ENCANA SHALLOW GAS INFILL DEVELOPMENT IN THE CFB SUFFIELD NATIONAL WILDLIFE AREA CEAA FILE #05-07-15620

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

Responses to IR Requested of Whidden Environmental Ltd (Written Formal
Hearing 002, filed February 18, 2008) by EnCana Corporation (filed March 26,
2008)

May 23, 2008

IR #1

Reference: Page 10, Paragraph 4.
Preamble: “It appears that the information provided lacks basic scientific principles.
Such principles were not developed to be only used by academics. These principles exist
to facilitate the understanding of nature in general and of the effects that industrial
activities cause, in particular. Without such information the significance of impact
cannot be determined.”
Request: The statement has no support or explanation. Provide detailed explanations of
what, specifically, was not done, and provide specific evidence to support why it is
required.

Response:
The question of whether or not the information requested by Government of Canada
(GOC) is required for the JRP to fulfill its mandate (for wildlife management) needed to
be addressed in Wildlife Management Report #1 and was discussed, in part, with
comments for each of GOC’s points in the Summary Section of Annex 2, page 20. Alone,
the statement referenced by EnCana, which was part of a larger paragraph, lacks
context.    The statement is supported by information found before and after the
statement, which is reproduced below for the benefit of EnCana. The selected sentences
are highlighted in green. Please refer to the entirety of Section 3.1.1 – JRP Mandate and
Wildlife (Wildlife Management Report #1) for further explanation of the selected
statement contents and context.

GOC point 2 (Annex 2, page 20), as referenced and discussed in Wildlife management
Report #1:
 2. undefined project parameters and assessment of environmental impacts, including
 locations of infrastructure, waste disposal, fragmentation, wetlands, invasive species,
 and Species at Risk;
Species at risk (SAR) have not been dealt with adequately. The GOC’s request to provide
detailed information on all species listed under SARA Schedule 1 is justified (see also
JRP IR 17). The potential impacts on all SAR must be detailed in the impact assessment,
the potential habitats of SAR and their residences that may be disturbed must be
determined. EnCana should be expected to provide a good understanding, including
validated habitat models, of the potential for any SAR to be disturbed by the proposed

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project. It appears that the information provided lacks basic scientific principles. Such
principles were not developed to be only used by academics. These principles exist to
facilitate the understanding of nature in general and of the effects that industrial
activities cause, in particular. Without such information the significance of impact
cannot be determined. The GOC is justified in requesting this information without
which the JRP may not be able to fulfill its mandate.
However, EnCana’s argument that specific residences or critical habitat will be found
and evaluated through pre-disturbance assessments (PDA) is sensible (see also JRP IR
25,26,28,37,43). This is because the last details of engineering design, including
footprints, schedules, and sensory disturbance (i.e. traffic and construction details) are
often not finalized until days before the actual activity. For that reason, it does not make
sense to search for nests, dens, or microhabitats in a location that may never be
disturbed or for species which are not present during the season of the project activities.
The PDA approach by EnCana is therefore defendable, provided that EnCana has a clear
and approved plan of how and when PDAs will be done. The plans must include terms
and conditions of what EnCana would be required to do if SAR critical habitat or
residences were found. EnCana must consult with resource agencies and seek their
guidance on how surveys are to be conducted and what to do if SAR habitat or
residences are found. This consultation with agencies appears to have been weak thus
far and it must be done (see also JRP IR 28 and 32). Currently not all SAR in the Suffield
NWA area are protected by a recovery plan (see Table 1 and Section 2.13 above); hence,
the definition of critical habitat must still be developed by resource agencies.
The conceptual plan provided by EnCana is likely sufficient to assess the generalized
impacts, provided that the underlying data and information is sufficiently rigorous. That
is, for example, if it is known that 100 ha of a given habitat will be disturbed, then minor
changes in project design of 2 or 3 ha will not change that assessment in terms of the
severity of the impacts. The GOC’s request is therefore only relevant for major changes
that include increased footprints, durations, seasons of activities, or changes in
disturbance of specific habitats (critical habitat for SAR) or sensitive areas. Other minor
changes and the exact disturbance of any one residence can be dealt with by the PDA
process as discussed above. The PDA approach is therefore justifiable and the JRP will
be able to fulfill its mandate, provided that conditions are stipulated and review and
approval mechanisms in place that accept the PDAs as part of follow-up programs. The
GOC’s request to develop detailed Environmental Effects Monitoring Plans (see JRP IR
38, 42) is therefore justified.

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IR #2

Reference: Page 12, Paragraph 3.
Preamble: “EnCana’s apparent reluctance to conduct adequate statistical analyses,
including the power analyses and consideration of sample sizes requested by GOC (see
also JRP IR 17 and 27) is disappointing and disenchanting. If the lack of proper analysis
is “typical” for Canadian environmental assessments as EnCana argues, then the typical
assessment is inadequate indeed.”
Request: Please provide examples of the use of power analysis for wildlife and/or
vegetation studies in EIA in Canada.

Response:
The question about power analysis was regarding the reason why it was not conducted,
not if “typical” analysis was done for the Suffield NWA EIS, which was for an arguably
“atypical” area in Canada. It has been recognized for some time that power analysis is a
useful tool that could be used in environmental monitoring (i.e., Green 1989) and has
been used in a wide-variety of studies examining the detection of environmental
impacts for more than a decade (i.e., Osenberg et al. 1994). Power analysis can either be
before (a priori) or after (a posteriori or post hoc) data is collected. A priori power
analysis is conducted prior to the conducting of research and is typically used to
determine an appropriate sample size to achieve adequate power. Post-hoc power
analysis is conducted after a study has been conducted and uses the obtained sample
size and effect size to determine what the power was in the study assuming the effect
size in the sample size is equal to the population effect size.

In theory, EIAs and monitoring programs should have statistically-based study designs
which would test some specific null hypothesis. Power analyses can be applied a priori
in the design phase or a posteriori (post-hoc), in the interpretation of the results
(Antcliffe 1999). A power analysis can be a useful tool when designing field survey
protocol because it can aid in estimating an adequate sample size that will allow the
statistical analysis to have sufficient power. Power is important in providing reliable
outcomes to questions that the researcher is investigating. With insufficient power, a
treatment could be effective but because the size of the sample may be too small, no
outcomes may be detected (Type II error). Conducting a power analysis to test whether
the sample size was adequate to detect any effects can highlight whether the researcher
is confident in the conclusions.

In “typical” EIAs, sample sizes are often set based on sampling costs, access issues or
other logistical constraints associated with the proposed development project which can
lead to low-power studies that are unlikely to detect large ecologically important effects
(Antcliffe 1999). However, there few projects are implementing these techniques:

In Canada:

Imperial Oil Resources Ventures Limited, 2004. Environmental Impact Statement for the
Mackenzie Gas Project, Volume 3: Biophysical Baseline. Part E – Terrestrial Resources:
Wildlife, Submitted to the National Energy Board and the Joint Review Panel.

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In The United States of America:

Johnson, S.R., L.E. Noel, W.J. Gazey and V.C. Hawkes. 2005. Aerial monitoring of
marine waterfowl in the Alaskan Beaufort Sea. Environmental Monitoring and
Assessment 108:1-43.

Johnson et al (2005) designed and tested a monitoring protocol for marine waterfowl in
the central Alaskan Beaufort Sea. They found no evidence of change in duck densities
due to disturbance from nearshore petroleum exploration and coastal development.
They used power analyses to test whether the sampling and analysis procedures were
adequate to detect long term trends in duck density.

Other examples of impact assessments in the US can be found in:
Antcliffe, B.L. 1999. Environmental impact assessment and monitoring: the role of
statistical power analysis. Impact Assessment and Project Appraisal 17 (1): 33–43.

International:

Harbour Area Treatment Scheme Environmental Impact Assessment Study for the
Provision of Disinfection at Stonecutters Island Sewage Treatment Works –
Investigation. Final EM&A Manual. 2007. Maunsell Consultants Asia Ltd, Hong Kong

The monitoring program for the EIA Study for the Provision of Disinfection Facilities at
Stonecutters Island STW – Investigation required a statistical power analysis to be
conducted after the data of the first session of baseline sediment quality monitoring had
been obtained, in order to verify and review the number of replicates required for
subsequent baseline operation phase monitoring sessions

Regardless, even if power analysis had never been used in EIA in Canada, due diligence
and environmental stewardship by EnCana could be demonstrated through conducting
power analysis. In turn, this could prove to alleviate the uncertainty that stakeholders
have with the wildlife and/or vegetation data gathered.

As Peers (1996) states:

“When planning a survey or an experiment a common problem for researchers is the
determination of sample size or number of subjects in experimental groups. It is possible
to estimate the number of subjects required either in a sample survey or in experimental
design so that sample or treatment differences would be detected at a specified
significance level. The significance level of a statistical test is the likelihood of
concluding there is a difference (rejecting a hypothesis of no difference) when in fact
there is a difference (the hypothesis of no difference is refuted). The estimation of sample
size is achieved through statistical power analysis. Given certain assumptions, a
statistical test is said to be powerful if it is able to detect a statistically significant
difference should one exist. The point of doing a power analysis for a research plan
based on a particular sample size is that if the design turns out to have insufficient

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power, that is one is unable to detect any statistically significant difference, then the
researcher can revise the plan. One option would be to increase sample size. As little can
be done after data has been collected, consideration of sample size and statistical power
is crucial at the planning stage.”

As such, and given the ecological significance of the Suffield NWA, it would have been
nothing short of basic due diligence on the part of EnCana to conduct a priori power
analysis. Post hoc power analysis could be conducted to demonstrate the power of the
various analyses provided by EnCana with respect to wildlife in the Suffield NWA.
However, there are arguments that confidence intervals are a more useful tool in lieu of
post hoc power calculations in certain instances (Colegrave and Ruxton 2003, Steidl et al.
1997). To date, neither has been apparently utilized in the wildlife components of the
EIS. As such, confidence in the information presented (data, analyses, etc.) on impacts
to, and effects on, some wildlife species remains low.

References Cited:

Antcliffe, B.L. 1999. Environmental impact assessment and monitoring: the role of
statistical power analysis. Impact Assessment and Project Appraisal 17 (1): 33–43.

Colegrave, N. and G.D. Ruxton. Confidence intervals are a more useful complement to
nonsignificant tests than are power calculations. Behavioural Ecology 14(3):446-47.

Green, R.H. 1989. Power analysis and practical strategies for environmental monitoring.
Environmental Research 50: 195-205.

Harbour Area Treatment Scheme Environmental Impact Assessment Study for the
Provision of Disinfection at Stonecutters Island Sewage Treatment Works –
Investigation. Final EM&A Manual. 2007. Maunsell Consultants Asia Ltd, Hong Kong.

Imperial Oil Resources Ventures Limited. 2004. Environmental Impact Statement for the
Mackenzie Gas Project, Volume 3: Biophysical Baseline. Part E – Terrestrial Resources:
Wildlife, Submitted to the National Energy Board and the Joint Review Panel.

Johnson, S.R., L.E. Noel, W.J. Gazey and V.C. Hawkes. 2005. Aerial monitoring of
marine waterfowl in the Alaskan Beaufort Sea. Environmental Monitoring and
Assessment 108:1-43.

Osenberg, C.W., R.J. Schmitt, S.J. Holbrook, K.E. Abu-Saba and A. R. Flegal. 1994.
Detection of Environmental Impacts: Natural Variability, Effects Size, and Power
Analysis. Ecological Applications 4(1): 16-30.

Peers, I. S. 1996. Statistical Analysis for Education and Psychology Researchers: Tools for
researchers in education and psychology. Falmer Press, Taylor and Francis Inc. and 436
pages.

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Steidl, R.J., J.P. Hayes, and E. Schauber. 1997. Statistical Power Analysis in Wildlife
Research. The Journal of Wildlife Management 61(2): 270-279.

IR #3

Reference: Page 21, Paragraph 2.
Preamble: “Habitat fragmentation was not assessed because it was not considered to be
a key issue for the project as disturbance from pipelining would be < 2m for well tie-ins
and < 4m for loop lines. These widths were considered insufficient to result in a habitat
fragmentation effect (Section 5, p. 5-43). However, these claims remain unsubstantiated
and lack any provision of rationale related to the potential impacts to all VECs (large
and small) from linear disturbances < 4m in width on the ecological integrity of the
NWA. Any fragmentation effect could be felt more by smaller wildlife species (i.e.,
amphibians, snakes, arthropods).”

Request: Provide the scientific evidence (i.e. peer-reviewed journal articles, technical
reports) to support the last statement of the preamble specific to plowed-in shallow gas
pipelines and associated access trails for the purposes of infill drilling.

Response:
It is not clear why the peer-reviewed journal articles or technical reports need to
specifically apply to plowed-in shallow gas pipelines and associated access trails for the
purposes of infill drilling. The rationale behind the absence of any fragmentation
assessment was questioned in Wildlife Management Report #1. Please note that the last
sentence reads “Any fragmentation effects could (emphasis added) be felt more by
smaller wildlife species (i.e., amphibians, snakes, arthropods.” It would be hoped by all
stakeholders that EnCana would have considered the possibility of fragmentation effects
to smaller wildlife species given the significance of the Suffield NWA. To date, this is
not apparent in the EIS materials reviewed by Whidden Environmental. Arthropod
assemblages and pipeline developments have been studied in the boreal forest in
Alberta (Blake 2006). Vegetation and microclimate factors potentially impacting
arthropods were not apparently examined in the EIS. Although it is not the
responsibility of Whidden Environmental to guide EnCana through due diligence
activities related to wildlife issues scoping, the following references, a very small
representation of what exists, are pertinent:

Blake 2006. Arthropod Assemblages and Pipeline Development: Implications For Forest
Songbirds? Department of Renewable Resources, University of Alberta. Unpublished
Report, 27 pages.

Cushman, S.A. 2006. Effects of Habitat Loss and Fragmentation on Amphibians:
A Review and Prospectus. Biological Conservation 128: 231-240.

Mader, H.J., C. Schell and P. Kornacker. 1990. Linear Barriers to Arthropod Movements
in the Landscape. Biological Conservation. 54: 209-222.

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Richardson, M.L., P.J. Wetaherhead and J.D. Brawn. 2006. Habitat Use and Activity of
Prairie Kingsnakes (Lampropeltis calligaster calligaster) in Illinois. Journal of
Hepetology 40(4): 423-428.

Shine, R., M. Lemaster, M. Wall, T. Langkilde and R. Mason. 2004. Why did the Snake
Cross the Road? Effects of Roads on Movement and Location of mates by Garter Snakes
(Thamnophis sirtalis pareietalis). Ecology and Society 9(1): 9. [online] URL:
http://www.ecologyandsociety.org/vol9/iss1/art9

IR #4

Reference: Page 24, Paragraphs 4 and 5
Preamble: “It is concluded in the EIS that pronghorn antelope appear to feel more
secure and less likely to expend energy fleeing at distances >150 to 200m from survey
vehicles. Most pronghorn antelope that were observed (72%) did not run away from the
survey vehicle and pronghorn only ran away from the vehicle when the distance was <
103 m (Volume 3, Section 5.1, p. 5-2). No pellet group surveys were conducted to gauge
aspects of habitat use and relative distance from roads and trails.
Prey (which can include pronghorn antelope) responds to generalized threatening
stimuli even when the source may be new to their evolutionary history such as vehicles
(Frid and Dill 2002). Even if these sources may be more or less non-lethal, individuals
should still exhibit anti-predatory behaviour. Considering fitness costs, if individuals
overestimate the risk associated with the disturbance, they may reduce their foraging for
vigilance which would have a lesser fitness cost compared to if they underestimated the
risk that led to mortality (Bouskila and Blumstein 1992).”
Request: It is suggested that behavioural effects reduce reproductive fitness through
increased vigilance and reduced foraging. Please provide the specific scientific evidence
that behavioural effects resulting from shallow gas infill drilling activities (e.g. drilling)
lead to decreased survival, fitness, and reproduction in antelope.

Response:
The paragraphs selected by EnCana should be reviewed in the context of Wildlife
Management Report #1 – Section 3.2.5.1 Disturbance Response [for pronghorn antelope]
in its entirety. Several pertinent references are provided in this Wildlife Management
Report #1 Section.
It appears that EnCana has only mentioned one of several anthropogenic disturbances
that could arise from shallow gas infill drilling; these include maintenance activities
where personnel must access the additional proposed wells and pipelines via roads and
trails. Drilling is but one activity associated with the proposed project. Again, it is not
clear why “specific scientific evidence” needs to pertain to shallow gas infill drilling
activities; there when discussing what disturbance (via noise, increased vehicle traffic
and direct land occupation) could do to pronghorn antelope survival, fitness (which is a
nebulous term) and reproduction in antelope. This would be analogous to adding the
caveat of “pronghorn antelope in an NWA”. There are myriad studies on anthropogenic
disturbances and human-antelope interactions and it is not the mandate of Whidden

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Environmental Ltd to provide an annotated bibliography to EnCana. However, some
useful references, not necessarily referenced in Wildlife Management Report #1, include:

North Dakota State Management Guide for pronghorn antelope - 2006:
URL: http://gf.nd.gov/multimedia/pubs/prong-mgmt-guide-pt8.html

Sawyer, H., F. Lindzey, D. McWhirter and K. Andrews. 2002. Potential effects of oil and
gas development on mule deer and pronghorn populations in western Wyoming.
Transactions of the North American Wildlife and Natural Resource Conference. 67: 350-
365.

IR #5

Reference: Page 27, Paragraph 5
Preamble: “In addition, the summer RSF for pronghorn antelope in the EIS did not use
vegetation data per se in any analysis, but rather ecological range site information.
Admittedly, it is not clear if the use of ecological range site was an appropriate surrogate
for vegetation data. Pronghorn antelope are an obligate grassland species and previous
research suggest that pronghorn significantly favour certain vegetation types. If
pronghorn distribution was influenced mainly by forage distribution, then pellet
distribution should follow the resources. Gavin and Komers (in press) found that
although high traffic roads had higher shrub coverage, which would indicate quality
foraging habitat, pellet densities were lower near (200-400m) high traffic roads
compared to other roaded areas.”
Request:
    a) Is the reference to Gavin and Komers (in press) referring to:
                    i. Gavin, S.D. and Komers, P.E. 2006. Do pronghorn (Antilocapra
                        americana) perceive roads as a predation risk? Can. J. of Zool. 84,
                        1775-80.
                   ii. If not, please provide the appropriate citation.
    b) Please explain how the results of that study can be compared to the summer RSF
        findings regarding well density.

Response:

   a) Yes, the citation should be:
      Gavin, S.D. and Komers, P.E. 2006. Do pronghorn (Antilocapra americana)
      perceive roads as a predation risk? Can. J. of Zool. 84, 1775-80.

   b) The point of discussing the work by Gavin and Komers (2006) was to highlight
      the potential importance of vehicle disturbance to pronghorns, not compare this
      work directly with the summer RSF findings in the EIS (the merits of the latter
      are also discussed in Wildlife Management Report #1). Disturbance of pronghorn
      could potentially occur throughout the summer and winter with increased
      vehicle use of existing roads, trails and required new access trails. Disturbance

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associated with vehicles could potentially increase during drilling and routine
maintenance activities (i.e., swamping) and it is the opinion expressed in Wildlife
Management Report # 1 that there needs to be additional work to better
understand the potential impacts to pronghorn during the summer and winter
months.

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