01 4356-09-PL-03-017 Fox Valley Ditchline 52+500 52+500 7.5 0.00 0.00 0.01 0.01 community grass community Calamovilfa longifolia - sand grass - needle- REC-80-SK EC-01 4356-09-PL-03-018 Fox Valley Ditchline 55+400 55+400 28.4 0.00 0.00 0.05 0.05 Hesperostipa comata and-thread grassland Grassland Artemisia cana/Hesperostipa silver sagebrush / REC-81-SK EC-01 4356-09-PL-03-019 Fox Valley Ditchline 57+800 57+800 43.8 0.00 0.00 0.06 0.06 comata - Calamovilfa longifolia needle-and-thread - shrub herbaceous sand grass shrub herbaceous Acer negundo / Prunus Manitoba maple / REC-82-SK EC-01 4357-09-PL-03-001 Piapot Ditchline 1+000 1+000 55.4 0.00 0.00 0.05 0.05 virginiana Forest choke cherry forest Sarcobatus vermiculatus / greasewood / salt REC-85-SK EC-01 4357-09-PL-03-016 Piapot Ditchline 48+700 49+700 937.7 0.00 0.00 4.12 4.12 Distichlis stricta - Pascopyrum grass - western smithii shrub herbaceous wheat grass shrub vegetation herbaceous vegetation Salix bebbiana / Cornus beaked willow / red- REC-83-SK EC-01 4357-09-PL-03-006 Piapot Ditchline 0+000 0+000 0.0 0.00 0.00 0.00 0.00 stolonifera shrubland osier dogwood shrubland

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Appendix F Rare Ecological Communities within the Construction Footprint January 2019

Table F-2 Locations of Rare Ecological Communities by Pipeline Segment, Areas within Disturbance Footprint and Construction Mitigation for Saskatchewan

Construction KP Length RoW TWS TF PDA Latin Name Common Name REC Unique ID Mitigation Map Sheet Segment Name Start KP End KP (m) (ha) (ha) (ha) (ha) Salix bebbiana / Cornus beaked willow / red- REC-84-SK EC-01 4357-09-PL-03-006 Piapot Ditchline 0+000 0+000 0.0 0.00 0.00 0.00 0.00 stolonifera shrubland osier dogwood shrubland Artemisia cana/Hesperostipa silver sagebrush / REC-86-SK EC-01 4358-09-PL-03-005 Grassy Creek Ditchline 16+000 16+600 608.9 0.96 1.94 0.00 2.90 comata - Calamovilfa longifolia needle-and-thread - shrub herbaceous sand grass shrub herbaceous Artemisia cana/Hesperostipa silver sagebrush / REC-87-SK EC-01 4358-09-PL-03-006 Grassy Creek Ditchline 16+600 16+700 81.0 0.11 0.18 0.00 0.29 comata - Calamovilfa longifolia needle-and-thread - shrub herbaceous sand grass shrub herbaceous Artemisia cana/Hesperostipa silver sagebrush / REC-88-SK EC-01 4358-09-PL-03-006 Grassy Creek Ditchline 16+700 16+800 130.6 0.08 0.28 0.00 0.36 comata - Calamovilfa longifolia needle-and-thread - shrub herbaceous sand grass shrub herbaceous Artemisia cana/Hesperostipa silver sagebrush / REC-89-SK EC-01 4358-09-PL-03-006 Grassy Creek Ditchline 16+800 16+900 53.4 0.02 0.10 0.00 0.12 comata - Calamovilfa longifolia needle-and-thread - shrub herbaceous sand grass shrub herbaceous Artemisia cana/Hesperostipa silver sagebrush / REC-90-SK EC-01 4358-09-PL-03-006 Grassy Creek Ditchline 16+900 17+100 160.5 0.13 0.43 0.00 0.56 comata - Calamovilfa longifolia needle-and-thread - shrub herbaceous sand grass shrub herbaceous Artemisia cana/Hesperostipa silver sagebrush / REC-91-SK EC-01 4358-09-PL-03-006 Grassy Creek Ditchline 18+100 18+100 81.1 0.10 0.33 0.00 0.43 comata - Calamovilfa longifolia needle-and-thread - shrub herbaceous sand grass shrub herbaceous Artemisia cana/Hesperostipa silver sagebrush / REC-92-SK EC-01 4358-09-PL-03-006 Grassy Creek Ditchline 18+200 18+500 348.2 0.33 0.98 0.00 1.32 comata - Calamovilfa longifolia needle-and-thread - shrub herbaceous sand grass shrub herbaceous Artemisia cana/Hesperostipa silver sagebrush / REC-93-SK EC-01 4358-09-PL-03-006 Grassy Creek Ditchline 18+500 18+600 112.9 0.06 0.20 0.00 0.27 comata - Calamovilfa longifolia needle-and-thread - shrub herbaceous sand grass shrub herbaceous Artemisia cana/Stipa comata - silver sagebrush / REC-94-SK EC-01 4358-09-PL-03-006 Grassy Creek Ditchline 19+200 19+400 242.9 0.45 0.58 0.00 1.03 Pascopyrum smithii - needle-and-thread - Bouteloua gracilis shrub western wheat herbaceous grass - blue grama shrub herbaceous Artemisia cana/Stipa comata - silver sagebrush / REC-95-SK EC-01 4358-09-PL-03-006 Grassy Creek Ditchline 19+500 19+600 99.9 0.16 0.27 0.00 0.43 Pascopyrum smithii - needle-and-thread - Bouteloua gracilis shrub western wheat herbaceous grass - blue grama shrub herbaceous

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Appendix F Rare Ecological Communities within the Construction Footprint January 2019

Table F-2 Locations of Rare Ecological Communities by Pipeline Segment, Areas within Disturbance Footprint and Construction Mitigation for Saskatchewan

Construction KP Length RoW TWS TF PDA Latin Name Common Name REC Unique ID Mitigation Map Sheet Segment Name Start KP End KP (m) (ha) (ha) (ha) (ha) Artemisia cana/Stipa comata - silver sagebrush / REC-96-SK EC-01 4358-09-PL-03-007 Grassy Creek Ditchline 19+600 19+800 184.6 0.34 0.64 0.00 0.98 Pascopyrum smithii - needle-and-thread - Bouteloua gracilis shrub western wheat herbaceous grass - blue grama shrub herbaceous Artemisia cana/Stipa comata - silver sagebrush / REC-97-SK EC-01 4358-09-PL-03-007 Grassy Creek Ditchline 19+800 20+100 312.2 0.54 0.98 0.00 1.51 Pascopyrum smithii - needle-and-thread - Bouteloua gracilis shrub western wheat herbaceous grass - blue grama shrub herbaceous Artemisia cana/Stipa comata - silver sagebrush / REC-98-SK EC-01 4358-09-PL-03-007 Grassy Creek Ditchline 22+200 22+800 534.8 0.62 1.89 0.00 2.51 Pascopyrum smithii - needle-and-thread - Bouteloua gracilis shrub western wheat herbaceous grass - blue grama shrub herbaceous

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KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Appendix G Rare Plant and Rare Ecological Community Figures January 2019

RARE PLANT AND RARE ECOLOGICAL COMMUNITY FIGURES

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Appendix G Rare Plant and Rare Ecological Community Figures January 2019

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Appendix H Project Specific Mitigation January 2019

PROJECT SPECIFIC MITIGATION

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Appendix H Project Specific Mitigation January 2019

KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Appendix H Project Specific Mitigation January 2019

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KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Appendix I Descriptions of Rare Plant Species within 30 m of the Construction Footprint January 2019

DESCRIPTIONS OF RARE PLANT SPECIES WITHIN 30 M OF THE CONSTRUCTION FOOTPRINT

I.1 SPECIES LIST IN ALPHABETICAL ORDER BY SCIENTIFIC NAME

Alisma gramineum Lej. (narrow-leaved water plantain)

Narrow-leaved water plantain (Alisma gramineum) is a perennial plant with fibrous roots (Moss 1983). This species might be found as erect and emergent on mud flats or it can be submersed with floating leaves, found in brackish waters with high calcium carbonate sediments (The Great Plains Flora Association 1986). It is an obligate wetland plant (USDA, NRCS 2017) and is found in rich hydric sites in British Columbia (E-Flora BC 2018).

Narrow-leaved water plantain (narrow-leaved water plantain has a provincial rank of S3 in both Saskatchewan where it is tracked (SK CDC 2018) and Alberta, where it is not tracked (ACIMS 2018). Nationally it is ranked N4 Apparently Secure occurring in the grassland regions of Alberta, Saskatchewan and Manitoba, and in southern British Columbia (NatureServe 2017). Narrow-leaved water plantain was observed in five wetland locations during Project surveys in Saskatchewan. It was not found in Alberta.

Almutaster pauciflorus (Nutt.) A.&D. Löve (few-flowered aster)

Few-flowered aster (Almutaster pauciflorus [synonym Aster pauciflorus]) has long slender rhizomes with fleshy roots (FNA 1999+). Although some literature describes these perennials as inhabiting only dry or drying and open sites, the few flowered aster has also been found along streams, in ditches, deserts, inland salt marshes and dry grassland areas. The few-flowered aster is expected to prefer alkaline soils and does well in alluvial soils with halophytic vegetation (Moss 1983; FNA 1999+). It is considered a facultative wetland species (usually occurs in wetlands but occasionally found in non-wetlands) (USDA, NRCS 2017).

In both Alberta and Saskatchewan few-flowered aster is ranked S3 tracked (ACIMS 2018, SK CDC 2018). The national rank of this species is N4 Apparently Secure occurring in Canada in the Northeast Territories, Alberta, Saskatchewan and Manitoba (NatureServe 2017). Few flowered aster was found during Project surveys at ten wetland locations in Saskatchewan and ten in Alberta.

Alopecurus carolinianus Walt. (Carolina foxtail)

Carolina foxtail (Alopecurus carolinianus) grows in moist areas, particularly wetlands, as well as old fields, waste areas and roadsides, floodplains, and lower wooded areas (The Great Plains Flora Association 1986, Kershaw et al. 2001). It is common in central and southeastern United States and in the Mississippi Valley. It is at the northern edge of its range in Canada, occurring only in British Columbia, Alberta, and Saskatchewan. It is a facultative wetland species; usually occurring in wetlands, but occasionally found in non-wetlands (USDA, NRCS 2017). In arid areas, it is restricted to ditches and vernal pools (Crins 2017).

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Appendix I Descriptions of Rare Plant Species within 30 m of the Construction Footprint January 2019

Carolina foxtail is an annual grass. Apomixis (the production of seed without the sexual fusion of cells) has been recorded in the Alopecurus genus (Fryxell 1957).

Carolina foxtail is not tracked in Alberta, where is ranked S3 (ACIMS 2018). In Saskatchewan Carolina foxtail is ranked S2 tracked (SK CDC 2018). Nationally this species is considered Vulnerable, N3 (NatureServe 2017).

Carolina foxtail was observed in 88 wetland locations during Project surveys in Saskatchewan. Many of the wetlands where it occurred were heavily grazed. This species was not found in Alberta.

Anagallis minima (L.) Krause (Lysimachia minima) (chaffweed)

Chaffweed (Anagallis minima [synonyms Lysimachia minima and Centunculus minimus]) is a very small annual plant with prostrate or erect stems that root at the nodes. The roots are fibrous or there may be a taproot. This plant commonly grows in moist soils and muddy margins of wetlands, in addition to seasonally flooded lowlands and acidic/damp soils of forests, and is a facultative wetlands species (USDA, NRCS 2017). It flowers May to July and occasionally August, depending on the moisture conditions. (Kershaw et al. 2001; Moss 1983; FNA 1999+). Population densities might fluctuate dramatically with annual precipitation.

In Alberta chaffweed is tracked under the name Lysimachia minima and is ranked S2S3 in the province (ACIMS 2018). In Saskatchewan chaffweed is tracked under the name Anagallis minima and is ranked S3, vulnerable/rare to uncommon (SK CDC 2018). The national rank of this species is N3N4, Vulnerable to Apparently Secure (NatureServe 2017). Chaffweed was observed in six upland locations during Project surveys in Alberta and ten locations in Saskatchewan.

In Alberta three wetlands that support chaffweed will be impacted by project development. Prior to 2017 In Saskatchewan eight wetlands that support chaffweed will be impacted by project development (WSM019, WSM018, WSM016, WSM015, WSM013, WSM010, WSM009, WSM008).

Anthoxanthum monticola (Bigelow) Y. Schouten & Veldkamp (alpine sweet grass)

Alpine sweet grass (Anthoxanthum monticola) is a tufted, sweet-smelling perennial grass with leafy shoots at base. It grows on dry acidic areas often near bedrock outcrops (Kershaw et al. 2001). Alpine sweet grass S3 tracked in Alberta (ACIMS 2018) but does not occur in Saskatchewan. It is considered N5 Secure nationally (NatureServe 2017) and occurs in most provinces in Canada. This species was found at three upland location in Alberta and does not occur in Saskatchewan.

Aristida purpurea var. longiseta (Steud.) Vasey (red three-awn grass)

Red three-awn grass is a tufted perennial grass with fibrous roots. The fruit is mature from August to September (Kershaw et al. 2001). In British Columbia, it has been recorded on xeric soils with medium nutrient regime, and is found on sandy or rocky slopes and plains, and in barren soils of disturbed ground (Barkworth et al. 2007). The long spreading awns allow the seeds to be dispersed by wind and animals

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Appendix I Descriptions of Rare Plant Species within 30 m of the Construction Footprint January 2019

(Barkworth et al. 2007). Propagation by seed has been attempted; however, the long awns present a challenge (Barner 2009).

Red three-awn grass is ranked Critically Imperiled/ Extremely rare S1 tracked in Saskatchewan (SK CDC 2018), and S3 tracked in Alberta (ACIMS 2018). It is considered N4 Apparently Secure nationally (NatureServe 2017). It is at the northern edge of its range in Canada, extending south into northern Mexico (Barkworth et al. 2007). This species was found at one upland location in Saskatchewan and was not found in Alberta.

Astragalus kentrophyta var. kentrophyta A. Gray (spiny milk-vetch)

Spiny milk-vetch (Astragalus kentrophyta var. kentrophyta) is a perennial forb that occurs on eroding sandy soils (Wallis 2001). Spiny milk-vetch grows in association with mycorrhizal bacteria (Kershaw 2001).

Spiny milk-vetch is S2 tracked in both Alberta (ACIMS 2018) and Saskatchewan (SK CDC 2018). This species is Imperiled nationally with a N2 ranking (NatureServe 2017). This species was found at four upland locations in Saskatchewan and was not found in Alberta.

Astragalus purshii var. purshii Dougl. Ex Hook. (Pursh’s milk-vetch)

Pursh’s milk-vetch (Astragalus purshii var. purshii) is a low-lying legume with deep taproots and a distinctively furry seedpod. It is found in dry mixedgrass grasslands and on sand plains. It flowers from April to June however the seed pod is a more distinctive identification feature. Low milk-vetch sometimes produces cleistogamous flowers (small self-fertilized flowers) close to the ground (Kershaw et al. 2001). Details on cleaning and storing seed are available in Barner 2007. It readily colonizes disturbances and mature plants can be prolific seed producers. Many seeds are attacked by insects though (Youtie and Miller 1986).

Pursh’s milk-vetch is ranked S3 in both Alberta, where it is tracked on watch-list (ACIMS 2018), and in Saskatchewan, where it is tracked (SK CDC 2018). Pursh’s milk-vetch is ranked N5 nationally (NatureServe 2017). This species was found at ten upland locations in Saskatchewan and was not found in Alberta.

Astragalus spatulatus E. Sheld. (tufted milk-vetch)

Tufted milk-vetch (Astragalus spatulatus) is a densely tufted perennial plant that typically inhabits open and rocky hilltops and hillsides which commonly have shallow soils (The Great Plains Flora Association 1986).

Tufted milk-vetch is ranked S3 in both Alberta, where it is not tracked (ACIMS 2018), and in Saskatchewan, where it is tracked (SK CDC 2018). Tufted milk-vetch is ranked N3 Vulnerable nationally, occurring in Alberta and Saskatchewan (NatureServe 2017). This species was found at 16 upland locations in Saskatchewan and was not found in Alberta.

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KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Appendix I Descriptions of Rare Plant Species within 30 m of the Construction Footprint January 2019

Atriplex canescens (Pursh) Nutt. (four-wing saltbush)

Four-wing saltbush (Atriplex canescens) is a salt-tolerant woody, perennial herbaceous species that typically inhabits salt flats (Moss 1983). It is ranked S3 Tracked in Alberta (ACIMS 2018) and NU Unknown in Canada (NatureServe 2017). It occurs only in Alberta in Canada but occurs throughout the . This species was found at four upland locations in Alberta and was not found in Saskatchewan.

Bidens frondosa L. (common beggarticks)

Common beggarticks (Bidens frondosa) is an annual facultative wetland forb (USDA, NRCS 2017). It is found in moist ground and ditches (Moss 1983). This species propagates by seeds which are produced in late summer to fall (USDA, NRCS 2017).

Common beggarticks is S3 tracked in both Alberta (ACIMS 2018) and Saskatchewan (SK CDC 2018). Nationally this species is Secure N5 occurring in British Columbia east to Newfoundland (NatureServe 2017). Common beggarticks was found in three wetland locations in Alberta and was not found in Saskatchewan.

Botrychium campestre W. H. Wagner & Farrar (prairie dunewort, field grape fern)

Prairie dunewort (Botrychium campestre) is a very small, fleshy, perennial herb in the fern family, known to occur in sandy exposed grassland or dune habitats (NatureServe 2017). It appears early in the spring in May and early June and reproduces from spore clusters. However, above ground stems of the plant may remain dormant if moisture conditions are not suitable for growth in a particular year.

Prairie dunewort is ranked S3 tracked in Alberta (ACIMS 2018) and S2 tracked in Saskatchewan (SK CDC 2018). Nationally this species is considered Imperiled with a rank of N2 (NatureServe 2017). This species was found at one upland location in Saskatchewan and was not found in Alberta.

Botrychium simplex E. Hitchc. (dwarf grape fern)

Dwarf grape fern (Botrychium simplex) is a small, fleshy, perennial herb in the fern family, which grows in a wide variety of habitats including moist meadows, barrens, along field edges, along edges of wetlands, and woods (Kershaw et al. 2001). It reproduces from spore clusters. However, above ground stems of the plant may remain dormant if moisture conditions are not suitable for growth in a particular year (NatureServe 2017).

Dwarf grape fern is ranked S2 tracked in Alberta (ACIMS 2018) and S2 tracked in Saskatchewan (SK CDC 2018). Nationally this species has a widespread but not abundant occurrence distribution with a rank of N4 nationally in Canada (NatureServe 2017). This species was found at one upland location in Alberta and was not found in Saskatchewan.

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KEYSTONE XL PIPELINE PROJECT RARE PLANTS AND RARE ECOLOGICAL COMMUNITIES (CONDITION 8)

Appendix I Descriptions of Rare Plant Species within 30 m of the Construction Footprint January 2019

Bouteloua curtipendula (Michx.) Torr. (side-oats grama)

Side-oats grama (Bouteloua curtipendula) is a perennial bunchgrass that is found on rocky open slopes, woodlands and forest openings (USDA, NRCS 2017). This grass is sometimes used a component of erosion control seed mixes (USDA, NRCS 2017).

Side-oats grama is ranked S1 tracked in Alberta (ACIMS 2018) and S3 tracked in Saskatchewan (SK CDC 2018). Nationally this species is ranked N3 Vulnerable occurring from Alberta east through to Quebec (NatureServe 2017). This species was found at two upland locations Alberta and was not found in Saskatchewan. The occurrences were found in a reclamation planting on a parallel reclaimed right-of- way.

Cerastium brachypodum (Engelm. Ex. Gray) B.L. Robins (mouse-ear chickweed)

Short-stalk mouse-ear-chickweed (Cerastium brachypodum [synonym Cerastium nutans var. brachypodum]) is a delicate annual herb with shallow taproots. This rare plant is found in open canopy sites in grasslands, meadows, open woods and waste places. It is often found on rocky or sandy soil of wet to dry moisture content (Kershaw et al. 2001). It blooms from April to July. It is considered a facultative upland species, but is occasionally found in wetlands. (USDA, NRCS 2017).

Short-stalk mouse-ear-chickweed is tracked S3 in both Alberta and Saskatchewan (ACIMS 2018, SK CDC 2018), and is consider Apparently Secure, N4, nationally occurring in Alberta, Saskatchewan and Ontario (NatureServe 2017). This species was found at 19 wetland locations in Alberta and was not found in Saskatchewan.

Chenopodium subglabrum (S. Watson) A. Nelson (smooth goosefoot)

Smooth goosefoot (Chenopodium subglabrum) is an annual upland sand dune colonizing herb, occurring in sand or sandy soil on active sand dune complexes which are characterized as being partially stabilized sand dunes (Environment Canada 2015). Reproduction is by seed. Smooth goosefoot is dependent on a moderate level of disturbance to provide early-successional to mid-successional sand dune habitat, however some disturbances can also harm populations, for example indirectly through introduction of invasive species following a disturbance, or directly through direct mortality of plants or seed banks (Environment Canada 2015).

Smooth goosefoot is ranked S2 and tracked in the province of Alberta (ACIMS 2018), and is ranked S3, vulnerable/rare to uncommon, and tracked in the province of Saskatchewan (SK CDC 2018). Nationally smooth goosefoot is designated by Committee on the Status of Endangered Wildlife in Canada (COSEWIC) as Threatened and is SARA-listed as Schedule 1 Threatened. Threats to Canadian populations, which occur in British Columbia, Saskatchewan, Alberta, and Manitoba, include alteration or suppression of natural grazing and fire regimes, invasion of exotic, invasive or introduced species, habitat loss and degradation, and direct disturbance or harm. Critical Habitat was designated for smooth

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Appendix I Descriptions of Rare Plant Species within 30 m of the Construction Footprint January 2019 goosefoot in 2015 (Environment Canada 2015). This species was found at nine upland locations in Saskatchewan and was not found in Alberta.

Chenopodium watsonii A. Nels. (Watson's goosefoot, Dakota stinking goosefoot)

Dakota stinking goosefoot (Chenopodium watsonii) is a foul-smelling annual occurring in badland and open areas (Kershaw 2001). It occurs in silty or clayey soil (SASK Herbarium 2018).

Dakota stinking goosefoot is tracked in both the province of Alberta, S2 (ACIMS 2018) and Saskatchewan, S3 (SK CDC 2018). Nationally this species is Imperiled N2 (NatureServe 2017).

This species was found at four upland locations in Saskatchewan and was not found in Alberta.

Corispermum americanum var. americanum (Nutt.) Nutt, (American bugseed)

American bugseed (Corispermum americanum var. americanum) is an annual herb that flowers in the late summer-fall and occurs on sandy soils of sand dunes, shores, fields and waste places (FNA 1999+). In Saskatchewan plants are locally numerous but restricted in area (SASK Herbarium 2018).

American bugseed is tracked in both Alberta, S2 (ACIMS 2018) and in Saskatchewan S3 (SK CDC 2018). Nationally this species is Apparently Secure with uncertainty N4? (NatureServe 2017). This species was found at two upland locations in Alberta and was not found in Saskatchewan.

Cryptantha celosioides (Eastw.) Payson (clustered oreocarya)

Clustered oreocarya (Cryptantha celosioides [synonyms: Cryptantha nubigena var. celosioides, Cryptantha bradburiana, Oreocarya glomerata, Cryptantha nubigena, and Oreocarya celosioides]) is a biennial (Robson 1997) or short lived perennial (Luna 2008) that inhabits dry grassland sites, including sandy soils and dunes (Moss 1983), and eroding grassland slopes. It is generally not found on saline soils (Robson 1997). It has one large hard seed per flower (nutlets) and a slender rootstock (Currah et al. 1983). It is pollinated by insects, and the seeds have hooked barbs to facilitate distribution by mammals (Robson 1997). Germination after 5 months outdoor cold moist stratification is 50%. Taproot development occurs rapidly following germination (Luna 2008).

Clustered oreocarya is ranked S2 in Saskatchewan (SK CDC 2018) and S2S3 in Alberta (ACIMS 2018). Nationally it is ranked N4 Apparently Secure occurring in both Alberta and Saskatchewan (NatureServe 2017). This species was found at 120 upland locations in Saskatchewan and was not found in Alberta.

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Appendix I Descriptions of Rare Plant Species within 30 m of the Construction Footprint January 2019

Cryptantha kelseyana Greene (Kelsey’s cat’s eye; Kelsey’s cryptantha)

Kelsey’s cat’s eye (Cryptantha kelseyana) is a small, upland annual plant superficially similar to tiny cryptantha (Cryptantha minima) and fendler’s cryptantha (Cryptantha fendleri). All three species are found on dry sandy soils, often where soil is deposited by wind or occasionally in eroded sites. Kelsey’s cat’s eye often germinates along the sides of animal trails and unimproved roads where the soil is loose and competition is low. Construction of the pipeline may provide increased germination sites where windblown soil accumulates on the lee side, provided the seed source is not destroyed.

Kelsey’s cat’s eye Is tracked as S2 in Saskatchewan (SK CDC 2018) and as S3 in Alberta (ACIMS 2018). Nationally this species is considered Imperiled with a rank of N2 (NatureServe 2017). This species was found at four upland locations in Saskatchewan and seven locations in Alberta.

Cryptantha minima (tiny cryptantha)

Tiny cryptantha (Cryptantha minima) is a small annual herb. It is frequently found on eroding sand on sand dunes and valley slopes in sand dune areas (Wallis 2001), however a very high level of disturbance and repeated disturbance may limit tiny cryptantha (Environment Canada 2012b). Confirmed occurrences of tiny cryptantha are found within 5 km of river systems (Environment Canada 2012b).

Tiny cryptantha is Critically Imperiled/ Extremely rare S1 tracked in Saskatchewan (SK CDC 2018) and S2 tracked in Alberta (ACIMS 2018). Nationally it is COSEWIC designated Threatened and is SARA- listed Schedule 1 Threatened. Critical habitat for tiny cryptantha was designated in 2012 (Environment Canada 2012b). Tiny cryptantha has not been observed during Project surveys since 2008 at which time it was observed at 12 locations in Alberta. It has not been found in Saskatchewan.

Danthonia californica var. americana (Scribn.) Hitchc. (California wild oat grass)

California wild oat grass (Danthonia californica var. americana) is a perennial loosely tufted grass with lax stems and fibrous roots. It grows in open grassy meadows (Kershaw et al. 2001). It was found on moist microsites in shallow drainages and depressions on loamy dark brown soils. It flowers in June (July) and the fruit matures late July to September (Kershaw et al. 2001). California wild oat grass is found in Western North America (Barkworth et al. 2007).

California wild oat grass is ranked S3 in both Alberta, where it is not tracked (ACIMS 2018), and in Saskatchewan, where it is tracked (SK CDC 2018). Nationally the species is ranked N5 (NatureServe 2017). This species was found at three upland locations in Saskatchewan and was not found in Alberta.

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Appendix I Descriptions of Rare Plant Species within 30 m of the Construction Footprint January 2019

Danthonia unispicata (Thurb.) Munro ex Macoun (few-flowered oat- grass)

Few-flowered oat-grass (Danthonia unispicata) is a small perennial tufted grass with fibrous roots. few- flowered oat-grass is common throughout the northern plains and western states (Barkworth et al. 2007). It grows in open moist microsites on rocky or sandy ground. It flowers in June (July) and the fruit matures late July to September (Kershaw et al. 2001).

Few-flowered oat-grass is ranked S3 and tracked in Saskatchewan (SK CDC 2018) and not tracked in Alberta (ACIMS 2018). Nationally this species is ranked N4 Apparently Secure (NatureServe 2017). This species was found at three upland locations in Saskatchewan and was not found in Alberta.

Draba reptans (Lam.) Fern. (Carolina whitlow-grass; creeping draba)

Carolina whitlow-grass is a small delicate upland annual forb. It occurs in undulating sand dominated soils, numbering in the tens of thousands of plants in some locations. It is often observed on disturbed or naturally exposed sandy soils (Moss 1983). It is also found in sparsely vegetated, exposed, sandy or gravelly sites especially in naturally disturbed areas, (Kershaw et al 2001). Carolina whitlow-grass grows and blooms in mid-May, setting seed and senescing by mid-June. Following senescence, remnants of the plant are often difficult to observe and in some instances, can no longer be found within the vegetation community.

Carolina whitlow-grass is Critically Imperiled/ Extremely rare S1 tracked in Saskatchewan (SK CDC 2018) and S2 tracked in Alberta (ACIMS 2018). Nationally this species is considered Vulnerable, N3 (NatureServe 2017). This species was found at four upland locations in Saskatchewan and three locations in Alberta.

Epilobium campestre (Jeps.) Hoch & W.L. Wagner (smooth spike-primrose, smooth boisduvalia)

Smooth spike-primrose (Epilobium campestre [synonym Epilobium pygmaeum]) is an annual forb that is a facultative wetland species (USDA, NRCS 2017). In Saskatchewan most local populations are small (SASK Herbarium 2018).

Smooth spike-primrose ranked S3 in both provinces and is tracked (ACIMS 2018, SK CDC 2018). Nationally this species is N2N3 Imperiled to Vulnerable and occurs in British Columbia, Alberta and Saskatchewan (NatureServe 2017). This species was found at one wetland location in Alberta and 11 wetland locations in Saskatchewan.

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Appendix I Descriptions of Rare Plant Species within 30 m of the Construction Footprint January 2019

Eremogone congesta var. lithophila (Rydb.) Dorn (rocky-round sandwort)

Rocky-round sandwort (Eremogone congesta var. lithophila), previously called Arenaria congesta var. lithophila is found on dry plains and slopes in the Cypress Hills and Milk River Ridge in Alberta (Moss 1983). It prefers mid to upper slopes and gravelly soils (Currah et al. 1983).

Rocky-round sandwort is a small, loosely matted plant with a somewhat woody caudex (Moss 1983), and fibrous roots from rhizomes (Currah et al. 1983). Few seeds are produced per plant, but germination is good without treatment, although stratification increases germination.

Effects of small diameter pipeline constructed during frozen ground conditions through a population of rocky ground sandwort in the Cypress Hills were monitored for three years post-construction. Plants persisted and flowered on the unstripped work side and unstripped spoil storage areas. Little re-establishment occurred on the stripped soils of the ditchline (AXYS Environmental Consulting Ltd. et al. 2004).

Rocky-round sandwort is tracked in Saskatchewan and ranked S3 (SK CDC 2018). In Alberta, Eremogone congesta is ranked S3 and is ranked SU at the variety level, neither of which are tracked (ACIMS 2018). Rocky-round sandwort is considered Vulnerable to Apparently Secure N3N4 nationally, occurring in Alberta and Saskatchewan (NatureServe 2017). This species was found at 90 upland locations in Saskatchewan and was not found in Alberta.

Erigeron compositus Pursh (compound fleabane)

Compound fleabane (Erigeron compositus) is a low growing perennial with a stout well-branched taproot. It is found in grasslands on calcareous rocks, sands, and gravels, often on exposed hillsides and badlands. Although rare, this increaser species has a woody taproot and can tolerate trampling by livestock or wildlife and drought (The Great Plains Flora Association 1986; Tannas 2003-2004; Currah et al. 1983). It flowers late May to early June, and the seeds ripen late June to July. Numerous seeds are produced per plant. Vegetation propagation is by woody stem cuttings taken in the spring (Currah et al. 1983). Germination after 60 days of cold moist stratification is 90%. More propagation details are available at Luna, et al. 2008.

Compound fleabane is ranked S3 tracked in Saskatchewan (SK CDC 2018) and S5 not tracked in Alberta (ACIMS 2018). Nationally this species is Secure, N5 (NatureServe 2017). This species was found at 10 upland locations in Saskatchewan and was not found in Alberta.

Erigeron lanatus Hook. (woolly fleabane)

Woolly fleabane (Erigeron lanatus) is a small, densely tufted, tap-rooted mat forming perennial with a single large flower per stem (Kershaw et al. 2001; NatureServe 2017). It grows in open wetlands. Is occurs in Alberta, British Columbia and several western states and is ranked N4 nationally in Canada and

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Appendix I Descriptions of Rare Plant Species within 30 m of the Construction Footprint January 2019 is ranked S3 tracked in Alberta. This species was found at two wetland locations in Alberta and does not occur in Saskatchewan.

Eutrema salsugineum (Pall.) Al-Shehbaz & Warwick (mouse-ear cress)

Mouse-ear cress (Eutrema salsugineum), (synonym: Arabidopsis salsugineum) is a small delicate annual herb in the mustard family. It grows in moist alkaline or saline soils on saline lowlands and around wetlands (FNA 1999+). Mouse-ear cress is dependent on saline habitats (Kershaw et al. 2001). It blooms late April through June (Kershaw et al. 2001). Its distribution includes western Canada, Montana and Colorado.

Mouse-ear cress is tracked in Alberta and ranked S1 (ACIMS 2018). In Saskatchewan mouse-ear cress is ranked S5 and is not tracked (SK CDC 2018). At the national level it is ranked Secure with some uncertainty, N5? (NatureServe 2017),

Several plants were found in a large saline wetland in the Remount Community Pasture along with spatulate-leaved heliotrope (Heliotropium curassavicum, S3, ACIMS 2018), and few-flowered aster (Almutaster pauciflorus, S3, ACIMS 2018). No plants of these species were found directly on the project footprint but occur elsewhere in the wetland. This wetland is immediately adjacent to a slender mouse-ear cress (Transberingia bursifolia ssp. virgata, S2, ACIMS 2018) site.

Juncus confusus Coville (few-flowered rush)

Few-flowered rush (Juncus confusus) a perennial, tufted herb with fibrous roots. Typically, this species inhabits low grasslands, thickets and open woods (Kershaw et al. 2001; FNA 1999+).

Few-flowered rush is tracked in the province of Saskatchewan where it is ranked S2 and considered Imperiled/Very rare (SK CDC 2018). Few-flowered rush is ranked S3 not tracked in Alberta (ACIMS 2018). Nationally this species occurs in British Columbia, Alberta, and Saskatchewan, and is ranked N4 Apparently Secure (NatureServe 2017).

Effects of small diameter pipeline constructed during frozen ground conditions through a population of few-flowered rush in the Cypress Hills were monitored for three years post-construction. Tussocks persisted and recovered on the unstripped work side. Little re-establishment occurred on the stripped soils of the ditchline (AXYS Environmental Consulting Ltd. et al. 2004). This species was found at 20 wetland locations in Saskatchewan and was not found in Alberta.

Juncus interior Wieg. (inland rush)

Inland rush (Juncus interior) is a facultative wetland species (USDA, NRCS 2017). In Canada, this species occurs in British Columbia, Saskatchewan, Manitoba, and Ontario (NatureServe 2017). This perennial graminoid species has densely branching rhizomes and has 1-loculed capsules in a loose panicle (FNA 1999+).

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Appendix I Descriptions of Rare Plant Species within 30 m of the Construction Footprint January 2019

Inland rush is ranked S3 track in Saskatchewan (SK CDC 2018), and its presence in Alberta is uncertain, it is not reported to occur in Alberta according to NatureServe (2017) and ACIMS 2018, but is reported by Flora of North America to occur in Alberta (FNA 1999+). Nationally this species is considered N4N5, Apparently Secure to Secure (NatureServe 2017). This species was found at six wetland locations in Saskatchewan and was not found in Alberta.

Lilaea scilloides (Poir.) Hauman (flowering quillwort)

Flowering quillwort (Lilaea scilloides) is an aquatic annual with tufted leafless stems and slender, short rhizomes. This is a cryptic species which could be mistaken for a wetland grass. It grows in shallow water (sloughs) and adjacent mud flats (FNA 1999+; Moss 1983).

Flowering quillwort is tracked in both Alberta S3 (ACIMS 2018) and in Saskatchewan is Critically Imperiled/ Extremely rare S1 (SK CDC 2018), Nationally it is N2N3 Imperiled to Vulnerable occurring in British Columbia, Alberta and Saskatchewan (NatureServe 2017).

Flowering quillwort was observed during project surveys in one Class 3 wetland (wetland ID-2628 near kp GD 79+600. This species was not found in Alberta.

Lobelia spicata Lam. (spiked lobelia)

Spiked lobelia (Lobelia spicata) is a terrestrial perennial forb found on sandy grassland soil (Kershaw 2001, USDA, NRCS 2017).

Spiked lobelia is S1 tracked in Alberta (ACIMS 2018) and is S4 not tracked in Saskatchewan under the name Lobelia spicata var. hirtella (SK CDC 2018). Nationally this species is Secure with some uncertainty N5? occurring from Nova Scotia west to Alberta (NatureServe 2017). In the United States this species most western most extent is in Montana (USDA, NRCS 2017). This species was found at two upland locations in Alberta and was not found in Saskatchewan.

Lupinus pusillus ssp. pusillus Pursh (small lupine, annual lupine)

Small lupine or annual lupine (Lupinus pusillus ssp. pusillus) is an annual forb. It is found in the grasslands from Alberta and Saskatchewan to Arizona and New Mexico (NatureServe 2017). Typically, the best habitat for small lupine is in sandy soils of the grasslands, including dunes, stream valleys, badlands and roadsides (The Great Plains Flora Association 1986; Moss 1983). This species is an grazing increaser and therefore is often found in areas of heavy grazing, although good condition rangelands can also support high populations of this plant (Tannas 2003-2004). It is widespread through the Saskatchewan grasslands.

Small lupine is tracked in Saskatchewan where it is ranked S3 (SK CDC 2018). This species is ranked S3 not tracked in Alberta (ACIMS 2018). Nationally this species is ranked Vulnerable to Apparently Secure, N3N4 (NatureServe 2017). This species was found at 15 upland locations in Saskatchewan and was not found in Alberta.

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Appendix I Descriptions of Rare Plant Species within 30 m of the Construction Footprint January 2019

Lycopus americanus Muhl. Ex. W.P.C. Bartram (American water- horehound)

American water-horehound (Lycopus americanus) is a perennial herb that is a wetland obligate, found in marshes and along streams (Kershaw 2001, USDA, NRCS 2017), This species of the mint family flowers June to August (Kershaw 2001). American water-horehound propagates by seed or by tubers (USDA, NRCS 2017).

American water-horehound is tracked on a watch-list in Alberta S3 (ACIMS 2018) and is not tracked S4 in Saskatchewan (SK CDC 2018). Nationally this species is secure N5 occurring in Canada from British Columbia east through to Newfoundland (NatureServe 2017). This species was found at three wetland locations in Alberta and was not found in Saskatchewan.

Lysimachia hybrida Michx. (lance-leaved loosestrife)

Lance-leaved loosestrife (Lysimachia hybrida) is found on mesic to moist soils of woodlands, meadows, shrub thickets and wetland shores (Kershaw et al. 2001). It is considered an obligate wetland species (USDA, NRCS 2017), but is not tolerant of saline or alkaline conditions. This perennial reproduces primarily by seed and by short rhizomes. The seedlings are reported to have low vigor. The pH range is 5-7 (USDA, NRCS 2017).

Lance-leaved loosestrife is tracked in Alberta, S3 (ACIMS 2018) and is ranked S5 not tracked in Saskatchewan (SK CDC 2018). Nationally it is N5?, Secure with some uncertainty (NatureServe 2017). This species was found at 27 wetland locations in Alberta and was not found in Saskatchewan.

Marsilea vestita Hook. & Grev. (hairy pepperwort)

Hairy pepperwort is a perennial obligate wetland species (USDA, NRCS 2017). Plants form clones in ponds, wetlands and on floodplains and is adapted to fluctuating water levels (FNA 1999+, Hamel et al. 2001). Reproduction is by spores and vegetatively through slender rhizomes. This plant is tolerant of alkaline conditions (Hamel et al. 2001).

Hairy pepperwort is S3 tracked in both Alberta and Saskatchewan (ACIMS 2018, SK CDC 2018). Nationally this species is Imperiled to Vulnerable, N2N3 (NatureServe 2017). This species was found at one wetland location in Alberta and was not found in Saskatchewan.

Mentzelia decapetala (Pursh ex Sims) Urban & Gilg ex Gilg (eveningstar)

Eveningstar is a biennial or perennial forb that reproduces via seeds (USDA, NRCS 2017). It grows in coarse to medium textured soils and has a high drought tolerance (USDA, NRCS 2017).

Eveningstar is S3 tracked in Saskatchewan (SK CDC 2018) and S3 not tracked in Alberta (ACIMS 2018). Nationally it is ranked N4? Apparently Secure with some uncertainty occurring in Alberta, Saskatchewan

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Appendix I Descriptions of Rare Plant Species within 30 m of the Construction Footprint January 2019 and possibly Manitoba (NatureServe 2017). This species was found at two upland locations in Saskatchewan and was not found in Alberta.

Mirabilis linearis (Pursh) Heimeri (narrowleaf umbrella-wort)

Narrowleaf umbrella-wort is a perennial herb (USDA, NRCS 2017). This species is at its northern edge of its range in Alberta and Saskatchewan (FNA 1999+).

Narrowleaf umbrella-wort is S2 tracked in Alberta (ACIMS 2018) and S3 tracked in Saskatchewan (SK CDC 2018). This species is considered Vulnerable N3 nationally (NatureServe 2017) and occurs in Alberta, Saskatchewan and Manitoba (FNA 1999+). This species was found at 22 upland locations in Saskatchewan and 19 locations in Alberta.

Muhlenbergia asperifolia (Nees & Meyen ex Trin.) Parodi (scratch grass)

Muhlenbergia asperifolia is a perennial wetland grass which reproduces by rhizomes. It prefers low areas with moist soils and wetlands in the Central Parkland subregion in Alberta. It is a facultative wetland species, and is often found in alkaline meadows or around seeps and hot springs. The caryopses (seeds) are frequently infected by a smut (Tilletia asperifolia). Muhlenbergia asperifolia is a warm season grass, growing more rapidly during the warmest part of the summer (The Great Plains Flora Association 1986; Kershaw et al. 2001; USDA, NRCS 2017; Barkworth et al. 2007). It is adapted to fine and medium textured soils, has high tolerance for calcium carbonate (CaCO3) and salinity, and has a low drought tolerance (USDA, NRCS 2017).

Scratch grass it is ranked S3 on the watch-list in Alberta (ACIMS 2018), and S4, not tracked in Saskatchewan (SK CDC 2018). It is considered N5 Secure nationally (NatureServe 2017). This species was found at five wetland locations in Alberta and was not found in Saskatchewan.

Munroa squarrosa (Nutt.) Torr. (false buffalo grass)

False buffalo grass is a prostrate annual grass with slender stolons (a trailing branch which produces new plants from buds at its tips). It grows in dry open areas, often in sandy soil or disturbed sites, and may be found adjacent to little-used gravel roads. It is a C4 grass (warm season grass), growing more rapidly during the warmest part of the summer. It needs bare ground, high light levels and high temperatures, and is tolerant of compaction. There are only five species of Munroa, four of which occur only in South America (Barkworth 2007; Robson 1997).

False buffalo grass is ranked Critically Imperiled/ Extremely rare S1 tracked in Saskatchewan (SK CDC 2018) and S3 tracked in Alberta (ACIMS 2018). Nationally this grass occurs only in Alberta and Saskatchewan and is ranked N2 Imperiled (NatureServe 2017). This species was found at one upland locations in Alberta in the Project construction footprint and an additional nine sites more than 30 m from the Project construction footprint. It was not found in Saskatchewan.

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Appendix I Descriptions of Rare Plant Species within 30 m of the Construction Footprint January 2019

Myosurus apetalus var. borealis Whittemore (awned mousetail) and Myosurus apetalus var. montanus (bristly mousetail)

Awned mousetail (Myosurus apetalus) consists of two varieties, awned mousetail (var. borealis) and bristly mousetail (var. montanus). Both mousetail varieties are annual obligate or facultative wetland species (USDA, NRCS 2017), and are typically found in mud-flats and moist depressions in Alberta, and in vernally moist meadows, streambanks and pools elsewhere (E-Flora BC 2018). Mousetail populations appear to fluctuate with moisture levels (Robson 1997). They colonize soils exposed by cattle trampling or receding seasonal water, occurring in ephemeral wetlands or the muddy edges of deeper wetlands.

This species is tracked at the variety level in both provinces. Both varieties are ranked S2 tracked in Saskatchewan (SK CDC 2018) and both varieties are ranked S1S2 tracked in Alberta (ACIMS 2018). Nationally bristly mousetail is ranked Apparently Secure (N4), while awned mousetail is unranked, NNR (NatureServe). Bristly mousetail was found at 22 wetland locations in Saskatchewan and was not found in Alberta. Awned mousetail was found at eight wetland locations in Saskatchewan and was not found in Alberta.

Myosurus minimus (L.) (least mousetail)

Like awned and bristly mousetail, least mousetail (Myosurus minimus) is also an obligate to facultative wetland species (USDA, NRCS 2017), is are typically found in mud-flats and moist depressions in Alberta, and in vernally moist meadows, streambanks and pools elsewhere (E-Flora BC 2018). Least mousetail is an annual with populations that appear to fluctuate with moisture levels (Robson 1997). It’s life cycle and habitat characteristics are the same as those for awned and bristly mousetail. Least mousetail seeds will only germinate in cool temperatures (Bartow 2005).

Least mousetail is ranked S3 in Saskatchewan (SK CDC 2018) and S3 not tracked in Alberta (ACIMS 2018). Occurring in British Columbia through to Quebec this species is ranked N4 Apparently Secure in Canada (NatureServe 2017). This species was found at 63 wetland locations in Saskatchewan and one in Alberta.

Navarretia saximontana S.C. Spencer (Rocky Mountain pincushion plant)

Rocky Mountain pincushion (Navarretia saximontana) plant is an annual, facultative wetland plant. Typically, this plant inhabits sandy soils of moist areas of the plains, including some wetlands, bottom lands and slough margins (Moss 1983). It is found in ephemeral wetlands in dry grasslands.

Rocky Mountain pincushion plant is ranked S3 tracked in Saskatchewan (SK CDC 2018). Previously tracked under the name Navarretia leucocephala in Saskatchewan (SK CDC 2010), which is the name still used in Alberta where the plant is S3 not tracked (ACIMS 2018). Nationally Navarretia saximontana is unranked, NNR (NatureServe 2017). This species was found at 26 wetland locations in Saskatchewan and was not found in Alberta.

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Appendix I Descriptions of Rare Plant Species within 30 m of the Construction Footprint January 2019

Oenothera caespitosa ssp. caespitosa Nutt. (gumbo evening primrose)

Gumbo evening primrose (Oenothera caespitosa ssp. caespitosa) It is a short-lived perennial that inhabits eroding dry, rocky and gravelly hillsides, talus slopes, banks and clay road cuts, clay flats or open woodlands. It inhabits eroding dry, rocky and gravelly hillsides, talus slopes, banks and clay road cuts, clay flats or open woodlands (The Great Plains Flora Association 1986; Tannas 2003-2004; Moss 1983). It is adapted to medium and coarse textured soil, tolerant of calcium carbonate soils (CaC03) and drought, and moderately tolerant of saline soil (USDA, NRCS 2017). It is readily grown from seeds, with 3 months stratification (Luna 2007). Germination is 60% after cold moist stratification. One year container growth is sufficient for outplanting. More propagation information is available at Wick et al. 2004). Gumbo evening primrose can reproduce by its lateral roots which form new shoots and the growth rate is rapid. Gumbo evening primrose is a showy plant and hence has been cultivated.

Gumbo evening primrose is ranked S3, tracked, in Saskatchewan (SK CDC 2018) and in S4 not tracked in Alberta (ACIMS 2018). It is nationally considered N3N4, Vulnerable to Apparently Secure (NatureServe 2017). This species was found at eight upland locations in Saskatchewan and was not found in Alberta.

Oenothera flava ssp. flava (A. Nelson) Garrett (low yellow evening- primrose)

Low yellow evening-primrose (Oenothera flava ssp. flava) is a perennial forb occurring on clay flats (Moss 1983). It is also found along edges of sandy, gravelly wetlands and occasionally occurs on gravelly moist disturbances (Wallis 2001).

This species is S3 tracked in both Saskatchewan (SK CDC 2018) and Alberta (ACIMS 2018). Nationally this species occurs in Alberta and Saskatchewan and is ranked N3 Vulnerable (NatureServe 2017). This species was found at three upland locations in Saskatchewan and was not found in Alberta.

Oenothera serrulata Nutt. (shrubby evening-primrose)

Shrubby evening-primrose (Oenothera serrulata) is an erect, perennial sub-shrub or forb (Kershaw et al. 2001). It occurs in a variety of habitats including sandy grasslands and dunes; moist depressions in grasslands, gravel flats, and dry fields (Kershaw et al. 2001).

This species is S3 tracked in Alberta (ACIMS 2018) and S5 do not track in Saskatchewan (SK CDC 2018). Nationally this species is ranked N5 and occurs in in Alberta, Saskatchewan, Manitoba, and Ontario (NatureServe 2017). This species was found at two upland locations in Alberta and was not found in Saskatchewan.

Orobanche ludoviciana Nutt. (Louisiana broom-rape)

Louisiana Broom-rape (Orobanche ludoviciana) is an annual forb that is parasitic on Artemisia and other sunflower family plants (Moss 1983). It is found in grassland habitats (Moss 1983).

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Appendix I Descriptions of Rare Plant Species within 30 m of the Construction Footprint January 2019

Louisiana Broom-rape is tracked in Saskatchewan where it is ranked S3 (SK CDC 2018) and is ranked S3 not tracked in Alberta (ACIMS 2018). Nationally it is ranked N3 Vulnerable, occurring in British Columbia, Alberta, Saskatchewan and Manitoba (NatureServe 2017).

This species was found at 119 upland locations in Saskatchewan often on previously disturbed pipeline RoW, suggesting an adaptation to disturbance. This species was not found in Alberta.

Parietaria pensylvanica Muhl. ex Willd. (American pellitory)

American pellitory (Parietaria pensylvanica) is an annual forb that is found in wooded areas, banks, brushy and rocky places generally in shaded areas (Moss 1983). It may have male, female, or perfect (male and female) flowers on one plant (The Great Plains Flora Association 1986). It is a facultative upland species, but is occasionally found in wetlands (USDA, NRCS 2017). American pellitory is restricted to a distinct and small habitat in a large area of the province. Maps in Kershaw et al. (2001) show this species is restricted to the Grassland Natural Region.

American pellitory is tracked in Alberta on a watch-list with ranking of S3 (ACIMS 2018). In Saskatchewan, this species is not tracked and is considered S4 (SK CDC 2018). American pellitory is ranked nationally as S5 secure (NatureServe 2017). This species was found at four upland locations in Alberta and was not found in Saskatchewan.

Paronychia sessiliflora Nutt. (low whitlowwort)

Low whitlowwort (Paronychia sessiliflora) is a perennial plant (USDA, NRCS 2017). This plant forms mats on dry stony hillsides and summits (FNA 1999+).

Low whitlowwort is tracked as S3 in Saskatchewan (SK CDC 2018) and is not tracked S3 in Alberta (ACIMS 2018). Nationally it is ranked N5 Secure occurring in Alberta and Saskatchewan (NatureServe 2017). This species was found at six upland locations in Saskatchewan and was not found in Alberta.

Perideridia gairdneri ssp. borealis Chuang & Constance (northern Gairdner’s squawroot; common yampah)

Northern Gairdner's squawroot or common yampah (Perideridia gairdneri ssp. borealis) is a perennial forb in the carrot family (USDA, NRCS 2017). It occurs in moist woods and hillsides in grasslands (Tannas 2003-2004). This species is propagated by seed following mid spring blooming period (USDA, NRCS 2017).

Common yampah is Critically Imperiled/ Extremely rare S1 tracked in Saskatchewan (SK CDC 2018) and is S3 not tracked in Alberta (ACIMS 2018). Nationally this species is Vulnerable to Apparently Secure, N3N4, occurring in British Columbia, Alberta and Saskatchewan (NatureServe 2017). This species was found at four upland locations in Saskatchewan and was not found in Alberta.

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Appendix I Descriptions of Rare Plant Species within 30 m of the Construction Footprint January 2019

Physaria spatulata (Rydb.) Grady & O'Kane (spatulate bladderpod)

Spatulate bladderpod (Physaria spatulata) previously known as Lesquerella alpina var. spathulata in Alberta and Lesquerella alpina var. spathulata or Lesquerella spathulata in Saskatchewan. It occurs on dry plains in the southern portions of both provinces (Moss 1983). It is a tufted, taprooted perennial and may occur with a form that is erect, spreading or prostrate. It can be grown from seed, with seed germinating at room temperature.

Spatulate bladderpod is tracked in both the province of Alberta, S2S3 (ACIMS 2018) and Saskatchewan S3, Vulnerable/Rare to uncommon (SK CDC 2018). Nationally this species is ranked N3, Vulnerable (NatureServe 2017). This species was found at ten upland locations in Saskatchewan and was not found in Alberta.

Plantago patagonica var. spinulosa (Decne.) A. Gray (spinulose plantain)

Spinulose plantain (Plantago patagonica var. spinulosa) is an annual, winter annual, biennial or short- lived perennial. It is found in grasslands on dry, sandy and/or rocky plains, hillsides, badlands, roads and waste areas (The Great Plains Flora Association 1986). In Alberta it is confined to the Dry Mixedgrass Natural Subregion (Moss 1983). Germination is in the fall without low temperature treatment (Tolstead 1941 in Redente et al 1982), however the research was based in Nebraska and may not be applicable to Saskatchewan. Spinulose plantain is adapted to fine to coarse textured soil. It is drought tolerant, moderately tolerant to calcium carbonate soils (CaCO3), intolerant to shade, and with low tolerance for salinity. It is best propagated by seed, and does not require stratification. Seedling vigor is medium and the seed spread rate is slow (USDA, NRCS 2017). Plantago patagonica established well when seeded on a pipeline in the Okanogan (Atwood 2000). Spinulose plantain is disturbance adapted. It was observed in numerous locations in the Great Sand Hills near Crane Lake, growing at the edge of ungraded grassland trails. It was also common and widely distributed in a crested wheatgrass pasture on brown sandy chernozemic soils SE of Crane Lake (Kestrel Research Inc. 2008).

Spinulose plantain is not tracked in Alberta where it is considered to be S5 (ACIMS 2018). In Saskatchewan Harms (2006) recognizes two varieties: var. patagonica which is common, and var. spinulosa which he considers threatened however neither NatureServe (2017) nor ITIS (2017) recognizes any varieties. According to the SK CDC (2017) Plantago patagonica var. spinulosa is tracked S2, while Plantago patagonica var. patagonica is ranked S4, not tracked. Nationally Spinulose plantain is considered secure, N4 (NatureServe 2017). This species was found at one upland location in Saskatchewan and was not found in Alberta.

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Appendix I Descriptions of Rare Plant Species within 30 m of the Construction Footprint January 2019

Potentilla lasiodonta Rydberg (sandhills cinquefoil)

Sandhills cinquefoil (Potentilla lasiodonta [synonym Potentilla finitima]) is a perennial forb found in low mesic depressions in sandy grassland, hills and dunes (Moss 1983). Sandhills cinquefoil is prone to rust diseases. However, sandhills cinquefoil successfully colonizes disturbances from the seedbank (AXYS Environmental Consulting Ltd. 2006). On the Amoco pipeline, many more plants were observed post- construction in disturbed sandy soils than prior to construction (Kestrel Research Inc. 1999).

Sandhills cinquefoil is tracked in both Alberta S3 (ACIMS 2018) and Saskatchewan S2 (SK CDC 2018). Nationally this species is Vulnerable N3 (NatureServe 2017). This species was found at 84 upland locations in Alberta and 64 in Saskatchewan.

Potentilla plattensis Nutt. (low cinquefoil)

Low cinquefoil (Potentilla plattensis) is found in meadows and hillsides ranging from moist to dry soils (The Great Plains Flora Association 1986), and in coulees and dry flats in grasslands (Kershaw et al. 2001). It usually occurs in wetlands in the northern plains (facultative wetland) (USDA, NRCS 2017). Low cinquefoil is a short-lived perennial with a woody root crown and taproot. It prefers medium textured soils, is intolerant of saline conditions or drought, has low tolerance for calcium carbonate (CaCO3) and is somewhat shade tolerant. It can be propagated by bare root and seed, but the seed spread rate and seedling vigor is low. It can be propagated by bare root but otherwise does not spread vegetatively (USDA, NRCS 2017).

Low cinquefoil is S2 tracked in Alberta (ACIMS 2018) and is S4 not tracked in Saskatchewan (SK CDC 2018). Nationally this species is apparently secure N4 (NatureServe 2017).

Potentilla supina ssp. paradoxa Nutt. (bushy cinquefoil)

Bushy cinquefoil (Potentilla supina ssp. paradoxa) is an annual, biennial, or short lived perennial. It is found in open areas, on moist or wet sandy soils of grasslands, bottoms, river banks, low fields, sand bars, and lake shores.

In Alberta, bushy cinquefoil is ranked S3 and tracked on a watch-list (ACIMS 2018), In Saskatchewan the same plant is tracked by the name Potentilla supina ssp. paradoxa and is considered to be Vulnerable/Rare to uncommon, S3 tracked (SK CDC 2018). Nationally it is ranked N4N5 Apparently Secure to Secure nationally, occurring in British Columbia east through to Ontario (NatureServe 2017). This species was found at one wetland location in Saskatchewan and was not found in Alberta.

Ranunculus cardiophyllus Hook. (heart-leaved buttercup)

Heart-leaved buttercup (Ranunculus cardiophyllus) is a perennial which typically inhabits moist areas including meadows, open woods and seepage areas (The Great Plains Flora Association 1986; Moss 1983). It is a facultative wetland species (usually occurring in wetlands but occasionally occurring in upland habitats) USDA, NRCS 2017). No information on propagation was found, but it is assumed that a perennial species with thick roots may be slow to propagate.

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Heart-leaved buttercup is ranked S2 tracked in Saskatchewan (SK CDC 2018). It is ranked S4 and is not tracked in Alberta (ACIMS 2018). Nationally it is considered Secure with a N5 ranking (NatureServe 2017).

Heart-leaved buttercup was observed at two sites near Bone Creek during project field surveys, one in a wetland and the other in a mesic grassland area dominated by Hooker’s oat-grass north of a wetland.

Ruppia maritima L. (beaked ditch-grass)

Beaked ditch-grass (Ruppia maritima) is a submerged aquatic plant with medium salinity tolerance (USDA, NRCS 2017). Reproduction is by seeds produced in spring-summer, and by bare root or sprig propagation (USDA, NRCS 2017).

Beaked ditch-grass is ranked S3 tracked in Saskatchewan (SK CDC 2018), it does not occur in Alberta (ACIMS 2018, NatureServe 2017). Occurring in the provinces of British Columbia, Saskatchewan, Ontario east to Newfoundland, beaked ditch-grass is considered Secure N5 (NatureServe2017). This species was found at one wetland location in Saskatchewan and was not found in Alberta.

Schedonnardus paniculatus (Nutt.) Trel. (tumble grass)

Tumble grass (Schedonnardus paniculatus [synonym Muhlenbergia paniculata]) is an upland perennial grass of dry grassland habitats (USDA, NRCS 2017). It is a grazing increaser and often naturally colonizes disturbed sites, however it is not easily propagated due to low seed fertility (Tannas 2003-2004).

Tumble grass is tracked in both Alberta, where it is ranked S2 (ACIMS 2018), and in Saskatchewan, where it is ranked S3 (SK CDC 2018). Nationally tumble grass is considered Vulnerable N3 and occurs natively in Alberta, Saskatchewan and Manitoba (NatureServe 2017). This species was found at 12 upland locations in Saskatchewan and seven upland locations in Alberta.

Scirpus nevadensis S. Watson (Nevada bulrush)

Nevada bulrush (Scirpus nevadensis) is a perennial rhizomatous graminoid species occurring in wet alkaline soils (Moss 19830). This species is an obligate wetland species (USDA, NRCS 2017).

Nevada bulrush is tracked in Saskatchewan where it is ranked S3 (SK CDC 2018). In Alberta Nevada Bulrush is ranked S3 under the name Amphiscirpus nevadensis and is not tracked (ACIMS 2018). In Canada, this species occurs from British Columbia east to Manitoba and is considered N3N4 nationally (NatureServe 2017). This species was found at four wetland locations in Saskatchewan and was not found in Alberta.

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Sedum lanceolatum ssp. lanceolatum Torr. (lance-leaved stonecrop)

Lance-leaved stonecrop (Sedum lanceolatum ssp. lanceolatum) is most commonly found in open, exposed areas that are rocky or otherwise in areas overlaying bedrock with thin soil cover (The Great Plains Flora Association 1986), in the mountains and in the Cypress Hills (Moss 1983). In Saskatchewan it is found on moist, northwest or west-facing coulee slopes with a diverse selection of graminoids and forbs. It is a succulent perennial with Crassulacean Acid Metabolism, a photosynthetic pathway common in plants adapted to arid conditions. It is pollinated by insects (Robson 1997). Sedums are commonly cultivated for gardens by cuttings or seeds, and detailed instructions are available at Wick et al. (2008).

Lance-leaved stonecrop in Saskatchewan is ranked S3 tracked (SK CDC 2018), It is ranked S4 not tracked in Alberta (ACIMS 2018). Nationally this species is considered Secure, N5 (NatureServe 2017). This species was found at eight upland locations in Saskatchewan and was not found in Alberta.

Sisyrinchium septentrionale Bickn. (pale blue-eyed grass)

Pale blue-eyed grass (Sisyrinchium septentrionale) is a tufted perennial, with fibrous roots and rhizomes (Kershaw et al. 2001). Pale blue-eyed grass grows in mesic to dry soils, often associated with meadows and stream banks, often in gravelly soil (Kershaw et al. 2001; Moss 1983; FNA 1999+). It is a tufted perennial, with fibrous roots and rhizomes (Kershaw et al. 2001).

Pale blue-eyed grass is tracked in Saskatchewan where it is ranked S3 (SK CDC 2018), it is no longer on the watch-list in Alberta and is now S4, not tracked (ACIMS 2018). Nationally this species is considered Apparently Secure, N4, occurring in British Columbia, Alberta, and Saskatchewan (NatureServe 2017). This species was found at three upland locations in Saskatchewan and was not tracked in Alberta.

Solidago mollis Bartl. (velvety goldenrod)

Velvety goldenrod (Solidago mollis) is a perennial that inhabits a wide range of conditions in the Grassland and Parkland Natural Regions. It is found in open woods, in mesic sites in dry grassland, in fence rows, and roadsides (The Great Plains Flora Association 1986; Moss 1983). Germination was 95% after 30 days of stratification, and two-year-old seed is still viable (Redente et al. 1982).

Velvety goldenrod is tracked on a watch-list in Alberta with an S3 ranking (ACIMS 2018). In Saskatchewan, this species is ranked S4 and is not tracked (SK CDC 2018). Nationally this species is Secure N5 with Canadian distribution in Alberta, Saskatchewan and Manitoba (NatureServe 2017). This species was found at nine upland locations in Alberta and was not found in Saskatchewan.

Symphyotrichum ascendens (Lindl.) Nesom (western aster)

Western aster (Symphyotrichum ascendens [synonym Aster ascendens]) is as perennial grassland forb (USDA, NRCS 2017). Reproduction is via seeds of sprigging with rhizomes (USDA, NRCS 2017).

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Appendix I Descriptions of Rare Plant Species within 30 m of the Construction Footprint January 2019

Western aster is tracked in Saskatchewan where it is ranked S3 (SK CDC 2018) and not tracked S3 in Alberta (ACIMS 2018). Occurring in British Columbia, Alberta and Saskatchewan this species is ranked N3 nationally (NatureServe 2017). This species was found at two wetland locations in Saskatchewan and was not found in Alberta.

Townsendia hookeri Beaman (Hooker’s townsendia)

Hooker’s townsendia (Townsendia hookeri) is a perennial forb occurring on gravelly benches and dry sandy slopes (FNA 1999+, SASK Herbarium 2018). This species flowers March to June (FNA 1999+). This species reproduces both asexually and sexually, with flowering time of March to June across North America (USDA, NRCS 2017). While some populations reproduce primarily through asexual means (Thompson et al. 2008).

Hooker’s townsendia is Critically Imperiled/ Extremely rare S1 tracked in Saskatchewan (SK CDC 2018). It is not tracked and is ranked S3 in Alberta (ACIMS 2018). Nationally this species occurs in Yukon, British Columbia, Alberta and Saskatchewan and is considered Vulnerable N3 (NatureServe 2017). This species was found in Saskatchewan in a disturbed area, cleared of sheep fescue (Festuca trachyphylla) in the Frenchman river valley suggesting a species tolerance to disturbance. This species was found at 25 upland locations in Saskatchewan and was not found in Alberta.

Transberingia bursifolia ssp. virgata (Nutt.) Al-Shehbaz & O'Kane (slender mouse-ear-cress)

Slender mouse-ear-cress (Transberingia bursifolia ssp. virgata [synonym Halimolobos virgata]) is a biannual sometime perennial found on grassland uplands and undulating terrain. Slender mouse-ear- cress typically grows in low depressions, low sand dune edge or at slope bases (Environment Canada 2012a). A study by Low (2016) suggests this species shows some level of resilience to pipeline disturbances and suggests that this species may not strictly require a 300 m setback when proper mitigations are used.

In Alberta, slender mouse-ear cress is S2 tracked (ACIMS 2018) and S1 tracked in Saskatchewan (SK CDC 2018). Nationally this species occurs only in Albert and Saskatchewan and is COSEWIC designated Threatened and is SARA-listed Schedule 1 Threatened. Threats to populations include land use changes including habitat loss or habitat change through changes to fire, grazing regimes or hydrology. Invasive alien species, and climate change are additional threats (Environment Canada 2012a). Critical habitat was designated for slender mouse-ear-cress in 2012 (Environment Canada 2012a). This species was found at 52 upland locations in Saskatchewan and was not found in Alberta.

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Appendix I Descriptions of Rare Plant Species within 30 m of the Construction Footprint January 2019

Veronica serpyllifolia L. ssp. humifusa (Dicks.) Syme (northern thyme-leaved speedwell)

Northern thyme-leaved speedwell (Veronica serpyllifolia ssp. humifusa) is a creeping perennial herbaceous species that grows in marsh wetlands. In Alberta, northern thyme-leaved speedwell is listed as S3 do not track (ACIMS 2018) and S1 tracked in Saskatchewan (SK CDC 2018). Nationally this species occurs in all provinces of Canada except Manitoba. This species was found at one wetland location in Saskatchewan and was not found in Alberta.

Vulpia octoflora (Walt.) Rydb. (six-week fescue)

Six-weeks fescue (Vulpia octoflora) is an upland graminoid species that grows on dry, eroded sandy sites including stabilized sand dunes (SASK Herbarium 2018). Six-weeks fescue is ranked S3 tracked in Saskatchewan (SK CDC 2018) and S3 not tracked in Alberta (ACIMS 2018). Nationally this species occurs from British Columbia through to Ontario and is ranked Apparently Secure to Secure, N4N5 (NatureServe 2017). This species was found at two upland locations in Saskatchewan and was not found in Alberta.

I.2 SPECIES DESCRIPTIONS REFERENCES

Literature Cited

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AXYS Environmental Consulting Ltd. 2006. North Suffield Pipeline Project (National Energy Board Approval Order GH-2-2000) Final Post-Construction Environmental Monitoring Report 2006: Results of Five Years of Monitoring to Evaluate the Success of Rare Plant Mitigation Measures. Prepared for: AltaGas Ltd.

AXYS Environmental Consulting Ltd. In association with: Gramineae Services Ltd. and Kestrel Research Inc. 2004. Merry Flats Drilling Program Rare Plant Monitoring Report. Prepared for EnCana Oil and Gas Co. Ltd. POG609. pp. 48.

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Barkworth, M.E., L.K. Anderton, K.M. Capels, S. Long and M.B. Piep. 2007. Manual of Grasses for North America. Intermountain Herbarium and Utah State University Press, Logan UT. Available at: https://muse.jhu.edu/book/9406. Accessed February 2018.

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Barner, J. 2009. Propagation protocol for production of Aristida purpurea Nutt. longiseta (Steud.) Vasey seeds; USDA FS - R6 Bend Seed Extractory, Bend, Oregon. In: Native Plant Network. Moscow (ID): University of Idaho, College of Natural Resources, Forest Research Nursery. Available at: https://rngr.net/renderNPNProtocolDetails?selectedProtocolIds=-aristida-3762. Accessed February 2018.

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Environment Canada. 2012a. Recovery Strategy for the Slender Mouse-ear-cress (Halimolobos virgata) in Canada. Species at Risk Act Recovery Strategy Series. Environment Canada, Ottawa. v + 45 pp. Available at: https://www.registrelep- sararegistry.gc.ca/virtual_sara/files/plans/rs_slender_mouse_ear_cress_e.pdf. Accessed February 2018.

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Appendix I Descriptions of Rare Plant Species within 30 m of the Construction Footprint January 2019

Environment Canada. 2012b. Amended Recovery Strategy for the Tiny Cryptantha (Cryptantha minima) in Canada. Species at Risk Act Recovery Strategy Series. Environment Canada, Ottawa. vii + 38 pp. Available at: http://www.registrelep- sararegistry.gc.ca/virtual_sara/files/plans/amended_rs_tiny_cryptantha_final_e.pdf. Accessed February 2018.

Environment Canada. 2015. Recovery Strategy for the Smooth Goosefoot (Chenopodium subglabrum) in Canada. Species at Risk Act Recovery Strategy Series. Environment Canada, Ottawa. Vii + 50 pp. Available at: http://publications.gc.ca/collections/collection_2016/eccc/En3-4-213-2015- eng.pdf. Accessed February 2018.

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Great Plains Flora Association. 1986. Flora of the Great Plains. University of Kansas Press, Lawrence, Kansas. 1402 pp.

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Harms, V.L. 2006. Annotated Catalogue of Saskatchewan Vascular Plants. Published by Vernon Harms, Saskatoon SK. Available at: http://www.biodiversity.sk.ca/Docs/AnnotatedCatalogueSKVascPlants2006.pdf. Accessed February 2018.

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Kershaw, L, J. Gould, D. Johnson, J. Lancaster. 2001. Rare Vascular Plants of Alberta. Univ. Alberta Press, Edmonton, Alberta and Nat. Resour. Can., Can. For. Serv., North. For. Cent., Edmonton, Alberta.

Kestrel Research Inc. 1999. Rare and Endangered Plant Mitigation Monitoring Conducted on the Amoco Canada Petroleum Company Ltd. Empress to Kerrobert Pipeline Expansion Project. Prepared for Amoco Canada Petroleum Company Ltd. Kestrel Research Inc. 2008. Petro-Canada Crane Lake 16 Well 2008 Drilling Program: Environmental Protection Plan. Prepared for: Petro-Canada Oil and Gas, 150 6th Avenue S.W., Calgary, Alberta, T2P 3E3

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Appendix I Descriptions of Rare Plant Species within 30 m of the Construction Footprint January 2019

Luna, T. 2008. Propagation protocol for production of container Cryptantha celosioides (Eastw. ) Pays. plants (172 ml containers); USDI NPS - Glacier National Park, West Glacier, Montana. In: Native Plant Network. Moscow (ID): University of Idaho, College of Natural Resources, Forest Research Nursery. Available at: https://npn.rngr.net/renderNPNProtocolDetails?selectedProtocolIds=boraginaceae-cryptantha- 43&referer=wildflower. Accessed February 2018.

Luna, T. 2007. Propagation protocol for rock evening primrose (Oenothera caespitosa Nutt.). Native Plants Journal – Volume 8, Number 1, Spring 2007, pp. 40-41. https://npn.rngr.net/npn/journal/articles/propagation-protocol-for-rock-evening-primrose- oenothera-caespitosa-nutt. Accessed December 2017.

Luna, T.; J. Evans and D. Wick. 2008. Propagation protocol for production of container Erigeron compositus Pursh glabratus Macoun. plants (160 ml cone-tainers); USDI NPS - Glacier National Park, West Glacier, Montana. In: Native Plant Network. Moscow (ID): University of Idaho, College of Natural Resources, Forest Research Nursery. Available at: https://npn.rngr.net/renderNPNProtocolDetails?selectedProtocolIds=-erigeron- 27&referer=wildflower. Accessed February 2018.

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Tolstead. 1941. In Redente, E.F., P.R. Ogle, and N.E. Hargis. 1982. Growing Colorado Plants from Seed: A State of the Art. Voll III: Forbs. U.S. Dept. Int. Fish Wildl. Serv. FWS/OBS-82/30. 141 pp.

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Wick, D.; J. Evans and T. Luna. 2004. Propagation protocol for production of container Oenothera caespitosa Nutt. plants (116 ml containers); USDI NPS - Glacier National Park, West Glacier, Montana. In: Native Plant Network. Moscow (ID): University of Idaho, College of Natural Resources, Forest Research Nursery. Available at: https://npn.rngr.net/renderNPNProtocolDetails?selectedProtocolIds=onagraceae-oenothera- 112&referer=wildflower. Accessed February 2018.

Wick, D., T. Luna and J. Evans. 2008. Propagation protocol for production of container Sedum lanceolatum Torr. plants (160 ml containers); USDI NPS - Glacier National Park, West Glacier, Montana. In: Native Plant Network. Moscow (ID): University of Idaho, College of Natural Resources, Forest Research Nursery. https://npn.rngr.net/npn/propagation/protocols/crassulaceae-sedum- 63/?searchterm=sedum%20lanceolatum. Accessed February 2018.

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