Encana's shallow gas infill development project in the Suffield National Wildlife Area. A presentation to the Joint Panel Review.

The Environmental Impact Assessment prepared by Encana�s consultants is incomplete in many respects. These include:

� Narrow definition of "valued ecosystem components". Focus is on vertebrates with no attention paid to either non-vertebrate biota or to ecological processes.

� Narrow definition of "time". The comparison of the shallow gas infill is that of the current landscape. No effort made to compute the "range of natural variability" of VECs in a pre-disturbance landscape.

� Complete omission of anthropogenic edge, or the concept of edge buffering.

� No effort made to quantitatively explore the consequences of "best practice" options, in comparison to business as usual activities.

� No attempt to quantify the "key uncertainties" of the shallow gas play in relation to defined VECs.

This concerns expressed above are confirmed by the absence of any simulation modeling work intended to track the arrival, persistence, and reclamation of all relevant footprints associated with the shallow gas play within the NWA, or the effects of these simulated anthropogenic features on a set of valued ecosystem components (VECs). The consultants state that there are no significant cumulative effects of anticipated landuses on several key VECs, yet present no simulation data to support these conclusions.

The argument for this key omission is the implementation of mitigation measures and avoidance of sensitive environments. Given the magnitude of both linear and polygonal features on the landscape today (~3 km/km

2) and the anticipated growth of linear feature density to 5 km/km2 (once the proposed infill phase is completed) the possibility that the historic or proposed Encana landuses do not have a profound effect on key ecological variables is zero.

A key weakness of the EIA is its spatial focus on the direct footprint of anthropogenic features, and its relative inattention to indirect effects of landuse features. To robustly quantify the effects of this gas infill play on ecological processes, it is essential to consider the buffering effects on VECs. The direct footprint of landuse on this landscape is generally in the 2-2.5% range, but its spatial influence can extend to the 100% range for those ecological processes or wildlife species influenced by anthropogenic features within 500 m of linear or polygonal features. The EIA does adopt a constraint mapping technique, but generally uses an arbitrary buffer width of 100 m, though numerous VEC are adversely affected for distances of several hundred meters (for example, pronghorn can be spatially displaced within 500 m of some features of the oil and gas industry; see Tobin Seagal text within EIA). Further, the EIA indicates that where constraint mapping could not accommodate the desired gas extraction trajectories using exclusion and avoidance zones, then anthropogenic features were allowed to fall within these zones. This EIA needs to quantify the extent to which the ecological integrity of VEC are compromised by the "actual" proposed spatial and temporal trajectory of each landuse footprint associated with historic and proposed oil and gas activity.

To assist the impact assessment process, the EIA needs to provide indicator performance reference points. The EIA contains much detailed information that describes the current "static" landscape, but generally ignores the temporal variability that characterizes all ecological systems. Whether discussing pronghorn, sage grouse, exotic invasive plants, bare ground, and other VECs, a useful EIA needs to inform the reader about the "range of natural variability (RNV)" for each VEC, so that the RNV can serve as a reference point to allow the reader to determine the extent to which indicator performance is acceptable or unacceptable.

The construction and persistence of linear and polygonal features is a key element in the risk equation for all VECs. The EIA refers to the reclamation of these features, yet does not provide quantitative insight into the probability of achieving the intended reclamation trajectory, or the key uncertainties that might complicate the reclamation process.

Based on the above commentary, it is my opinion that the EIA could be significantly improved by incorporating the following additional elements:

� Tracking both the direct and indirect (buffered) footprint of each footprint type throughout the full lifespan of the gas play in NWA.

� Assessment of the uncertainty of performance of reclamation trajectories.

� Assessment of the uncertainty of invasion of exotic plants, and the anticipated expansion trajectories of invasive plants off all relevant anthropogenic features.

� Comparison of performance of key VECs to Range of Natural Variability for each of the first pulse (historic) and second pulse (proposed) of gas development. It makes no sense to compare the performance of VECS to the proposed infill relative to the current situation. A proper assessment of cumulative effects must consider the full set of actions and anthropogenic features of the full shallow gas play.