Alberta Lepidopterists’ Guild (ALG) Submission re: Impacts of Drilling Proposed Gas Wells on Protected and other Arthropod Species in Suffield N.W.A. The Alberta Lepidopterists’ Guild is a non-profit citizens society made up of both amateur and professional entomologists with a focused interest in Lepidoptera (butterflies and moths). Our membership includes experts who are familiar with the available scientific information on Lepidoptera in Alberta, and who are actively expanding our knowledge of this poorly known arthropod group. ALG is concerned about the impacts of the proposal by ENCANA to drill wells in the Suffield National Wildlife Area. In recent years, ALG members have carried out extensive surveys of Lepidoptera in the Grasslands region of southern Alberta, including areas immediately adjacent to both the larger Suffield base as well as the Suffield NWA itself (Anweiler 2006). During those surveys we encountered numerous species of Lepidoptera that were otherwise rarely encountered in Alberta, including a number of species that are not known from elsewhere in Alberta, and in some cases, known nowhere else in Canada or the world. Our concerns with the ENCANA proposal are mutifaceted. One concern is that two species of moths that have been assigned either Threatened or Endangered status by COSEWIC have been found in the region. Others such as the Endangered Schinia bimatris may also be present, but no surveys for them in this region have ever taken place. We are troubled by the fact that these federally listed species have not been mentioned in your submission. There are also species of moths that are known from only 2 sites Globally (Protogygia alberta) or two sites in Canada (Cucullia dorsalis) that have been found in areas adjacent to Suffield. The SARA-listed Endangered Gold-edged Gem (Schinia avemensis) is known in Canada from only 3 active and two historic locations, and less than 10 locations globally. Two of these sites are located within approximately 30 km of the north and south sides of the Suffield base. To our knowledge, no surveys to determine whether or not this species occurs within the base including the Wildlife Refuge have ever been carried out. The COSEWIC listed Threatened Verna’s Flower Moth is also known from only a handful of sites in grasslands in Canada, which make up all the sites known for this species globally Two of the three known Alberta sites (2 of the 5 global sites) where this moth has been found are also located on either side of and within 30 km of the Suffield base. We are aware of no efforts having been made to determine whether or not these two listed species occur within the proposed drilling area(s). It is disturbing to find that species of wildlife that are currently guaranteed protection on Federal lands under Federal (SARA) Legislation that are known to occur in areas adjacent to the proposed drilling area are not even mentioned in the Impact Assessment reports prepared for ENCANA. Of broader concern than the effects on these two protected species of Lepidoptera, are the potential effects on other species of Lepidoptera. Very little is known about what other species of arthropods may inhabit the NWA, and what their habitat requirements are. Many of these other species are almost certainly rare and restricted in range, but we know so little about the fauna of the area and their habitat requirements, that we cannot predict what effects the proposed drilling activity will have on them. The only significant survey of arthropods within the Suffield NWA, that we are aware of, was carried out by researchers from the Royal Alberta Museum (the Provincial Museum of Alberta) (A. Finnamore). Although that survey collected approximately 3 million specimens, the vast majority have never been identified to species. The only groups examined in detail were Coleoptera (beetles) and Hymenoptera (bees, ants, and wasps). We know of no surveys of Lepidoptera in the Suffield NWA, but based on our knowledge of the Lepidoptera fauna of Alberta, we estimate that over 800 species of Lepidoptera occur in the Suffield NWA. Overall, the vast majority of arthropod species remain virtually unsurveyed at the Suffield NWA. The vast majority of wild species in Canada are arthropods, but they are also among the least-known groups. There are probably more species of Lepidoptera occurring within the Suffield NWA, than there are bird species and mammal species combined in all of Canada. Traditionally, birds and mammals receive the most attention in conservation efforts, but most ecosystem functions, are not carried out by those groups. In Canadian grassland habitats, one dominant group animals in terms of biomass are grasshoppers – which are also poorly known arthropods . Arthropods are so diverse and so poorly known in Canada that the vast majority of species have not yet been assessed for protection under SARA. The exceptions are most species of butterflies, and a few species of moths. We rely on the protection afforded by areas such as Suffield NWA to conserve the thousands of species that may be rare, but which are not known well enough to be afforded protection under SARA. Although we know very little about the Lepidoptera fauna within Suffield NWA, we do have some information on Lepidoptera in adjoining areas and in habitats similar to those of Suffield NWA. Sand habitats such as those found in the Suffield NWA are particularly scarce and threatened in Alberta, and harbour a number of Lepidoptera species known to be very rare and/or localized. Badlands habitats along the slopes of major southern river systems, including the South Saskatchewan river, are also known to support a unique arthropod fauna, including a number of species rare in Alberta, Canada and even globally. An example is Protogygia alberta, a noctuid moth described only recently and known from only two sites globally, along the Lost River valley in the Milk River drainage and in the badlands north of Jenner, about 30 km north of Suffield. Other species of moths known in Alberta from only one or two sites and which have been found adjacent to the WMA include (number of sites in brackets): Acronicta innotata (1), Acronicta longa (2), Abagrotis scopeops (1), Cucullia dorsalis (2 – the only Canadian records), Cycnia tenera (2), Schinia roseitincta (1), Hemileuca hera (2), Oncocnemis sanina (1). A number of these would almost certainly qualify for protection under SARA, but assessments have yet to be done on them. Undoubtedly other species exist in Suffield NWA that have yet to be discovered there. Therefore, based on our knowledge of Alberta Lepidoptera, we expect that the 800+ species that occur in Suffield almost certainly include a number of species that would qualify for SARA protection if we knew more about them. This applies to other arthropod groups as well - most of which are even less known than the Lepidoptera. From a biological perspective, the object of establishing protected sites such as SNWA is to ensure that ALL our wild species have adequate habitat set aside to ensure their viability, whether or not they are big, warm, and fuzzy/feathered, and whether or not we know much about their population levels and habitat requirements. The best protection for species that we do not fully understand is to ensure that adequate habitat exists for them at a landscape level. We therefore submit that the Impact Assessments provided to the board are deficient and flawed and cannot be relied upon to determine the impacts of the proposed drilling on arthropods, including but not limited to COSEWIC listed species and species protected under SARA Legislation. Respectfully submitted by Gary G. Anweiler (founding President) Dr. Felix Sperling (President) Greg Pohl (Secretary-Treasurer) Alberta Lepidopterists’ Guild http://www.biology.ualberta.ca/uasm/alg/index.html.