Information Letter How to Prepare the Environmental Assessment Required Pursuant to the Canadian Environmental Assessment Act

Transcription

1 Indian Oil and Pétrole et gaz des Gas Canada Indiens du Canada Suite 100, 9911 Chula Boulevard, Tsuu T ina, AB T2W 6H6 Tel.: (403) Fax: (403) March 2000 Your file - Votre référence Our file - Notre référence E-5010 Information Letter How to Prepare the Environmental Assessment Required Pursuant to the Canadian Environmental Assessment Act Note: This Information Letter was issued as IOGC IL It supercedes IOGC IL95-1. PURPOSE The purpose of this Information Letter is to provide guidelines for those completing environmental assessments for oil and gas projects being conducted on Indian Lands. More specifically, the Information Letter provides details of the information requirements of IOGC in order to adequately screen an environmental assessment. The following information requirements apply to all applications for oil and gas exploratory licences, surface leases and rights of way agreements on Indian Lands in Canada. In the past, there has been a range in the quality of the information contained in environmental assessments. This has resulted in delayed approvals and has created an unnecessary work load. In order to expedite assessments, quantitative data must be collected as per this Information Letter. If environmental assessments, environmental protection plans or other documents forwarded to support an application are not complete, they will be returned to the proponent. Appendix A outlines the criteria required and will ensure that unnecessary project approval delays are not encountered. The criteria in this Information Letter do not apply to transmission pipeline applications as these are the responsibility of the Lands and Trust Services Directorate, Indian and Northern Affairs Canada (INAC). For information regarding transmission pipelines, please contact the regional office of INAC in the province of the proposed pipeline. BACKGROUND The Indian Oil and Gas Act and Indian Oil and Gas Regulations, 1995, provide the framework under which Indian Oil and Gas Canada (IOGC) operates. Copies of these documents may be obtained from the following website:

2 IOGC IL March 2000 How to Prepare the Environmental Assessment Page 2 of 16 The Canadian Environmental Assessment Act (CEAA) and associated Regulations have been in force for over five years and its intent is generally well understood. For further information, contact the CEAA office at the National website: info@ceaa.gc.ca or the above Canada Justice website. Regulatory Authority Indian Oil and Gas Canada is a regulatory agency within the Department of Indian Affairs and Northern Development (DIAND) responsible for the management and administration of oil and gas resources located on Indian reserve lands in Canada. The mandate of IOGC is: to further First Nation initiatives to manage and control their own oil and gas resources; and, to fulfil the Crown s fiduciary and statutory obligations related to the management of oil and gas resources on Indian reserve lands. Pursuant to sections 5(1)(c) and (d) of the CEAA, IOGC is the responsible authority (RA) for the environmental screening and approval of applications to conduct oil and gas projects on Indian reserve land. To do this, IOGC requires the proponent (grantee) to provide an environmental assessment covering the proposed project. Linkage to other Regulations Section 4(c) of the Indian Oil and Gas Regulations, 1995, states: It is a condition of every contract that the operator will comply with, unless otherwise agreed to by the Minister and specified in the contract, all provincial laws applicable to non- Indian lands that relate to the environment or to the exploration for, or development, treatment, conservation or equitable production of oil and gas and that are not in conflict with the (Indian Oil and Gas) Act or these Regulations. Note that section 4(c) includes the rules and regulations of the Alberta Energy and Utilities Board (EUB) which are adopted by IOGC on all Indian reserves except where more stringent provincial standards exist.

3 IOGC IL March 2000 How to Prepare the Environmental Assessment Page 3 of 16 APPLICATION PROCEDURE Once the environmental assessment is complete using the criteria outlined in Appendix A, submit one copy to IOGC and provide one copy to the Chief and Council of the First Nation where the project will take place. A third copy should be made available to the First Nation environmental monitor, where applicable. Scheduling: application approval or rejection A minimum of 12 working days is required by IOGC to screen a project application. This period commences when the complete assessment is received at IOGC and the screening period will increase for complex applications or those in potentially sensitive areas. When IOGC has screened and approved your application, you will receive a letter containing the environmental terms attached to the approval. This letter will subsequently be attached to the surface lease, exploratory licence or right of way agreement and become part of the leasing conditions. In the event that there are environmental concerns preventing the approval of your application, you will be contacted by telephone to discuss alternatives. Submit your application to: Indian Oil and Gas Canada Suite 100, 9911 Chula Boulevard Tsuu T ina, AB T2W 6H6 phone: fax: Questions and information: Manager, Environment and Surface phone: Contact IOGC for DIAND contacts in each province.

4 IOGC IL March 2000 How to Prepare the Environmental Assessment Page 4 of 16 APPENDIX A CRITERIA FOR PREPARING AN ENVIRONMENTAL ASSESSMENT PURSUANT TO THE CANADIAN ENVIRONMENTAL ASSESSMENT ACT 1.0 INTRODUCTION Proponents (applicants) are responsible for ensuring that the level of effort directed to the assessment is appropriate for the nature of the project under assessment, its potential effects and the environmental setting. The First Nation Chief and Council and residents issues must also be addressed and documented. Concise reporting of the pertinent facts, keeping environmental conservation and protection, sustainable development and residents concerns foremost, will speed up the process. Where an EUB guide, information letter or interim directive applies, this must be noted. 2.0 THE CEAA PROCESS The proponent is responsible for: Scope of project (see Appendix A-1) Potential impacts Mitigation measures Cumulative effects (see Appendix A-2) Residual impacts and level of significance Reclamation plans Indian Oil and Gas Canada is responsible for: CEAA screening Project approval: IOGC is the Responsible Authority (RA) in consultation with the First Nation CEAA terms letter 3.0 ENVIRONMENTAL ASSESSMENT REQUIREMENTS The following requirements are common to all applications: Project scope: the environmental assessment must include all the components and activities of the proposed project from site selection to decommissioning and reclamation (cradle-to-grave). Appendix A-1: Scope of Project Standard Considerations provides examples. Spatial boundaries: typically the area being leased or permitted plus an area of typically 1 km diameter around the leased or licenced land.

5 IOGC IL March 2000 How to Prepare the Environmental Assessment Page 5 of 16 Borrow pits and remote sumps must be included in the assessment if they are on Reserve lands. Using such boundaries will allow the assessment of off-lease impacts and the evaluation of cumulative effects (see Appendix A-2). When a project transects both provincial and Indian Reserve land (an off- Reserve facility is being tied-in to an on-reserve facility) briefly describe the complete project but provide baseline information, impacts and mitigation for the on-reserve portion of the project, and off-reserve impacts which could potentially have an effect on the Reserve. Temporal boundaries: covers those impacts anticipated over the lifetime of the project. Effects on the environment, humans and wildlife, health and safety, accidents and malfunctions, land clearing, drilling, operations and the reclamation phases must be considered. Project schedule: state the date the initial project phase is expected to commence and when it will be completed, e.g., land clearing, construction and drilling. Emergency Response Plan: for projects involving hydrogen sulphide gas, attach the appropriate page from the Emergency Response Plan (ERP) call-up roster. Indian Oil and Gas Canada does not require a copy of the complete ERP. Sustainable development is a fundamental objective of the environmental assessment process. During the exploration and development of the hydrocarbon resource, attention must be paid to the conservation of other resources. 4.0 BASELINE INFORMATION The following baseline information must be covered and forms the basis of the assessment regardless of whether the application is for a exploratory licence, lease or right-of-way agreement. As some of this information will affect the surveyors preparing the land survey, ensure that they are aware of any policy items that may affect their work. This could avoid a re-survey. The assessment must include captioned colour photographs and a brief description of the existing landscape within the project area. Include photographs of sensitive areas and areas of concern. These photographs will also be used at the decommissioning and reclamation stage to assess the quality of landscape recontouring.

6 IOGC IL March 2000 How to Prepare the Environmental Assessment Page 6 of Map Scale Provide maps and/or photo mosaics, for example: Regional map at 1:50,000 scale or 1:250,000 scale for large projects Known cultural, archaeological, or environmentally sensitive sites at 1:50,000 scale Air photos at 1:20,000 or 1:30,000 scale 4.2 Biophysical conditions List the existing biophysical conditions using the following guidelines: Topography: Does the proposed project area include any steep land forms? IOGC Environmental Policy (March 1997) states: Surface leases with more than 9.0 m cut-and-fill (measured as the change in elevation between any two corners of a surveyed lease) require written explanatory justification to be placed on file. Such exception will be granted in only extreme circumstances. Cut-and-fill must never exceed a 10 m change in elevation. Disturbance shall not be allowed within 50 m from the lease boundary to coulee breaks or steep slopes. In most cases, there will be a requirement to re-contour the lease to its original topography upon decommissioning. There shall be a distance of not less than 100 m between the lease boundary and any water body. Land use: state the existing and surrounding land use. Groundwater: provide information on the depth to groundwater, natural springs, and the distance to potable water wells; are they upslope or downslope? If no information is available, note this in the environmental assessment. Further information may be required. Groundwater information is not always readily available on Reserve land so check with the First Nation as a survey may have been conducted. If the project becomes extensive (as the pool develops) a groundwater survey may be required. Surface water and wetlands: ensure the distance to any water body or wetland (including riparian areas, seasonal draws, ephemeral draws and muskeg) is stated on the survey plan and in the assessment.

7 IOGC IL March 2000 How to Prepare the Environmental Assessment Page 7 of 16 Compliance is required with The Navigable Waters Protection Act and The Fisheries Act. Contact the Department of Fisheries and Oceans for information: Soils: provide information on the soil characteristics. Wherever possible avoid stripping topsoil, such as on native prairie or in frozen conditions in a forested area. Identify subsoil characteristics. Identify any soil with special handling requirements, or potential for wind or water erosion. Vegetation: state the ecoregion, the regional vegetation type and describe the existing vegetation within the spatial boundaries. List any potentially endangered or traditionally important species. Forested areas: describe the dominant forest cover type, and species and provide data on salvageable timber, as follows: Salvageable timber volume assessment Coniferous: average dbh, for spruce, fir and pine Deciduous: average dbh Volume of timber requiring salvage: deciduous and coniferous (m 3 ) Number of loads (based on 45 m 3 /loads) Wildlife and wildlife habitat: describe the wildlife habitat, list key species known to frequent the area and if a Wildlife Management Plan is in effect for the region. Contact the Band s representative to request information from the elders wherever possible. Using the list developed by the Committee on the Status of Endangered Wildlife Species in Canada (COSEWIC) state if any threatened or endangered species use the area. Identify species of concern or at risk using the provincial ranking definitions. Identify riparian habitat, overwintering grounds, calving grounds, mineral licks and wildlife species of subsistence or economic value. If sensitive habitat may be affected provide an approximation of the area of similar habitat available within four surrounding sections. Be aware of compliance requirements with the Migratory Birds Convention Act. Fish and fish habitat: describe any fish and fish habitat on which the project may have an impact. Compliance with The Fisheries Act, subsections 35(1) and (2), is required. Contact the Department of Fisheries and Oceans for details:

8 IOGC IL March 2000 How to Prepare the Environmental Assessment Page 8 of Social and traditional concerns The following areas of concern must be addressed: Social: list proximity to homes and other structures, traplines (First Nation members are not required to register with the province) or other social concerns. Traditional uses and traditional environmental knowledge (TEK): contact the Band representative and request that an elder is consulted regarding traditional uses. Document them and any concerns. Cultural and archaeological sites: contact the Band representative and request that an elder is consulted regarding cultural or archaeological sites. Document them and any concerns. If the information is sensitive, it may be forwarded to IOGC as a separate memorandum. An archaeological survey may be required. Noise: discuss the noise to be generated and the effect on surrounding residents. Document any concerns and your mitigation. Recreation and aesthetic concerns: provide details. 4.4 Malfunctions and accidents List the environmental effects that could be caused by malfunctions and accidents that might occur over the life of the project. 4.5 Public consultation Public participation and consultation is a key objective of the CEAA. Although approval of the First Nation Chief and Council is required for a project to proceed, it is also crucial that the proponent contacts all Reserve residents who may be affected by the project and address any concerns related to health, environment, social effects or safety that may be expressed. The proponent must maintain a log stating who has been contacted, their concerns if any, and how they have been addressed. Include a copy of the log with plans to mitigate the concerns. Likewise, if a public consultation program was undertaken (e.g., open houses, meetings) provide a record of those residents with concerns and how they have been addressed.

9 IOGC IL March 2000 How to Prepare the Environmental Assessment Page 9 of ENVIRONMENTAL IMPACTS AND PROPOSED MITIGATION State clearly the potential environmental impacts from the proposed project on each of above components and your planned mitigation of those impacts. Conclude by stating the residual impacts and level of significance when mitigation is in place. Approval or rejection of the project may largely depend on your treatment of this requirement. Cumulative effects: see CEAA, section 16(1), (2), (3) and (4). This covers the consideration of the effects of all past, present and possible future projects (see Appendix A-2). Note: The Environmental Operating Practices for the Upstream Petroleum Industry - Alberta Operations, Canadian Association of Petroleum Producers (CAPP), May 1999, provides an excellent source of environmental management practices. 6.0 SPECIFIC PROJECT INFORMATION The following three sections provide additional pertinent information to be addressed while developing the project assessment. 6.1 Exploratory Programs IOGC Environmental Policy (March 1997) states: (a) Seismic programs using dynamite detonations must maintain a 180 m setback from potable water wells and residences unless a lesser setback is approved by the First Nation. (b) The proponent shall be advised to test potable water wells for flow and potability if the wells could potentially be affected by a proposed seismic program. If testing does not take place the proponent s CEAA terms letter must state that the proponent is responsible for subsequent water well complaints. Agreement shall be reached with the Nation involved if testing is not to take place and documented by IOGC. The environmental assessment must include: An air-photo mosaic of the program clearly showing the proposed seismic lines, locations of water body crossings, water bodies and riparian areas, erodible soils, areas of steep slope, homes and buildings within 500 m of the proposed lines, and sensitive areas. Include colour photographs of sensitive areas. Evidence of reserve resident consultation for the seismic program. Residents within 500 m of the proposed lines shall be contacted.

10 IOGC IL March 2000 How to Prepare the Environmental Assessment Page 10 of 16 Ensure the proposed routing has considered environmental and social factors and convey this information to the geophysical staff and surveyors. This may reduce the need for line location changes. The following information must be addressed, where applicable: New access roads which lie within 500 m of existing cut lines will not be approved unless adequate justification is provided. Seismic lines must follow existing cut lines or access where these lines lie within 400 m of the proposed lines. No new water crossings by seismic equipment will be permitted within 1 km of an existing crossing. Low impact avoidance cut techniques must be used. Low impact vehicles must be used where possible. Doglegs must be implemented at all road/seismic intersections and at the intersection of seismic lines with Reserve boundaries. Surface disturbance will not be permitted within 50 m of any water body except as hand-cut for the laying of cables. Wet terrain crossing is permitted only during frozen ground conditions. In forested areas a reforestation plan must be provided as part of the mitigation. Discuss this with the First Nation. Shot holes must be filled-in and reseeded during the following growing season. State if the First Nation requires rollback prior to reseeding. Native seed species compatible with the surrounding area will be required unless otherwise approved by the First Nation. Canada No.1 grade seed must be used. For 3D seismic programs in forested areas: detail how the program will be conducted to negate the potentially severe impact. Low impact ground vehicles shall be used. State if the program will be helicopter assisted. Wandering source lines are mandatory. Source line maximum width is 5 m. Receiver lines must be hand cut to a maximum of 1.5 m wide. Timber salvage is required. Seismic program reclamation plans must be provided.

11 IOGC IL March 2000 How to Prepare the Environmental Assessment Page 11 of Wellsite and Facility Leases, Access Roads, Borrow Pits, Remote Sumps IOGC Environmental Policy (March 1997) states: Surface leases with more than 9.0 m cut-and-fill (measured as the change in elevation between any two corners of a surveyed lease) require written explanatory justification to be placed on file. Such exception will be granted in only extreme circumstances. Cut-and-fill must never exceed a 10 m change in elevation. The environmental assessment must take the following into consideration: Disturbance shall not be permitted within 50 m of coulee breaks or steep slopes or any water body not being crossed. Lease boundaries shall be not less than 100 m from any water body, wetland or riparian area. New access roads must be at least 500 m from existing cut lines or access. Access road slope must not exceed 15 per cent. No roads shall be located within 100 m of streams or waterbodies. Remote sump and borrow pits: IOGC and the First Nation must approve a proposed remote sump or borrow pit location. These areas are subject to IOGC leasing requirements and the land characteristics must be included in the assessment. Potable water wells must be tested for flow and potability if within 400 m of the lease boundary. Land survey which must show residences and buildings within 500 m; access road length, and distance to waterbodies including seasonal wetlands and muskeg. Product: oil, sweet gas, sour gas Colour photographs of the proposed site, access road and surrounding area. Groundwater: provide depth to groundwater. No pump-off is allowed during any season where it may infiltrate muskeg or water bodies. Following satisfactory testing, pump-off onto agricultural land is acceptable, with land-user approval, or on to native grassland.

12 IOGC IL March 2000 How to Prepare the Environmental Assessment Page 12 of 16 Drilling mud program: include details of the drilling mud program and whether the sump will be on the lease (see also Groundwater, sub-section 4.2). State if a permeability test will be undertaken for the drilling mud sump. There shall be at least 1 m of impermeable material between the sump contents and the groundwater table. Surface water: state the distance to any water body (including seasonal sites and muskeg). Discuss surface water control on and off the lease. There shall be a distance of at least 100 m between the lease boundary and any water body. Vegetation: discuss how the lease has been located, short-sided, or aligned to avoid removing merchantable timber or impinging on sensitive areas. Practice low disturbance drilling on native grasslands. State your program for weed control. Reclamation both during operations and at project decommissioning will require using compatible native species if the site disturbed has native vegetation. Access road: discuss access road routing and the slopes encountered. The routing must follow the most environmentally benign path. State whether culverts will be used. Drainage ditches must be sized adequately to control run-off and be installed with erosion control materials. Where possible, consider not stripping the access road until a producing well has been confirmed. Subsequent flowline installation should be planned to follow access roads and existing clearings as much as possible. Operating phase Describe what equipment will remain on site when the well goes into production. Discuss the waste management plan. Knock-out tank placement must be approved by IOGC and the First Nation, and the method of leak detection must be stated. In general, underground storage tanks (USTs) will not be approved. Will the product be trucked or pipelined and to where? Is it likely that produced water disposal wells will be required during operations? State if the lease will be fenced. All equipment should be surrounded by an exclusion fence. Describe the proposed operating schedule. How often and during what seasons will the site be visited for product removal, inspection, service and/or maintenance. State if the well will be subject to seasonal shut-in.

13 IOGC IL March 2000 How to Prepare the Environmental Assessment Page 13 of 16 Application must be made to IOGC for approval to change the use of a lease, e.g., convert it to a battery or produced water disposal well. Additional environmental information will be required at this time General Health and safety Indian Oil and Gas Canada, the First Nation and the provincial authority must be notified immediately in the event of any health or environmentthreatening emergency or off-lease spills. On-lease spills greater than 1 m 3 must be reported to IOGC immediately. Lease environmental audit The lessee should be aware that a leasing condition requirement for the lessee on record at IOGC is to provide an independently conducted environmental lease audit to IOGC and the First Nation the year following lease approval and every five years thereafter (every three years for a battery) throughout the life of the lease Decommissioning and Reclamation Land reclamation on all Indian reserves will be subject to the Alberta C&R IL/95-3 (and revisions), Reclamation criteria for wellsites and associated facilities, as well as to First Nation and IOGC approval. Forested area reclamation may require trees to be replanted. Discuss this with the First Nation. Reclamation plans should be provided.

14 IOGC IL March 2000 How to Prepare the Environmental Assessment Page 14 of Flowlines, Pipelines and Linear Disturbances All flowlines or pipelines installations require application to IOGC for a right of way agreement. IOGC Environmental Policy (March 1997) states: A Conservation and Reclamation Plan (C&R Plan) will be required if the project criteria are equal to those required for an Alberta C&R Plan. The environmental assessment must address the following: Objective: state what is being transported. Pipeline rights-of-way must follow the access road and existing clearings as far as possible. Deviations from this will require justification. Water crossings: contact IOGC and the First Nation if a major water crossing is proposed. Hydrogen sulphide: if the pipeline will carry H 2 S, forward a copy of the relevant call-up page from the Emergency Response Plan to IOGC and the First Nation. Hydrostatic testing: state the source of test water. State the procedure and location for pipeline test water disposal. Transmission pipeline applications are the responsibility of Lands and Trust Services, Indian and Northern Affairs Canada at the regional office in the province of the proposed pipeline.

15 IOGC IL March 2000 How to Prepare the Environmental Assessment Page 15 of 16 SCOPE OF PROJECT - STANDARD CONSIDERATIONS Appendix A-1 The proponent is responsible for assessing the following, where applicable: Well Site objective: state the resource anticipated construction of the access road (including water crossings) and lease construction of temporary crew camp construction of a borrow pit construction of a remote sump installation and operation of a drilling rig collection of water for drilling operations disposal of drilling mud construction and operation of production facilities trenching and installation of pipelines truck transportation of product decommissioning and abandonment of facility remediation and reclamation of lease, access road, and pipeline right-of-way cumulative effects Seismic type of seismic equipment construction of temporary crew camp construction of access roads and linear clearings (including water crossings) shot hole drilling and dynamite installation operation of seismic equipment including source detonation shot hole abandonment reclamation of access roads and linear clearings cumulative effects Pipelines objective: product being transported construction of access roads and linear rights-of-way (including water crossings) stripping of soils, trenching and installation of pipe surface reclamation pipeline operation (including pressure testing and maintenance) decommissioning and abandonment of pipelines reclamation of access roads and pipeline rights-of-way cumulative effects Compressor construction of access roads (including water crossings) and lease construction of compressor facility (including leak collection system) trenching and installation of pipelines operation of compressor facility decommissioning and abandonment of facility and pipelines remediation and reclamation of access roads, lease and pipeline rights-of-way cumulative effects Oil Battery construction of access roads (including water crossings) and lease construction of oil battery facility construction of tank farm trenching and installation of pipelines operation of oil battery decommissioning and abandonment of facility and pipelines remediation and reclamation of access roads, lease and pipeline rights-of-way cumulative effects

16 IOGC IL March 2000 How to Prepare the Environmental Assessment Page 16 of 16 CUMULATIVE EFFECTS ASSESSMENT (CEA) Appendix A-2 In accordance with section 16 of the Canadian Environmental Assessment Act, cumulative effects must be addressed in every environmental assessment. The scope of the cumulative assessment should be relative to the degree of effects anticipated. Areas with high concentrations of development will require a more in-depth assessment. Sustainable Development is closely linked with cumulative environmental effect determination and is established as a fundamental objective of the federal environmental review process. Handling Uncertainty in predicting effects and determining significance can arise due to variations in natural systems, a lack of information, knowledge or scientific agreement regarding cause-effect relationships, or the inability of predictive models to accurately represent complex systems. The following guidelines should be followed when dealing with uncertainty: Make conservative conclusions (i.e., assume that an effect is more rather than less adverse) - Precautionary Principle; and Provide a record or audit trail of all assumptions, data gaps, and confidence in data quality and analysis to justify conclusions. KEY CRITERIA FOR AN ACCEPTABLE CEA The study area is large enough to allow the assessment of biophysical components that may be affected by the project. This may result in an area that is considerably larger than the project s footprint. Each biophysical component may have a different study area. As a standard consideration, assessment should be undertaken at an ecosection or ecosite (i.e., 1:50,000 to 1:20,000 scale) level. Airphoto interpretation and existing vegetation data bases should be used. As a guideline for spatial assessment, consider assessing effects in all immediately surrounding sections. Whether natural or human-induced, identify actions and/or developments that have occurred, or currently exist which may also affect those same biophysical components. Future actions that are approved within the study area must be considered. The incremental additive effects of the proposed project on the biophysical components are assessed. If the nature of the effect s interaction is more complex (e.g., synergistic) then assess the effect on that basis, or explain why that is not reasonable or possible. The total effect of the proposed project and other actions on the biophysical components are assessed. For analysis of effects use quantitative techniques (e.g., comparison of area of habitat within an area being lost versus total available within the spatial boundaries) based on the best available data. This should be enhanced by qualitative discussion based on the best professional judgement. Prediction of effects based on examination of precedent may be useful. Outline commitments to mitigation, monitoring and effects management (e.g., as part of the Environmental Protection Plan). These measures may be required at a regional scale to address broader concerns of effects on biophysical components. Implement mechanisms to evaluate the results of the monitoring and provide for subsequent mitigation or project modification, as necessary. The significance of residual effects are clearly stated and defended. Identification of the cumulative socio-economic impacts or benefits of the proposed project in association with existing developments.

17 August 2001 Addendum to IOGC IL How to Prepare the Environmental Assessment Page 1 ADDENDUM August 2001 IOGC staff process hundreds of surface applications each year. The time required to review and approve each application is as much of a concern to IOGC as it is to the applicants. Therefore, any information the environmental assessment authors can provide that will reduce ambiguities in the description of the project or the predicted impacts has the potential to reduce the IOGC review and approval time line. If a topic in the suggested Table of Contents is not relevant or there are not any data available, IOGC would prefer to see such a comment under that heading, rather than have the heading omitted, leaving the reviewer wondering whether the topic was overlooked. The Applicant shall ensure that, for each application, a copy of the environmental assessment and all relevant correspondence is provided to the First Nation Oil and Gas Representative. 1) Suggested Table of Contents and Report Outline for Environmental Assessments to be Reviewed by Indian Oil and Gas Canada for the Environmental Screenings Required Under the CEAA: Executive Summary Project Description Background -company name -project type (well site, pipeline, exploratory) -schedule -location -product expected Route / Site Selection and Consideration of Alternative Locations Proposed Construction Methods Operational Activities Environmental Overview (General and Site Specific) Surficial Geology, Landforms and Soils Hydrology (Surface Water and Groundwater - includes wetlands) Vegetation (including Species at Risk) Wildlife (including Species at Risk) and Wildlife Habitat Fish (including Species at Risk) and Fish Habitat Land Use Social and Traditional Concerns

18 August 2001 Addendum to IOGC IL How to Prepare the Environmental Assessment Page 2 -Social -Traditional Uses and Traditional Environmental Knowledge -Cultural and Archaeological -Noise -Recreation and Aesthetics -Public Consultation (summary of issues identified) Impacts and Mitigation Methodology Impact Assessment -Surficial Geology, Landforms and Soils -Hydrology (Surface Water and Groundwater) -Vegetation -Wildlife and Wildlife Habitat -Fish and Fish Habitat -Land Use -Social and Traditional Concerns (itemized as per overview) Mitigation (including implementation) Residual Impacts Interim and Final Reclamation Cumulative Environmental Effects Limitations (information unavailable at the time of the assessment) Conclusions References Appendices Map (1: scale) and/or Photomosaic (complete with reference date) Survey Plan Soils Data Site Photographs Record of Public Consultation forms List of Company / First Nation / IOGC / etc. contacts 2) Provided below is clarification of the requirements and expectations for specific sections. a) Application Procedures, Questions and Related Information: In mid year, 2000, the responsibilities of the separate Environmental Analyst and Surface Landman positions were combined into individual Environmental and

19 August 2001 Addendum to IOGC IL How to Prepare the Environmental Assessment Page 3 Surface Analyst positions. Each has responsibility for specific Reserves. Contact the IOGC Land Administrative Officer ( ) to determine which Environmental and Surface Analyst will be responsible for reviewing and processing your application. b) Appendix A, Section 3.0: Project Scope - Route/Site Selection Information provided on route/site selection should clearly describe the rationale for the chosen route/site. It is important to identify the alternatives that were considered and to demonstrate that biophysical and socio-economic components have been addressed, in addition to engineering constraints. It will be important to demonstrate that a more environmentally sound route/site was not practicable. It is particularly important that the route/site selection decision be based on current, on-the-ground conditions. Therefore the process should involve the assessment of recent, stereographic aerial photographs of the project area, combined with field reconnaissance (note: a photomosaic of the project area/reserve should be submitted with the environmental assessment). It is strongly recommended that siting decisions made in the field involve the environmental consultant and a representative of the First Nation, in addition to the proponent and the land surveyor. This approach will increase the probability that the project location is optimal from an environmental perspective and will reduce the likelihood of approval delays by IOGC. c) Appendix A, Section 4.2: Biophysical Conditions - Topography Paragraph 2 refers to a setback of the lease boundary relative to coulee breaks or steep slopes. This should read, Surface leases (including wellsites and access roads), pipeline rights-of-way and seismic lines shall be set back from coulee breaks, valley breaks or the top of any other steep slope a minimum of 50 m. This detail was inadvertently omitted from, and should be included in, Section 6.3 Flowlines, Pipelines and Linear Disturbances. d) Appendix A, Section 4.2: Biophysical Conditions - Soils Information provided on soil characteristics should include a general description of soils in the project area based on regional soil survey information, as well as more site-specific descriptions for well sites and pipeline corridors. The site-specific soil evaluation should be conducted prior to construction, by an individual capable of characterizing soils, to ensure proper soil handling and reclamation, as well as for effective spill and vegetation management. The evaluation effort should reflect the nature of any existing soils information for the project area, as well as the variability of the site. Sampling intensity should increase at locations with greater topographic variability. The evaluation should identify topsoil and upper subsoil depths, soil texture, structure, consistency, percent admixing (on arable lands - broken, cultivated or pasture), slope class and aspect, erosion potential, site drainage, site stability and any rooting restrictions

20 August 2001 Addendum to IOGC IL How to Prepare the Environmental Assessment Page 4 evident. Soil sampling locations and site characteristics should be clearly marked on a site map in the environmental assessment. Greater attention to soil conservation measures will be expected on arable lands, especially where problem soils are expected to be encountered (soils requiring special handling procedures during construction because they are salt-affected, contain sand or gravel layers, or contain bedrock). In the case of salt-affected soils, soil chemistry (e.g., electrical conductivity) will be required to determine appropriate soil conservation measures. e) Appendix A, Section 4.2: Biophysical Conditions - Surface Water and Wetlands Proponents should be aware of the potential implications of the Federal Policy on Wetland Conservation for their project. For guidance on addressing wetland issues in accordance with the policy, proponents are directed to the Wetlands Environmental Assessment Guideline. Both documents are available online at the Canadian Wildlife Service (CWS) website: f) Appendix A, Section 4.2: Biophysical Conditions - Vegetation Species at risk information can be obtained from the list developed by the Committee on the Status of Endangered Wildlife Species in Canada (COSEWIC) and from the biodiversity data centre of the relevant provincial government. A list of any potential species at risk and traditionally important species must be provided. The nature and extent of weed infestations on the project site should be documented. g) Appendix A, Section 4.2: Biophysical Conditions - Wildlife and Wildlife Habitat Traditional knowledge regarding wildlife and wildlife habitat must be documented. Contact the Band s representative and request they obtain the information from the Elders. Using the list developed by the Committee on the Status of Endangered Wildlife in Canada (COSEWIC), state if any species at risk utilize the area. This information is required to identify and assess the likely effects of a proposed project on species at risk in the project area. Updates to Environment Canada s Species at Risk website ( ) provide an improved means of predicting the presence of species at risk in the project area. The website offers a geo-referencing tool that will show any species at risk whose geographic distributions (ranges) fall within a specified spatial boundary. Information on the biology, population and distribution, habitat preferences, threats, protection, and recovery efforts of each species is also provided. Since documented ranges of wildlife species are rarely exact, proponents are advised to select spatial boundaries of varying sizes to ensure that

21 August 2001 Addendum to IOGC IL How to Prepare the Environmental Assessment Page 5 any species at the edge of its range in the project area will be recorded. The habitat preferences of each species listed should be cross-referenced to the habitats present in the project area to determine whether the species are likely to be affected by the project, and whether project relocation or other mitigation should be considered. This exercise should be included as part of the environmental assessment. Rationale is required if it is concluded that listed species are not affected by the project. In addition to the above, proponents are expected to be aware of, and incorporate into their project planning and implementation, provincial and federal government initiatives related to biodiversity conservation, whether they involve a wildlife refuge on adjacent, off-reserve lands, established environmental protection guidelines, etc. As an example, the CWS has produced a document entitled Development of Standardized Guidelines for Petroleum Activities that Affect COSEWIC Prairie and Northern Region Vertebrate Species at Risk. Phone the Environment Canada library, Prairie and Northern Region, in Edmonton at for information. The last sentence should read as follows: Compliance with the Migratory Birds Convention Act is required. For guidance on addressing migratory bird issues in an environmental assessment, proponents are directed to the Migratory Birds Environmental Assessment Guideline and Environmental Assessment Guideline for Forest Habitat of Migratory Birds. Both documents are available online at the CWS website: h) Appendix A, Section 4.2: Biophysical Conditions - Fish and Fish Habitat Proponents must ensure compliance with sections of The Fisheries Act relating to the protection of fish and fish habitat. As well, proponents should be familiar with specific policies and guidelines of the Department of Fisheries and Oceans (DFO) that apply to the activities being proposed. Such documents include Policy for the Management of Fish Habitat (1986) and Habitat Conservation and Protection Guidelines (1999). Both of these documents, and other relevant documents, are available on-line at the DFO website: i) Appendix A, Section 4.5: Public Consultation The Record of Public Consultation forms, filled out and signed by the interviewer who did the consultation, are required with the environmental assessment to substantiate that the intent of CEAA, in relation to adequate public consultation, has been met by the project proponent. A copy of the form is provided with this addendum for your convenience. j) Appendix A, Section 5.0: Environmental Impacts and Proposed Mitigation Environmental effects that extend to locations beyond the Reserve, resulting from on-reserve projects, must also be described.