encana shallow gas infill development in ir due date · ditcher (as opposed to the plow) is the...

EnCana Shallow Gas Infill Development in the CFB Suffield National Wildlife Area

IR Due Date:

CEAA File #05-07-15620 August 2nd, 2007 IR Requested By: Alberta Wilderness Association IR No.

CEAA-EIS-004 #AWA – 9 - A

Reference:

Preamble:

Request: Identify all mineral disposition holders in project area and surrounding area on a map.

Response: Please see the map below.


IR Due Date:

CEAA File #05-07-15620 August 2nd, 2007

EnCana Shallow Gas Infill Development in the CFB Suffield National Wildlife Area CEAA File #05-07-15620

IR Due Date: August 2nd, 2007

IR Requested By: Alberta Wilderness Association IR No. CEAA-EIS-004 #AWA – 9 - A

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IR Requested By: Alberta Wilderness Association IR No. CEAA-EIS-004 #AWA – 9 - A

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IR Due Date:


CEAA-EIS-004 #AWA – 34-B

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Reference:

Preamble:

Request: Section 5.1, volume 3, states that “buffers may be reduced”. Please provide the criteria for determining when buffers can be reduced and examples of when this would be done.

Response: See the response to Terr 256a for the decision-making process for Ord’s Kangaroo Rat, Terr 255 for Sharp-tailed Grouse, Gen 33 for the Burrowing Owl, and Terr 27 for wetlands.


IR Due Date:


CEAA-EIS-004 #AWA – 61- C

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Reference:

Preamble:

Request: The Exec Summ p.iii states, “Environmental baseline conditions were defined through a review of a considerable amount of baseline information, including a large amount of data from EnCana’s long-term operations in the area including sections up to 16 wps”. Please provide Environmental Overviews, PDAs or Environmental Assessments prepared by consultants to EnCana for CFB Suffield.

Response: The EIS contains sufficient information to determine the environmental effects of the

Project, including field studies on vegetation and wildlife. The AXYS report is available on the Canadian Environmental Assessment Registry at: http://www.ceaa-acee.gc.ca under document number 24.

http://www.ceaa-acee.gc.ca/

http://www.ceaa-acee.gc.ca/


IR Due Date:

CEAA File #05-07-15620 August 2nd, 2007 IR Requested By:Alberta Wilderness Association IR No.


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Reference:

Preamble:

Request: Provide all noncompliance reports or records of EnCana or its successors in the Suffield area.

Response: EnCana assumes this request is in relation to the environment. A review of EnCana’s records discloses that gas operations on CFB Suffield since the formation of EnCana in April 2002 has not had an issue/event resulting in an EUB high risk enforcement or Alberta Environment violation.


IR Due Date:


CEAA-EIS-004 #AWA – 64 - B

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Reference:

Preamble:

Request: Was the information from PDAs used in the EIS and, if so, how?

Response: PDAs are done in the spring/summer prior to drilling; therefore, the information is not yet available and was not incorporated into the EIS.


IR Due Date:



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Reference:

Preamble:

Request: What is EnCana’s understanding of SEAC’s role?

Response: EnCana’s interpretation of SEAC’s role is that it is an organization comprised of expert regulators and advisors who are the parties best suited to determine environmental issues at CFB Suffield, including the NWA. The Base Commander may only give or refuse approval of any activity, upon the recommendation of SEAC. EnCana, and the federal Crown (including DND) are bound by the 1975 Access Agreement. The 1975 Access Agreement ensures that environmental checks and balances will be administered by SEAC. SEAC is the appropriate independent authority to ensure environmental protection at the Base having the expertise to interpret applicable policy and guidelines. SEAC consists of one representative from Environment Canada, one from the EUB and one from Alberta Environment to make recommendations to the Base Commander on environmental issues.


IR Due Date:



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Reference:

Preamble:

Request: How was deemed lease area determined? How does it compare with actual disturbance?

Response: Deemed leases are 100 metres by 100 metres centered on the well. Refer to EUB Directive 36, Section 25 and Oil and Gas Conservation Regulations, Section 8.135. The actual disturbance footprint is approximately 30 metres squared to allow space for the well to be tied into the gas gathering system.


IR Due Date:



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Preamble:

Request: In the Exec summary p.ii EnCana suggests it will use the same techniques that have been “successfully” used for other development activities on native prairie including well sites located to reduce environmental effects, reduced footprint of wells and pipelines and innovative reclamation practices. What techniques is EnCana referring to and please provide evidence that these techniques were successful.

Response: The techniques EnCana is referring to is detailed within the Preconstruction Activities

Section (section 2.2.1) and the Construction Section (section 2.2.2) of the Project Description (Volume 1). The majority of these techniques are industry standard techniques that are successfully used throughout the prairie area under the regulatory guidance of Alberta Environment, Alberta Sustainable Resource Development, and the Energy and Utilities Board. EnCana conducted field research on the environmental effects of infill drilling on vegetation and wildlife. The results of the vegetation sampling program are discussed in Volume 3, Section 3.6.2. The wildlife field study results are discussed in Volume 3, Section 5.6.5. The field studies included sites where essentially the same techniques that are proposed were utilized.


IR Due Date:


CEAA-EIS-004 #AWA – 93- A

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Reference:

Preamble:

Request: At Volume 1 2-18 EnCana provides that ploughing will be used to install the pipelines where feasible. In what circumstances will it be not feasible. If it is not used will the other proposed techniques alter the predicted disturbance footprint and environmental assessment and if so, how?

Response: Feasibility on a site by site basis will be determined by the PDAs.

Plowing will not be used when the ground conditions are deeply frozen and the moisture content is high with non-sandy soil types. In these conditions, the chain ditcher (as opposed to the plow) is the optimal pipeline equipment. It will not alter the predicted footprint because, in the overall assessment, it was assumed that chain ditching would be used for all pipelines (as it has a larger predicted footprint).


IR Due Date:



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Preamble:

Request: What is the amount of stripping required for this project? (Vol 1, p.2-18) to 2-4 m (Vol 1, p.2-10).

Response: The amount of stripping will be confirmed upon completion of the PDA. PDAs will

determine the number of wells approved in an area and the pipeline requirements to meet the anticipated volume produced. Generally, between 15-30 m² of stripping is required at each of the wellsite and tie in point.


IR Due Date:



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Preamble:

Request: Vol 3, p.2-28 & 29 states that access routes will only be placed on well-drained soils on level, undulating or gently-sloping terrain with <15% gradient and to avoid crossing dunes, gravel plains and inclined fans and terraces. Will this occur in all instances and if not, in what circumstances will it not be followed and how much land will be taken up by these alternate routes.

Response: The final decision on access routes will be made during the PDA process, and as such, EnCana

cannot yet determine the number of possible exceptions. A professional biologist, botanist and construction representative will be involved (and may involve other specialists as required) in creating site specific mitigation of environmental effects for exceptions identified during the PDA. However in all cases, based on the results of the PDA, the route with minimum environmental effect will be selected.


IR Due Date:



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Reference:

Preamble:

Request: The EIS sets out techniques in unusual circumstances such as a low-volume, unsurfaced roads where gradient is >25% or flow path is >30 m (Vol 3, p.2-28 & 29), culverts at ephemeral drainages (Vol 3, p.4-17), and the placement of gravel in tracks in high traffic volume areas where there is erosion, braiding and weed accumulation (Vol 3, p.4-17). Estimate the number of situations when this will be needed and the potential environmental effects? Have these measures been used elsewhere and evaluated? Please provide documentation.

Response: Please see the responses to AWA 97 and Gen 76.

The environmental effects of the Project on vegetation are assessed in Volume 3, Section 3.


IR Due Date:


CEAA-EIS-004 #AWA – 108- B

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Reference:

Preamble:

Request: EnCana states that construction activities will avoid sensitive times for burrowing owl and other sensitive species (Vol 1, p.1-3) When is that and how will it be accommodated?

Response: Mitigation for wildlife VECs is presented in Section 5.8.2.

It will be accommodated by restricting drilling and completion to October 15 to April 15; pipeline construction to October 1 to April 15; and pipeline construction from October 1 to April 15, will be Spyder Plow only and restricted to the western portion of the NWA. The sensitive/breeding time for burrowing owls is in late March or early April. During that time period, EnCana will maintain a 500m buffer for construction activities.


IR Due Date:



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Preamble:

Request: How will the proponent deal with spreading of invasive species now in CFB Suffield and in the NWA which can be further mobilized by industry vehicles once inside the NWA?

Response: Invasive species listed as Restricted or Noxious by the Alberta Weed Control Act will be controlled where they occur on right-of-ways provided an evaluation does not indicate the invasion is the result of a greater problem off right-of-ways. In the event the restricted or noxious species are in greater abundance off right-of-way, EnCana commits to working collaboratively with DND to meet the obligations under the Act. EnCana will also conduct its activities to ensure the mobility of invasive species not listed by the Weed Control Act is minimized. Constraining construction activities to the dormant season will minimize mobility as most invasive plants will have dropped their seed prior to construction. Vehicles will arrive in a clean state with particular attention being paid to the undercarriage of the vehicles. Disturbances will be reclaimed promptly to ensure minimal opportunity for the establishment of invasive plants. All right-of-ways will be subject to EnCana’s Post Construction monitoring plan where invasive species will be identified and follow up actions taken. Further detail is outlined in the Undesirable Vegetation Control During Construction section of the EPP (Vol. 1, Section I.5.9, pg I-26) and the Operations and Maintenance section of the EPP (Vol. 1, Section I.6.11, pg I-42).


IR Due Date:



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Preamble:

Request: How does EnCana plan to survey for rare vegetation communities (detailed methodology)?

Response: See the response to Terr 189a.


IR Due Date:



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Reference:

Preamble:

Request: EnCana states that “Pre-planning of preliminary lease and pipeline locations/routes to avoid habitats with high rare plant occurrence potential where possible” (Vol 3. p.3-27). How will EnCana define and locate/map these habitats?



IR Due Date:



Page 1

Reference:

Preamble:

Request: EnCana states that it will do “Seasonally appropriate field surveys during PDAs, and soils handling to locate and avoid rare plant locations”. (Vol 3. p.3-27) Provide details of how does EnCana plan to survey for these (detailed methodology)



IR Due Date:



Page 1

Reference:

Preamble:

Request: What comprises a PDA?

Response: Please see Volume 1, Section 2.2.1. and the response to Terr 96.


IR Due Date:


CEAA-EIS-004 #AWA – 124 -A

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Reference:

Preamble:

Request: When is EnCana going to conduct surveys for rare species and rare communities i.e. during what months and over how many years?



IR Due Date:



Page 1

Reference:

Preamble:

Request: What are EnCana’s goals and responsibilities with respect to reclamation of these past disturbances in the NWA?

Response: Please see EnCana’s response to IR Gen-11-A for a complete discussion of EnCana’s reclamation legal commitments. EnCana’s goal is to continue the successful shared use of the land that has characterized the NWA during the last 30 years – such as the creation of the NWA as an area under the Canada Wildife Act with the support of all parties – and, upon completion of the extraction of the resource, return it to an equivalent land capability. This goal will be met by continuing practices and implementing mitigation measures which minimize EnCana’s impact on native prairie and wildlife during this time. These measures will be reflected in the final version of the Environmental Protection Plan (“EPP” – a draft version is presented in Appendix I of the Environmental Impact Statement) and their effectiveness monitored and adaptively managed with the implementation of the Environmental Effects Monitoring Plan (“EEMP”).


IR Due Date:


CEAA-EIS-004 #AWA – 131 - C

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Reference:

Preamble:

Request: Which regulators govern EnCana’s activities including the reclamation in the Suffield NWA and which legislation governs reclamation?

Response: Please see the responses to General 11, Terrestrial 47 and Terrestrial 55.

encana shallow gas infill development in ir due date · ditcher (as opposed to the plow) is the...

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