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EnCana Shallow Gas Infill Development in the CFB Suffield National
Wildlife Area – Assessment of Impacts to Soils, Vegetation, Rare Plants,
Reclamation Planning and Ecosystem Integrity –
Report No. 2 (Interveners Submissions)
Prepared for
Joint Review Panel - EnCana Shallow Gas Infill Development in the
Suffield National Wildlife Area
Prepared by
Jay Woosaree
Alberta Research Council
PO Bag 4000
Vegreville, AB
August 15, 2008
TABLE OF CONTENTS
TABLE OF CONTENTS................................................................................................................ i
EXECUTIVE SUMMARY ............................................................................................................ ii
1.0 INTRODUCTION............................................................................................................ 1
1.1 Review Objectives ........................................................................................................... 2
2.0 DOCUMENT REVIEWED.............................................................................................. 3
3.0 GENERAL OBSERVATIONS AND COMMENTS ..................................................... 5
3.1 Government of Canada .................................................................................................. 5
3.1.1 Department of National Defence .................................................................................. 5
3.1.2 Natural Resources Canada........................................................................................... 13
3.1.3 Department of Fisheries and Oceans.......................................................................... 14
3.1.4 Agriculture Canada....................................................................................................... 15
3.1.5 Environment Canada .................................................................................................... 15
3.1.6 Parks Canada ................................................................................................................. 21
3.1.7 Brad Stelfox’s Comments on Cumulative Effects Assessment of EnCana
Shallow Gas Infill Development.................................................................................. 21
3.1.8 NWA’s Management plan............................................................................................ 25
3.1.9 Suffield Environmental Advisory Committee/Suffield Industry Range
Control Ltd. .................................................................................................................... 26
3.1.10 Cheryl Bradley’s Submission Regarding Footprint, Soils and Vegetation............ 27
4.0 CONCLUSION .............................................................................................................. 27
5.0 REFERENCES ................................................................................................................ 31
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EXECUTIVE SUMMARY
The Canadian Forces Base Suffield National Wildlife Area (CFB Suffield NWA) is an
ecologically unique area of mixed grass prairie that is home to over 1,100 species of
plants, mammals, birds, reptiles, amphibians and insects and of which 14 species are
listed as species at risks in Canada. In 2003, the CFB Suffield NWA was declared a
protected area to assert the Government of Canada’s intention to preserve critical
wildlife habitat and to protect species at risks.
The proponent “EnCana Corporation” proposed to drill 1275 shallow gas wells within
the boundaries of its existing developed shallow gas field in the CFB Suffield NWA.
Jay Woosaree of the Alberta Research Council was contracted to provide advisory
services to the Joint Review Panel on analysis of the Environmental Impact Statement
(EIS), with regard to its impacts, and proposed mitigation measures pertaining to soils,
vegetation, rare plants and reclamation planning.
After reviewing the submissions from the Government of Canada and the major
environmental groups, several concerns with regard to EnCana’s Environmental Impact
Statement (EIS) were raised. The main issues included the following:
1. incomplete or insufficient information on the description of the proposed project
and related activities;
2. incomplete information on the description and characterization of the baseline
information;
3. uncertainties regarding environmental effects, predictions and analysis, and
cumulative effects;
4. uncertainties regarding effectiveness of the measures to mitigate significant
adverse environmental effects and the timeline for ecosystem recovery;
5. uncertainties regarding the effects of the project on species at risk (SAR) and their
critical habitat;
6. key environmental effects of the project on Base activities, including ecological
research capacity and cattle grazing;
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7. the NWA is a reservoir of a rare prairie habitat and associated biota; last remnant
of mixed grass prairie in North America and implies that the proposed gas infill
project should not proceed.
Department of National Defense (DND), especially as the land owner is overly
concerned of cumulative effects and wants to ensure that the capacity of the land, taking
into account military training, oil and gas, livestock/wildlife is not surpassed.
There are 14 species at risk in the Suffield NWA. A recovery plan for many of the species
identified within the NWA has to be developed, in order to abide by legislation at
described in Species at Risk Act (SARA). EnCana will have to apply for a permit before
any activities are conducted near a habitat that is deemed critical to the survival of
wildlife and plants, although many of the rare plants preferred disturbed areas, like
roadsides. EnCana have to demonstrate that its activities will help with conservation if
these species and that their habitat are protected. It will be a challenge to address the
needs of all the species in the area during well installation and operation.
A huge problem with invasive plant and weedy species already exists in the Suffield
NWA. Disturbed areas associated with roads and trails are the prime contributor. With
the proposed gas infill project, there is the potential that increased traffic will further
exacerbate the situation through the dispersal of seeds.
Information contained in the Suffield Industry Range Control (SIRC) and Suffield
Environmental Advisory committee (SEAC) report raise some concerns with operational
issues, compliance and with inadequate vegetation on some sites. However, these
reports also point to some good examples of best practices and revegetation techniques
leading to some sites fully recovered to nearly its pre-disturbed condition. There is also
an indication of EnCana’s willingness to cooperate with the CFB Base by funding several
research projects for a variety of wildlife studies in the NWA, including seed caches
created by Ord’s kangaroo rat and improved seed mixes. Reclamation practices, as they
relate to oil and gas activities, have evolved over the past three decades. Coupled with
best practices (erosion control, weed management strategies and reduced well visits
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(remote metering SCADA - Supervisory Control and Data Acquisition), avoidance of
critical habitat and obeying setback distances, effects from infill drilling can be
minimized.
The DND management plan is deficient in many respects. It has a vision but lacks
strategy on how to achieve its goals – preserving the integrity of the Suffield NWA. To
protect diversity, there should be some desired outcomes of what one wants and also the
feasibility and constraints. The Government of Canada is concerned with the integrity of
the Suffield NWA but have taken “a laissez faire approach” when it comes to the
management of invasive species and weeds in the NWA.
There is indication that bench mark data were being collected by DND staff and that
information could be better used to prevent impact if it was made available to the land
users, including EnCana. It also appears that a certain level of mistrust has been
developing since about 1999, which serves no good when it comes to protecting the
Suffield NWA.
Mitigation, at best should have taken into account the potential for restoration the land
to the pre-disturbance conditions. Depending on aspects and influences within the
landscapes and given the engineering constraints, the PDA (Pre-development Site
Assessment) approach is justifiable. DND staff must participate in that process.
Mitigation measures at best will sensitize us to the “trade-offs” that come with industrial
development, whether military or oil and gas on this unique landscape.
With regard to seeding disturbed areas, wild harvest seeds are sometimes not advisable
due to the difficulty in controlling weed seed content given so many weed and invasive
species were identified in the Suffield National Wildlife Area.
With regard to the effectiveness of the EIS, regular monitoring will be essential to
discover and rectify any impacts that were not predicted and to also ensure compliance
with restoration efforts and guidelines as set by the SARA and DND.
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v
On a final note, the Government of Alberta has stated that environmental liabilities from
mining and conventional oil recovery will not be passed on to future generations.
Protected areas such as the CFB Suffield NWA are designated so that future generations
can know the Majesty of the Earth as we know it today.
Recommendations
This is not to say the project is going to go ahead, but should the project proceed, the
following recommendation might be useful:
1. Constrained areas such as steep gullies and slopes are avoided as they can be
difficult to reclaim.
2. Setback distances so as to minimize project activities on species at risk ought to
be adhered to if an estimated 50 to 100 preliminary well locations are predicted
to fall within the specidfied 100m buffer.
3. Analysis of gaps indentified in the EIS to be completed in order to get an
understanding of the level of impact already occurring in the NWA.
4. Habitat loss and fragmentation have large impacts on wildlife and these should
be minimized whenever possible.
5. Appropriate management plans to ensure the protection of ecosystems within
the NWA must be in place to ensure that gas extraction activities do not impact
wildlife and their habitats.
6. Loss of habitat critical to species-at-risk should not be permitted.
7. To reduce cumulative effects of industrial activity, it may be useful to require
that abandoned or decommissioned sites are restored before additional sites can
are established.
8. A simplified quasi process to handle issues with operating in the NWA.
Sometimes the role of SEAC, SIRC and SGAC is not clear.
9. There should be a close scrutiny of all project activities as it appears that in the
past there was a lack of environmental inspectors to monitor environmental
effects.
1.0 INTRODUCTION
Jay Woosaree of the Alberta Research Council was contracted to provide advisory
services to the Joint Review Panel on analysis of the Environmental Impact Statement
(EIS), its impacts, and proposed mitigation measures pertaining to soils, vegetation, rare
plants and reclamation planning with regard to EnCana’s proposed Shallow Gas Infill
Drilling Project at CFB Suffield’s National Wildlife Area. Report # 2 dealt with the
similar matters based on information received from the interveners and through the
information requests.
Canadian Forces Base (CFB) Suffield National Wildlife Area (NWA) is part of a network
of NWAs established in June 2003 to protect critical habitats that are important to a wide
range of species that fall under the Species At Risk Act (Canadian Forces Based Suffield
NWA Management Strategy, Pp. 1-3). Examples of such species include: Burrowing
Owl, Peregrine Falcon, Loggerhead Shrike, Ord’s Kangaroo Rat – (Endangered) Sage
Grouse, tiny cryptanthe and sand verbena. In addition to the uniqueness of this habitat
in Canada the NWA also provides numerous goods and services such as military
training, resource extraction and cattle grazing. However, the Suffield NWA also
represents the last remaining of contiguous native mixed-grass prairie, an ecosystem
type which has been largely destroyed by agriculture and other human activities in
Canada. Thus, the Suffield NWA plays a critical role in the maintenance, and potential
recovery, of species unique to prairie habitats, and the mandate of Department of
National Defense (DND) is to ensure the long-term sustainable ecological carrying
capacity of this area.
Natural gas exploration and development began in 1975 in CFB Suffield, including the
NWA. However, drilling for deep gas and oil were prohibited in the NWA because of
the high degree of disturbance associated with this activity. Recently, EnCana
submitted a proposal to drill, over a period of three years, up to 1275 new shallow gas
wells in the Suffield NWA. This work would include construction, operation,
decommissioning, abandonment, and reclamation of wells sites and all associated
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infrastructure (e.g. roads) and activities. In addition, EnCana would like to drill three
wells at surface locations within the Suffield NWA.
Industrial activity within the Suffield NWA is prohibited without a permit, and permits
are only issued if the proposed activity does not interfere with the conservation of
wildlife (including direct mortality, habitat loss, etc.). EnCana commissioned an
Environmental Impact Statement (EIS) to determine if the proposed project would
impact wildlife in the NWA, the degree of that impact, and potential mitigation
approaches. In response to the EIS report, a variety of agencies (Department of National
Defence (DND), Environment Canada (EC), Natural Resources Canada (NRC),
Department of Fisheries and Oceans Canada (DFO), and Parks Canada (PC)) involved in
managing the Suffield NWA and the wildlife and habitats found in the area provided
written evaluations of the EIS, including identification of gaps in study design, data
collection, analyses, conclusions, and proposed management approaches.
The various stakeholders are directly concerned with ecological integrity and protecting
ecosystem components of the Suffield NWA and that the impacts from existing
development are still being observed. The key question with the proposed shallow gas
infill project in the Suffield NWA is “how can we respect and protect the qualities of the
NWA while still recognizing and allowing development and other land uses on this
pristine and endangered landscapes”?
1.1 Review Objectives
The primary objective of this technical review is to examine the materials provided by
the major interveners, namely the Government of Canada and the Environmental
Groups as they relate to the quality of information presented in the EIS.
The second objective is to provide advisory services to the Joint Review Panel (JRP) on
matters related to adverse impacts on the natural ecological processes of the Suffield
NWA.
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This review was undertaken not to present an answer to the question, “Should the
proposed EnCana shallow gas infill development in the Suffield NWA be approved?”
I have examined all the related materials, however not all of them are specifically
discussed in this technical review. For example, I have reviewed the submission made
by Garry Trottier, June 16th, 2008 as to why the “EnCana application should be denied
and that the JRP is not the place for making dispositions on well licenses (page 2,
paragraph 2)”. However, I could not comment on the JRP. My goal was to provide
advisory services to the JRP. I have also liaised with Dr. Troy Whidden, the JRP
independent consultant on wildlife issues with matters related to habitat suitability for
wild life in post reclamation and in general with regard to the EIS and by the
interveners. In addition, I have also consulted with (Brian Eaton, my colleague at the
Alberta Research Council) on issues related to ecosystems, habitat, and biota.
2.0 DOCUMENT REVIEWED
In addition to information provided in the EIS, the materials reviewed include those
presented by major interveners that are filed with the Canadian Environmental
Assessment Agency (CEAA). These are:
a. Government of Canada Submission 420, including submissions from the
Department of National Defence, Environment Canada, Natural Resources
Canada, Fisheries and Oceans Canada, Agriculture Canada, and Parks
Canada; updates on above submissions, including those from Natural
Resources Canada, and Environment Canada;
b. “Ecosystem impacts of historical shallow gas wells within the CFB Suffield
National Wildlife Area” by J. Rowland (2008);
c. Environmental coalition, submissions 421 , 422 and 550;
d. Suffield Environmental Advisory Committee (SEAC) - Olaf Jensen and Rob
Kennedy, submission. Submission 470;
e. Suffield Industry Range Control Ltd. Submission 445;
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f. Canadian Forces Base Suffield Range Standing Orders. Chapter 7-Oil and gas
activity protocols. 31 pp;
g. Brent Smith, March 2007 - Assessment of agronomic species invasion from
pipeline right-of-way at CFB Suffield National Wildlife;
h. Brent Smith and Andrew Taylor. December 21, 2007. Assessment of residual
crested wheatgrass lease site footprint and invasion from old pipelines to
new pipelines.
i. Brent Smith and Andrew Taylor. December 21, 2007. Comparison of
vegetation parameters between on and off lease areas after minimal
disturbance shallow gas development within the CFB Suffield National
Wildlife.
j. Canadian Forces Base Suffield National Wildlife Area Management Strategy.
k. Alberta Wilderness Association- Cliff Wallis; re: critical habitat for species at
risk;
l. Entomological Society of Alberta – Re: insect fauna;
m. EUB Application No. 1435831;
n. Federation of Alberta Naturalists, submission 411 and 548;
o. Entomological Society of Alberta, submission 545;
p. Garry Trottier, submissions 430 and 533;
q. Society for Grassland Naturalists – Thomas Michael Power;
r. Society for Grassland Naturalists – Henry Binder;
s. Alberta Wilderness Association and Nature Canada – Cleve R. Wershler:
Rare plants and rare ecological communities: wetland, wildlife, biodiversity;
t. Nature Canada – Johanna McNulty; the vision of National wildlife
management plan;
u. SEAC – Minutes of the AGM June 2006;
v. Douglas Hutton. Submission 423;
w. Nature Canada. Submission 407;
x. Federation of Alberta Naturalist. Submission 411;
y. Jacques Whitford AXYS Ltd. Inventory of selected wetlands in the CFB
Suffield Main Training Area. May 2008;
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z. EnCana’s response Miss Collier ‘s email of April 13th, April 17t h and letter of
May 1st. EnCana’s letterhead was not dated;
aa. Suffield Environmental Advisory Committee. 1999 – 2006. Minutes of
meetings with the Base Commander and industry;
bb. Suffield Grazing Advisory Committee. 2006. Context and Guiding Principles
for SGAC. Annex E of 2006 Report to DND;
cc. Rob Longair, Submission 427;
dd. Dennis Baresco, submission 408;
ee. Environment Canada – Setback distance guidelines. Prairie Plant Species at
Risk;
ff. Office of the Auditor General. 2008. Status Report of the Commissioner of the
Environment and Sustainable development to the House of Commons;
gg. Trican Well Service Ltd. Submission 401;
hh. Calfrac Well Services Ltd. Submission 383;
ii. Joyce Hildebrand. Submission 414;
jj. Weatherford partnership. Submission 393;
kk. Alberta Energy. Submission 406;
ll. Review of the proposed 2005 Oil and Gas drilling programs for CFB Suffield.
1262-1 (G3 Bio);
mm. Biological Survey;
nn. Northern EnviroSearch Ltd. 2008. Effects of oil and gas development on
grassland birds;
oo. Flint Energy Services Ltd. Submission 403;
pp. Milt Roney. Submission 400;
qq. Beacon Oilfield Services Ltd. Submission 432.
3.0 GENERAL OBSERVATIONS AND COMMENTS
3.1 Government of Canada
3.1.1 Department of National Defence
The Department of National Defence as the responsible authority for the Suffield NWA,
found that the information contained in the EIS (Volume 3, Terrestrial Biophysical
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Assessment) was insufficient to assess the potential for the proposed project to cause
significant adverse environmental effects, and that substantial additional information is
required before the review panel can reach a conclusion regarding the proposed shallow
gas infill project (page 11, last paragraph). DND provided a list of 61 recommendations
to the proponent, which provides an indication of the extent to which the EIS was
lacking key information (pages 122-131). The request for additional data is justified
when the potential impact of the project and the lack of key information in the EIS are
considered as a whole.
The main issues that DND had with the EIS for the proposed project included the
following (page 10, third paragraph):
1) incomplete or insufficient information on the description of the project and
related activities
2) incomplete information on the description and characterization of the baseline
information
3) uncertainties regarding environmental effects, predictions and analysis, and
cumulative effects
4) uncertainties regarding effectiveness of the measures to mitigate significant
adverse environmental effects
5) uncertainties regarding the effects of the project on species at risk (SAR) and their
critical habitat
6) incomplete information on alternative means analysis
7) key environmental effects of the project on Base activities, including ecological
research capacity and cattle grazing
DND examined the impacts of historical shallow gas wells in the NWA to determine the
short- and long-term effects of this type of activity on the ecology and biota of the area
(Rowland 2008). This study examined the impacts of wellsites and pipelines on various
ecological components in the Suffield NWA. The percent cover of native plant species,
for example, was found to be significantly higher on control transects than on impacted
transects for 8 of 10 comparisons (comparisons were made between two treatment types
[well, pipeline], 3 year classes [1985, 1997, 2000], and 2 soil types [loam, sand]). Percent
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cover of non-native species was higher on impacted transects than control transects in 6
of 10 comparisons; for the remaining 4, there was no difference between control and
treatment transects. There was significantly lower native species diversity on impacted
transects than control transects in 8 of 10 comparisons, with the other 2 being non-
significant, and significantly higher non-native species diversity on impacted transects
in 6 of 10 comparisons.
Taken together, these findings suggest that there are both short- and long-term impacts
related to gas extraction activities in the NWA. Increase in bare ground areas at
impacted sites was generally related to a decrease in native species percent cover, and an
increase in non-native plant species percent cover (Rowland 2008, page 27, paragraph 2).
The production of bare ground, which provides a route of invasion by non-native plant
species, results in a potentially serious impact to the ecological integrity of the NWA
(Rowland 2008, page 27, paragraph 3). Impacts after 22 years of development are still
being observed in the NWA (Rowland 2008; page 27, paragraph 3)
In addition, the establishment of wellsites and associated infrastructure in close
proximity to ephemeral and permanent wetlands in the NWA was seen as a cause for
concern, as wetlands are a valued ecosystem component in the NWA and can be
compromised by nearby development (Rowland 2008, page 28, paragraph 3).
Overall, Rowland (2008) concludes that there are a number of long-term effects to the
ecological integrity of the CFB Suffield NWA related to installation and operation of
shallow gas wells in the area. Therefore, appropriate management plans to ensure the
protection of ecosystems within the NWA must be in place to ensure gas extraction
activities do not impact wildlife, and wildlife habitat.
Reclamation Plan
The efficacy of the mitigation and compensation measures to be used when installing,
servicing, and de-commissioning shallow gas wells in CFB Suffield NWA is a cause for
concern. Environment Canada anticipates the proposed project will expand the existing
footprint (page 194, paragraph 2) as mitigation might take longer than 50 years.
7
Once the soil is disturbed there is always potential for the introduction of invasive
species and weedy species. Mitigation and compensation measures must take into
account the potential for the introduction of non-native species, soil erosion, direct and
indirect impacts on wildlife, long-term sustainability of the site. By sustainability I am
referring to the ability of the plant communities to reproduce themselves, biomass
production, litter production and nutrient cycling.
Although DND has requested that the proponent provide “definitive timelines for the
return to pre-disturbance conditions” (page 131, bullet f), there is much evidence
(Rowland, 2008; DND Audit, 2005) to suggest that impacted sites are not comparable to
pre-disturbance conditions even after approximately 10-20 years. Restoration is a long-
term process and at times can be difficult (Suding et al. 2004), or to predict the success of
restoration activities based on short-term monitoring or trajectories (Zedler and
Callaway 1999; Cortina et al. 2006; Herrick et al. 2006). Factors that can reduce the
restoration success include frequent burning, lack of or low organic content in the soil,
time of seeding, erosion issues and adapted plant species.
Reclamation is usually just the planting of some form of cover to stabilize the soil and
prevent erosion and provide function, while restoration aims to return a degraded site to
a plant cover that is protective, but also valuable in a conservation sense, and has long-
term sustainability (Hobbs and Norton 1996). Restoration is important for a number of
reasons. Restoration can increase the rate at which sites approach reference sites in
terms of similarity of species composition (McLachlan and Knispel 2005), and should be
considered as a viable approach when restoring impacted lands related to the proposed
project.
DND describes that “The Proponent states that “Reclamation will seek to maintain or
improve range health. Disturbed areas will be re-seeded immediately following cleanup
of the disturbance or as soon as possible to stabilize soil and reduce non-native species
invasion on exposed areas” (page 120, last paragraph) . Using adapted native species
whether from local harvesting or cultivated ecotypes, one can restore disturbances to a
8
state comparable to pre-disturbed conditions, thus maintaining the characteristics
(composition, structure, function and withstanding Nature’s disturbance regimes) of the
ecosystem. I see it difficult to understand why some impacts (lack of vegetation or
increased bare ground) are still being felt in certain areas of the NWA. Figure 1 shows a
site in the “Special Areas” near Hanna, Alberta where re-grassing (convert back from
non-native forages) and better farming methods 12 years ago have led to a native
pasture that fairs much better than the pre-disturbed area.
Figure 2. Restored plains rough fescue grassland in the mixed grass prairie near Hanna
(Photo taken first week of October 2007).
During my visit to the Suffield NWA (February 5th , 2008) it appeared that DND had
some test plots of various plant species. Information on provenance testing could be
valuable if incorporated in seed mixes that the proponent can use. It will also address
concerns with the genetics of the seeds that we proposed for the NWA. If harvested hay
from a nearby field is to be acquired, one has to ensure that the area is free from crested
wheatgrass, weedy species and other non-native species.
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Timeline to reclamation success
If the restoration objectives include the ability to “jump start” the natural succession
pathway by means of using late seral species in the seed mix, we can shorten the length
of time required for a disturbed site to recover to its natural state. Therefore I have to
agree with EnCana statement that it is possible to improve range health if proper
mitigation techniques are implemented. With proper monitoring, impacts of the
proposed gas infill along with other land use can be measured by evaluating its effects
on the flora and fauna. Biological effects to monitor included but not limited to: effects
on plant productivity, fitness of the seeded mixtures (how it withstands the elements),
litter amount and decomposition and occurrence of weedy and non-native species.
Therefore, EnCana should focus more on a restoration approach as to how to accelerate
the recovery process. Example of successful reclamation is described in SEAC’s notes
with reference to Site 1 (ANNEX G, 4500-12, Jul 04, paragraph 2). Using EnCana’s long
history in the Suffield area, EnCana has baseline data to build up restoration efforts and
determine some trajectory timelines. A revised reclamation plan should provide
information on how the restoration plan will proceed and potential endpoints, including
timelines, followed with monitoring and an action plan in case indicators of successful
restoration are not observed.
Cummulative effects
With regard to cumulative effects, DND; Cleve Wershler, page 21, paragraph 5) the
approach EnCana used to determine incremental footprint was not appropriate. The
anthropogenic footprint created by features detectable using digitized air photos could
not differentiate habitat types such as those that include crested wheatgrass. Ground
truthing would have differentiated between the crested wheatgrass and other native
vegetation cover.
With regards to effects of wellsite density on prairie integrity, it is impossible to
determine if a reference condition approach has not been used. Thus, if there is a
threshold function in terms of how wellsites affect native range condition (e.g. 4 wells
10
per section has a great impact, but incremental wells has relatively little impact) it was
not to be detected by the sampling design and analysis used in the EIS.
It should have been compared to a control area. In a “Sand Country Almanac”, Aldo
Leopold says that “we do not know how good a performance to expect of a healthy land
unless we have a wild for comparison”. Even in the 1940’s, it was known that we need to
have a control area to relate to as otherwise we would not know how healthy or sick the
land was. I raise this point because the incremental footprint size is estimated at
approximately 0.5% (EIS Volume 3,page 7-1) for now, should EnCana decide in the
future (let’s say 10-20 years), to increase the number of wellsites, a claim can be made
that footprint size is still negligible where in fact potential impact could have been
increased. To establish a cause-and-effect relationship, it is important to have some
controls or benchmark data to which we can measure performances of potential
mitigation techniques.
In addition, to reduce cumulative effects on this sensible landscapes, it would be
appropriate if some of the impacted areas including abandoned wellsites, sites that do
not have adequate cover ( (DND Audit, 2005; series of photos in the Appendix;) and
trails could be revegetated using a appropriate native seed mixes.
Invasive species
Cleve Wershler claims that “EnCana fails to recognise the deterioration of the grassland
ecosystem (page 13, paragraph 6) … and the proposed planting of a mixture of grasses,
including non-native forms will create a community that is different in structure and
species”. Similar concerns with regard to native prairie integrity by environment
Canada (Government of Canada, page 155, paragraphs 2, 3, and 4) were raised.
The spread of invasive species and weeds is one of the greatest factors that will influence
the integrity of the Suffield NWA. Between 1977 and 1982, a network of natural gas
pipelines and wells were installed in native mixed grass prairie at the CFB Suffield
NWA in southeastern Alberta, Canada. Crested wheatgrass was seeded and seeds
11
dispersed onto adjacent undisturbed native prairie have led to more occurrences of
crested wheatgrass. It was not clear (Rowland, 2008) how the influence of grazing and
military manoeuvres contribute to the spread of these non-native species. While
monitoring aids in bringing awareness to the issue, there should be an action plan
involving all land users to assist in controlling existing crested wheatgrass. Furthermore,
due to their prolific seed production, invasive species will target sites that have even
slight disturbances and especially those sites that have fine soils. It is important to
eradicate the new seedlings before they become prolific (Brent Smith, 2007 page 18,
paragraph 1).
The Suffield Grazing Advisory Committee (SGAC) identified crested wheatgrass
introduction during reclamation of industrial sites as a threat to future integrity (SGAC
Report 2006, Annex D) in the Suffield NWA. Attention should also be paid to the control
of many agricultural weedy species and non-native species found within wetland areas
in the Suffield NWA. Bradley ([2008] page 23-25) and Jacques Whitford AXYS Ltd.
(2008) described many of the introduced species found in the Suffield NWA. These
include: Bromus inermis (smooth awnless brome grass), Bromus tectorum (downy chess
brome), Dactylis glomerata (orchard grass), Elytrigia repens [=Agropyron repens](quack
grass), Phleum pretense (timothy), Poa pratensis (Kentucky bluegrass), Polypogon
monspeliensis (rabbitfoot grass), Setaria viridis (foxtail), Polygonum arenastrum (common
knotweed), Rumex stenophyllus (narrow-leaved dock), Axyris amaranthoides (Russian
pigweed), Chenopodium album (common lambsquarters), Kochia scoparia (kochia), Salsola
kali (Russian thistle), Alyssum desertorum (yellow alyssum), Capsella bursa-pastoris
(Shepherd’s purse), Descurainia sophia (flixweed), Erysimum cheiranthoides (wormseed
mustard), Sisymbrium altissimum (tumble mustard), Thlaspi arvense (field pennycress),
Medicago lupulina (black medic), Medicago sativa (alfalfa), Melilotus officianilis (yellow
sweet clover), Trifolium hybridum (alsike clover), Euphorbia esula (leafy spurge), Lappula
squarrosa (bluebur), Linaria dalmatica (broad-leaved toad-flax), Linaria vulgaris (butter-
and-eggs), Plantago major (common plaintain), Artemisia absinthium (absinthe wormwood
[another invasive species]) , Cirsium arvense (creeping thistle), Crepis tectorum (annual
hawk’s beard), Gnaphalium uliginosum (low cudweed), Lactuca serriola (prickly lettuce),
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Sonchus arvensis (perennial sow-thistle), Taraxacum officinale (common dandelion) and
Tragopogon dubius (common goat’s-beard).
3.1.2 Natural Resources Canada
The comments of Natural Resources Canada were largely restricted to geology and
groundwater impacts of the proposed project. However, some of these comments are
relevant to biota and ecological integrity. For example, EnCana proposes to work in
areas of active sand dunes, which are important habitat for Ord’s Kangaroo Rat and
other dune dependant species. Although EnCana states that the potential impact on
these dunes is insignificant, Natural Resources Canada concludes that declines in this
habitat type in the NWA make it important that potential impacts on sand dune habitat
stemming from the proposed project be examined more thoroughly (page 343, last
paragraph). Natural Resources Canada also suggests that EnCana provide a constraints
map for the entire NWA where proposed wellsites would be located, and including all
roads and trails used to access wells during the operational phase of the project (page
346, first paragraph), and provide additional detail on the Environmental Effects
Monitoring Plan that is required as part of the EIS (page 347, first paragraph). The
overall conclusion of Natural Resources Canada appears to be that additional detail is
required for some aspects of the proposed project, though adequate information was
provided for other aspects, such as climate change trends (page 348, first paragraph) and
impacts on quantity and quality of groundwater (page 351, fifth paragraph).
Natural Resources Canada reviewed the supplemental submission of an Environmental
Protection Plan and Environmental Monitoring Plan by EnCana and concluded that a
variety of problems existed with these plans. These included the fact that, despite clear
rules for constraints mapping to avoid placement of wells and access features in
environmentally sensitive areas, the preliminary well locations actually proposed were
located to optimize natural gas reservoir recovery (Natural Resources Canada’s review
of EPP and EMP, page 28, paragraphs 4 and 5). In addition, NRC concluded that the
requirements of the monitoring program were not clearly outlined in the EPP (NRC’s
review of EPP and EMP, page 30, third paragraph), and that the EMP did not appear to
fulfill the requirements of a follow-up program (NRC’s review of EPP and EMP, page
13
30, fifth paragraph). NRC concluded that additional detail was necessary before the
adequacy of the EMP could be fully assessed.
Environmentally sensitive areas such as wetlands or “prairie potholes” as it is often
referred on the prairies are important habitat for wildlife as it provides them with water,
food, cover and serve as breeding ground. There is also a greater number of plant
species that are associated with these wetlands, leading to greater productivity.
Furthermore, wetlands play an important role in the hydrogeological cycle. In the EIS,
approximately 400 wellsites were to occur within wetland boundaries. EnCana stated
that no well sitings will occur within a wetland (IR No. CEAA-EIS-019; Fan-23).
Setback distances for both wetlands and for “valued ecosystem components” such as for
those species affected by SARA (Recovery Team for Plant Species at Risk in the Prairie
Provinces, 2008, pages 2-3) must be observed. These serve two purposes. In case there is
a spillage during development, these important habitats are protected from
contamination and more importantly we do not know the population sizes that are
required to maintain a viable population for both endangered plants and wildlife.
3.1.3 Department of Fisheries and Oceans
The Department of Fisheries and Oceans, after reviewing the proposed EnCana project,
concluded that the project was unlikely to cause “significant adverse effects to fish and
fish habitat” as long as the suggested mitigation measures were implemented during the
project (page 355, paragraph 3). The measures suggested such as minimized vegetation
removal, site revegetated immediately, spill contingency plan, etc. (pages 358-359)
included efforts to minimize production of sediment that could enter water courses, and
prevention of waste materials and chemicals from entering water courses (page 358,
paragraph 4). Overall, DFO had no major concerns with the proposed project and I
agree that if the proposed mitigation techniques are properly implemented, the proposal
would not result in any impacts to fish habitat in the South Saskatchewan River.
14
3.1.4 Agriculture Canada
Agriculture Canada personnel reviewed the EnCana EIS and supplementary materials,
focusing on the potential impact of the project on grazing in the area. Agriculture
Canada concluded that, if EnCana followed the mitigation and consultation measures as
outlined in the EIS and supplementary documents (e.g. Supplemental Information
Requests) the project should not have significant effects on grazing in the area (page 371,
paragraph 2). My only suggestion is that livestock stocking rates may have to be
adjusted depending on mitigation effectiveness and carrying capacity of the area during
the early years of revegetation.
3.1.5 Environment Canada
CFB Suffield NWA is one of the few large contiguous areas of native prairie left in
Canada, and its ecological integrity must be preserved. Environment Canada, through a
detailed review process, found that the information provided by EnCana EIS was not
adequate to assess the potential detrimental effects of the proposed project to this
important area, and provided a list of 16 areas in which the EIS was considered
inadequate (pages 232-242). The independent analyses done by Environment Canada
suggested that negative effects from current industrial activities in the Suffield NWA
have already occurred, and that further activity in the area would exacerbate these
effects, and potentially endanger the recovery and survival of several species-at-risk that
occur in the area. Therefore, Environment Canada concluded that no additional
industrial activity should be permitted until it could be demonstrated by EnCana that
this activity would not negatively affect any species-at-risk, critical habitat, or the
ecological integrity of the area (page 144, paragraph 2).
Environment Canada, following a review of a supplemental submission of an
Environmental Protection Plan and Environmental Monitoring Plan by EnCana,
concluded that there were significant uncertainties in the plans regarding impact
analysis, mitigation, cumulative effects, and the potential for negative environmental
effects, especially for species-at-risk.
15
Species at Risk
EnCana’s response to the Federation of Alberta Naturalist (IR No. CEAA-EIS-019; Fan-
23) states that “EnCana will not drill any wells in wetlands….will never have wells
within 15 m of a wetland and in exceptional cases, will only have wells between
15-100 m of a wetland. By not having wells within a wetland help to address concerns
raised with regard to birds (Alberta Wilderness Association June 27, 2008), setback
distances for species at risk habitat (Government of Canada, page 191) and insects
habitat (CEAA document 545). My only concern is that some of the setback distances is
debateable until research is completed to fill some of the uncertainties associated with
“how far is far enough” before there is an impact to any endangered species and until a
recovery plan is completed for species that fall under SARA’s jurisdiction.
I completely agree with Environment Canada that SARA permits should be obtained for
all species at risk as identified (Table 1) in the Suffield NWA. The needs of each species
should be assessed, and appropriate buffers established (Goates et al. 2007). In addition,
critical activity periods (e.g. emergence of snakes from dens, movement periods for
pronghorns) should be considered when planning industrial activities.
Table 1. List of species that are of concern/threatened or endangered in the Suffield
NWA
Slender Mouse-Ear Cress Threatened Schedule 1
Smooth Goosefoot Threatened Schedule 1
Tiny Cryptanthe Endangered Schedule 1
Small flowered Sand Verbena Endangered Schedule 1
Western Harvest Mouse Endangered Schedule 3
Ord's Kangaroo Rat Endangered Schedule 1
Burrowing Owl Endangered Schedule 1
Gold-edged Gem Endangered Schedule 1
Lake Sturgeon Endangered Not Listed
Sprague's Pipit Threatened Schedule 1
Loggerhead Shrike Threatened Schedule 1
16
Common Nighthawk Schedule 1 Not Listed
McCown's Longspur Special Concern Schedule 1
Long billed Curlew Concern Schedule 1
Northern Leopard Frog Concern Schedule 1
Great Plains Toad Concern Schedule 1
Ferruginous Hawk Special Concern Schedule 3
Short eared Owl Special Concern Schedule 3
For species for which a recovery plan does not exist, appropriate setback distances for
known wildlife species should be observed or even such areas be avoided until research
gaps (effects on wildlife, avoidance responses, distribution shifts, habituation, migration
barriers and decreased productivity) is completed. Mitigation measures in the EPP and
the EEMP I can address some of these issues as seen in EnCana’s past experiences
(ANNEX G, 4500-12 Jul 04 (page 6, paragraphs 1 and 2).
It is important to manage and minimize impacts in the Suffield NWA as it is one of few
remnants of natural mixed grass prairie. Parameters such as species richness can be
maximized if disturbances mimic natural disturbances, such as fire and grazing (Collins
and Barber 1985). Cattle grazing, for example, is a good mimic of historical bison
grazing, and helps maintain biodiversity in grassland ecosystems (West 1993). In a
landscape being used to extract resources, it is imperative that connectivity across
ecological units be maintained, that keystone and threatened species be conserved, and
that invasive species be controlled (Fischer et al. 2006). Connectivity is essential,
especially for small animals to sustain flow of organism, genes, nutrients, water, energy
plus materials that builds and sustain habitat (Forman et al., 2003, page 227).
I supported DND’s remarks (Brent Smith, 2007; page 23) that research is required to
determine how birds and other small wildlife populations are affected and how rare and
provincially/federally listed species found adjacent to pipelines are affected.
17
With regard to the “Pre-disturbed assessment” (PDA), DND must be present when such
activity is being conducted, so that there is consensus as to the final siting of a particular
wellsite or pipeline.
Project footprint
The lack of baseline surveys and identification of potential project-related impacts , size
of footprint as reflected by site seeded with crested grass between 1977 and 1982
(Government of Canada, page 192, paragraph 6; Bradley, page 20, paragraph 2) were
considered a cause for concern (Environment Canada’s review of EPP and EMP, page 1,
paragraph 1). Environment Canada concluded that the EPP and EMP were insufficient
to warrant approval of the proposed project at the present time.
There is evidence that these disturbed areas are important routes of penetration by
invasive species (Larson 2003), from which they can spread (Hansen and Clevenger
2005), and that vehicles are important vectors of non-native seed dispersal (von der
Lippe and Kowarik 2007). Care must be taken to minimize introduction of non-native
and invasive native species during well construction, operation, and decommissioning.
It is interesting to note that 25 years ago, limited or no native seed sources existed for
seeding on native landscapes. The prescription of the day was to use non-native species
or tame forages as it is often referred, be used to control erosion, provide cover and for
forages. The Suffield NWA was no exception. Much crested wheat grass was planted on
the prairies to prevent wind erosion. Later, tame forages became popular for
revegetation as there were no commercially available alternative seeds. On my visit to
the area, I noticed that much of the road allowances had been seeded in the past to
crested wheatgrass and with brome grass near the river banks and a number of weed
species near the cattle pen. It is known that the spread of crested wheatgrass can lead to
reduction of biodiversity, yet over the previous years DND did not have a plan to deal
with the eradication of crested wheatgrass.
18
Today, there exists various native seed sources and along with new technologies one can
go a long way to reduce cumulative impacts. The reclamation plan includes “Canada
bluegrass” as one of the species that could be used in the seed mix. That seed mix will be
revised and in the February 7th workshop, EnCana stated that all disturbances including
those in the Suffield NWA will be seeded to native species.
With regard to the lack of information on seed mixes (Bradley, 2008; page 32, bullet 11),
there is nothing wrong with using slender wheatgrass as a rapid colonizer. It is a native
species, competes well with weeds, it is a short lived species (~5 years) and it does allow
late seral species to occur naturally in the area in which it was seeded. Its appearance
may not blend with the natural landscapes, but it provides the required landscape
function.
DND is considering harvesting seeds for its own use mixes (Bradley, 2008; page 32,
bullet 11), one has to be careful that more weeds and non-natives are not spread.
Proponents of wild harvesting seed sources believe that maintaining the integrity of
lineages adapted to local conditions is important because crossing with foreign genetic
materials leads to outbreeding depression (Guerrant, 1996). On the other side,
proponent believe that using multiple source materials combine a species genetic within
an individual site or ecologically similar sites (Jones, 1997) and this approach reduce
risks for revegetation failure and provide the genetic diversity that allows species to
adapt to future conditions.
Thus there is a need for an improved management plan involving all land users
(including EnCana) to address funding to control the spread of invasive and weedy
species in the Suffield NWA and to change focus from reclamation to restoration.
Combined with revegetation of decommissioned sites, and improved revegetation tools
(new seed mixes, erosion control measures, and minimum disturbances) footprint sizes
can be kept to a minimum.
19
Concern over mitigation effectiveness
Environment Canada stated “despite a long history of operating on CFB Suffield, the
proponent has not demonstrated that it can effectively reclaim large disturbed areas.”
Consequently, Gary Trottier’s (Submission 533; page 4,) is concerned that “SEAC does
not support further drilling in the NWA until such time as the recommended
environmental assessment and monitoring program has been developed and
implemented” and Bradley (page 28, paragraph 2) disagrees with the mitigation
measures proposed in the EnCana EIS (Vol 3, sec 2.8.2 and Sec 3.7) .
The following is a statement from the minutes of SEAC’s meeting. (Annex G, 4500-12,
Jul 4, 2004 Reece Operational Observations) makes note of how Wellsite 1 is reclaimed. It
reads:
“The reclamation of this particular wellsite appears to be progressing
very well. Assuming this site is reflective of the overall reclamation
practices being employed by the industry, it aptly demonstrates the
effective incorporation of an abandoned industrial site back into
surrounding natural landscape. This should provide all parties with the
confidence and certainty “end of life” obligations are being properly
addressed”.
Furthermore, ANNEX G, 4500-12 Jul 04 (page 6, paragraph 1 and 2) reads:
“EnCana’s record on environmental actions is excellent. Low impact
drilling, lease clearance, expansion of SEAC protocols to south block of
NWA, snake conservation plans including rerouting and seasonal drilling
restriction zone to all of the snake conservation area. Support for several
wildlife studies on the Base. Supported 1999 deep rights agreement
excluding the NWA from surface access”… “Military initiatives /
recognition are also outstanding” (page 9, paragraph 2). Annex A,
August 2005 (page 6, paragraph 2).
Recently, it seems that there is a disconnect between EnCana and the CFB Suffield
(SEAC’s Minutes of the AGM June 2006; page 7, paragraph 2).
20
With regard to minimal disturbance techniques (Bradley, page 29, paragraph 2) there are
some indications (SEAC’s Minutes of the AGM June 2006; ANNEX D, 4500-1-49, April
13, 2007; Serial 10, 12, 13) that mitigation measures were not to be overly effective
(braided trails, soils issues related to winter drilling, no attempt to control crested
wheatgrass on access trails ). Due to landscapes influences (steep slopes, decreased top
soil, reduced organic matter and wind) might impede revegetation success, thus
requiring additional efforts from the proponent.
3.1.6 Parks Canada
Parks Canada reviewed the EnCana EIS was limited to consideration of heritage
resources, and did not consider ecological attributes. One of their suggestions is to
consult First Nations with regard to archaeological site in the Suffield NWA (page 384,
paragraph 2).
With regard to Siksika Nation’s concern over traditional lands use (IR Siksika 2),
Traditional Ecological Knowledge (TEK) regarding vegetation (IR Siksika 3, 5),
importance of wetlands to the Siksika’s cultural and spiritual way of life vegetation (IR
Siksika 9), and Siksika’s historical presence in the Suffield NWA (IR Siksika 11), EnCana
is negotiating a Memorandum of Agreement with the Siksika Nation to dealt with the
issues raised (EnCana’s response August 2nd, 2007).
3.1.7 Brad Stelfox’s Comments on Cumulative Effects Assessment of EnCana Shallow
Gas Infill Development
With regard to methodologies used to address cumulative effects including the “natural
range of variability (Page 3, paragraph 3) , I agree with the statement that without solid
data prior to the arrival of industrial land uses, it is difficult to make reference against
which one can compare any future landscapes influence. Actually, there is a lack of
baseline data in both space and time in Alberta that we can relate to. We learned from
Rowland (2008) that impacts of industrial activities 20 years ago are still being felt in the
Suffield NWA. The use of the Monte Carlo method despite its randomness and
uniformity is still based on assumptions; however it can provide a “proactive approach”
to an environmental management plan.
21
Although ALCES is gaining popularity (page 3, figure 1) among land managers
(Southern Alberta Landscape project, page 3 paragraph 3), I am not sure if it is “the
preferred methodology” in determining cumulative effects. As the range of natural
variability is approximated, it provides an attribute of some pre-disturbance landscapes
to post disturbance landscapes. I would prefer to see some studies on thresholds for the
NWA. Thresholds are desired as they allowed certain activities to proceed until the
magnitude of the effects reach a point at which we have to take actions.
With any new project, there is biological and a social component (Thomas et al, 1993)
and there is no common view of what level of risk is acceptable. With implementation of
an “EIS Environmental effects monitoring plan and having an adaptive environmental
management strategy for the Suffield NWA, it should not reach a point where the
integrity of the landscapes is further compromised. The map time series (page 5, figure
2) illustrate how land use trajectories, even at a 2 to 3% growth per year can compound
and a have a significant impact on the landscapes. This landscape is already impacted by
current activities. I would rather see resources geared towards addressing issues that
can further affect the integrity of the landscapes such as the spread of invasive species,
lack of vegetation cover and implementation of practices (remote monitoring, avoidance
of critical habitats, better tires on vehicles, etc.) that when combined lead to decreased
footprint sizes.
The EIS provides a theoretical explanation of the range of natural variability (fire,
wildlife grazing, wind erosion, weather patterns, etc). We need an approach that can in
reality take into account the natural range of variability and use that information to
determine some timelines as to when we can expect a particular site to be fully restored.
Having to wait 20-50 years for a site to adequately recover is too long and jeopardizes
the status of the Suffield NWA as a wildlife sanctuary. In the EIS EnCana did not
attempt to model the pre-industrial landscape with respect to ecosystem processes and
valued ecosystem components. Such concern (Bradley, Page 4, paragraph 5) argues the
need for modeling to define whether the landscape in the Suffield NWA already
experienced a significant change because of cumulative effects of other anthropogenic
22
(man-made) disturbances? What is the current trajectory of ecosystem processes and
components?
Apparently, there seems to be no benchmark data for CFB, (although at some point in my
review it appears that CFB Suffield was collecting biophysical data). In order to model
impact of development in the Suffield NWA, I would suggest that EnCana use the 30
years experience in the Suffield area. Using these vegetation data (plant cover, species
richness, bare ground, weedy species occurrences, plant density, etc) we can construct a
detrended correspondence analysis ((DCA), McCune and Grace, 2002) that ordinates
sample units and species in time. DCA can be used to examine the change in plant
communities over time, based on the time the wellsites were revegetated, how they
appear now and how they compared to our target, which is a reference area in the NWA.
The reference area can be from a number of transects in an undisturbed area of the
Suffield NWA. As an example (Figure 1) I introduce a DCA analysis from one of my
studies, where plant stands are grouped by year and 67% confidence ellipses are
produced using the using the JMP statistical package (SAS 2000).
23
Figure 1. Detrended Correspondence Analysis showing the plant community changes
from 2002 to 2006 from a revegetated wellsite in the Ribstone Creek Ecological Area
Control
At least with the DCA analysis, we have used known data that incorporates the range of
natural variability of the area through the year the data were collected. By evaluating the
trends, we can then derive some meaningful references as to where the mitigation
techniques are directing the dynamics of the plant stand with regard to the plant
community trajectories.
This type of cluster analysis follows a stepwise discriminant analysis, which is estimated
to be 95% accurate (Uresik, 1990). The use of ordination is sensitive to determine
changes in ecological stages (Uresik, 1990) and is precise, time-efficient and meet the
goals of resource managers, without the bias.
24
Ecosystems are diverse, complex and variable. The need for simplification and accuracy
is essential if we are to effectively remediate effects from industrial activities. Having a
suite of response/recovery indicators such as soil bulk density, organic matter content,
litter amount, presence of weeds, etc that reflects the facets of landscapes of the Suffield
NWA can lead to proper ecological risk assessment.
3.1.8 NWA’s Management plan
The Canadian Forces Base Suffield National Wildlife Area Management Strategy
describes the vision of the Suffield NWA (page 1, paragraph 5) and characterizes the
attributes and services of the NWA (page A-1). The plan appears to have been prepared
“on the fly”. I could not find more information to include benchmark data by which the
Suffield NWA can be sustainably managed, performance goal for the Suffield NWA,
measures and methods that were used to evaluate activities in the area. Examples: how
does the Base manage its own activities so that ecological integrity is maintained? What
methods are used to control weeds like Russian thistle and tumble weeds and invasive
species such as brome grass and crested wheatgrass? What research is ongoing in the
NWA and how do we communicate the results to all land users? How does DND deal
with issues arising in the NWA? How does DND elicit the land users, including
EnCana? What options are provided to the land users if a certain activity is deemed to
impact the landscapes? Example with setback distances. There will be times that there
will be no options due to the preservation of a critical habitat, but these approaches have
to be specified and communicated to all land users.
Many of the practices stated in the “Canadian Base Suffield Range Standing Orders”
(Chapter 7, Oil and Gas Activity Protocol) can be incorporated in the Suffield NWA
management plan. At least this way, all the information governing Suffield is contained
in one document and information can be easily located. It appears that there is too much
of a spider-web of quasi bodies (SEAC, SIRC, SGAC, SARA, etc). A properly develop
management plan can go a long way in de-conflict issues arising in the NWA and help
with mutual understanding.
25
3.1.9 Suffield Environmental Advisory Committee/Suffield Industry Range Control
Ltd.
The Suffield Environmental Advisory Committee (SEAC) was created to provide
advisory services to the Base Commander at CFB Suffield (page 2, paragraph.1) with
respect to environmental issues. The SEAC illustrates examples of concerns related to
the current oil and gas activities such as well in wetland (page 23, serial 21) proliferation
of trails; multiple trails; trail braiding (page 18, serial 16), crested wheatgrass along
wellsite access road (page 15, serial 10), concern over source of top soil (page 26, serial
27), hydrocarbon spills and effects near a wetland (page 25, serial 26).
Comprehensive monitoring is an essential function during the life cycle of a major
project such as the proposed shallow gas infill project to ensure mitigation measures as
proposed in the Environmental Effects Monitoring Plan are fully implemented and to
evaluate their effectiveness. There should also be severe and immediate consequences
implemented for project activities that do not respect the EEMP, such as cut concrete left
on site, garbage on site, hydrocarbon spill left on site, etc.
The SEAC’s commented that Alberta Environment has no statutory or regulatory role at
CFB Suffield (page 9, paragraph 1) and did not participate in the preparation of the
SEAC’s submissions. I believe that Alberta Environment’s participation is essential as
water permits fall under AENV jurisdictions. The Joint Review Panel (JRP) should ask
AENV how the proposed infill project would impact wetland conservation (re: water
extraction for the infill drilling). Jacques Whitford AXYS (May 2008) found that
disturbances may already affect many wetlands in the CFB Suffield (page3-80,
paragraph3) and that previous land use, namely agriculture and over-grazing, resulted
in range modification. Current land use is also influencing wetland health and function.
Additionally, Jacques Whitford AXYS (May 2008, page 3-32, paragraph 2) found 13
provincially/federally species at risk associated with various wetlands.
26
3.1.10 Cheryl Bradley’s Submission Regarding Footprint, Soils and Vegetation
A summary of the submission by Alberta Wilderness Association points to the fact that:
• Cumulative effects from increased development activity on the landscape are an
issue that must be addressed in land use planning. Also, that the decreased well
spacing for shallow gas development allowed by the EUB is of particular
concern, and should be addressed by SREM.
• The impact of the intensive level of activity for shallow gas development on
other traditional land uses, (i.e. livestock grazing) prairie recovery from the
impact of industrial disturbance and fragmentation, combined with current
stocking rates and grazing practices are unknown.
• Steep slopes, choppy sandhills and solonetzic or saline soils can be difficult to
reclaim and revegetate in the Dry Mixedgrass.
• There is a lack of field supervision of contractors by industry, resulting in
unnecessary impact and disturbance.
• Research and monitoring is required to accurately evaluate current minimal
disturbance procedures.
• There is insufficient research and information on reclamation and revegetation
strategies, and how they affect Species at Risk. It is recommended that
comparative studies be implemented to evaluate the effects of different
revegetation strategies on Species at Risk.
Many of these points are discussed in previous sections, namely under the Government
of Canada.
4.0 CONCLUSION
The CFB Suffield NWA is an ecologically unique area of mixed grass prairie that is home
to over 1,100 species of plants, mammals, birds, reptiles, amphibians and insects and of
which 14 species are listed as Species at Risk in Canada. In 2003, the CFB Suffield NWA
was declared a protected area to assert the Government of Canada’s intention to
preserve critical wildlife habitat and to protect Species at Risk.
27
After reviewing the submissions from the Government of Canada and the major
environmental groups, several concerns with regard to EnCana’s Environmental Impact
Statement (EIS) were raised. The main issues included the following:
1. Incomplete or insufficient information on the description of the proposed project
and related activities;
2. Incomplete information on the description and characterization of the baseline
information;
3. Uncertainties regarding environmental effects, predictions and analysis, and
cumulative effects;
4. Uncertainties regarding effectiveness of the measures to mitigate significant
adverse environmental effects and the timeline for ecosystem recovery;
5. Uncertainties regarding the effects of the project on Species at Risk (SAR) and
their critical habitat;
6. Incomplete information on alternative means analysis;
7. Key environmental effects of the project on CF Base activities, including
ecological research capacity and cattle grazing;
8. The NWA is a reservoir of a rare prairie habitat and associated biota; the last
remnant of mixed grass prairie in North America and implies that the proposed
gas infill project should not proceed.
The Department of National Defense (DND), especially as the land owner is overly
concerned of cumulative effects and wants to ensure that the capacity of the land, taking
into account military training, oil and gas, livestock/wildlife is not surpassed.
There are 14 species at risk in the Suffield NWA. A recovery plan for many of the species
identified within the NWA has to be developed, in order to abide by legislation as
described in Species at Risk Act (SARA). EnCana will have to apply for a permit before
any activities are conducted near a habitat that is deemed critical to the survival of
wildlife and plants. EnCana has to demonstrate that its activities will help with
conservation of these species and that their habitats are protected. It will be a challenge
to address the needs of all the species in the area during well installation and operation.
28
There is a huge problem with invasive plant and weedy species already existed in the
Suffield NWA. Disturbed areas associated with roads and trails are a prime contributor.
With the proposed gas infill project, there is the potential that increased traffic will
further exacerbate the situation through the dispersal of seeds.
Information contained in the Suffield Industry Range Control (SIRC) and Suffield
Environmental Advisory committee (SEAC) report raise some concerns with operational
issues, compliance and with inadequate vegetation on some sites. However, these
reports also point to some good examples of best practices and revegetation techniques
leading to some sites recovered to nearly pre-disturbed condition. There is also an
indication of EnCana’s willingness to cooperate with the CFB Base by funding several
research projects for a variety of wildlife studies in the NWA, including seed caches
created by Ord’s kangaroo rat and improved seed mixes. Reclamation practices, as they
relate to oil and gas activities, have evolved over the past three decades. These combined
with best practices (erosion control, weed management strategies and reduced well
visits through remote metering SCADA - Supervisory Control and Data Acquisition),
avoidance of critical habitat and obeying setback distances minimize effects from infill
drilling.
The DND management plan is deficient in many respects. It has a vision but no strategy
on how to achieve its goal – preserving the integrity of the Suffield NWA. To protect
diversity, there should be some desired outcomes and also the feasibility and
constraints. The Government of Canada is concerned with the integrity of the Suffield
NWA but have taken “a laissez faire approach” when it comes to management of
invasive species and weeds in the NWA.
There is indication that bench mark data were being collected by DND staff and that the
information could better be used to prevent impact, if it was made available to the land
users, including EnCana. It also appears there is a certain level of mistrust that has been
developing since 1999, which impedes protection of the Suffield NWA.
29
Mitigation should have taken into account the potential for restoration of the land to
pre-disturbance conditions. Depending on aspects and influences within the landscape
and given the engineering constraints, the PDA (Pre-development Site Assessment)
approach is justifiable and DND staff must participate in that process. Mitigation
measures will sensitize us to the “trade-offs” that come with industrial development,
whether military or oil & gas on this unique landscape.
With regard to seeding disturbed areas, wild harvest seed are sometimes not advisable
due to the difficulty in controlling weed seed content, given so many weed and invasive
species were identified in the Suffield National Wildlife Area”.
With regard to the effectiveness of the EIS, regular monitoring will be essential to
discover and rectify any impacts that were not predicted and to also ensure compliance
with restoration efforts and guidelines as set by SARA and DND.
On a final note, the Government of Alberta has stated that environmental liabilities from
mining and conventional oil recovery will not be passed on to future generations.
Protected areas such as the CFB Suffield NWA are designated so that future generations
can know the Majesty of the Earth as we know it today.
Recommendations
This is not to say the project is going to proceed, but should the project be undertaken,
the following recommendation might be useful:
1. Constrained areas such as steep gullies and slopes are avoided as they can be
difficult to reclaim.
2. Setback distances so as to minimize project activities on species at risk be
adhered to although an estimated 50 to 100 preliminary well locations are
predicted to fall within the specified 100m buffer.
3. Analysis on gaps indentified in the EIS to be completed in order to have an
understanding of the level of impact already occurring in the NWA.
30
4. Habitat loss and fragmentation have large impacts on wildlife and these should
be minimized wherever possible.
5. Appropriate management plan in place to ensure the protection of ecosystems
within the NWA to ensure gas extraction activities do not impact wildlife, and
their habitats.
6. Loss of habitat critical to Species-at-Risk should not be permitted.
7. To reduce cumulative effects of industrial activity, it may be useful to require
that abandoned or decommissioned sites are restored before additional sites can
be established.
8. A simplified quasi process to handle issues with operating in the NWA.
Sometimes the role of SEAC, SIRC and SGAC are not clear.
9. There should be a close scrutiny of all project activities as it appears that
historically there has been a lack of environmental inspectors to monitor
environmental effects.
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