Porcupine Caribou Management Board Submission to the Select Committee Regarding the Risks and Benefits of Hydraulic Fracturing

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1 Porcupine Caribou Management Board Submission to the Select Committee Regarding the Risks and Benefits of Hydraulic Fracturing September 30, 2014 Introduction In response to the mandate of the Select Committee Regarding the Risks and Benefits of Hydraulic Fracturing to gather input from the Yukon public, First Nations, stakeholders, and stakeholder groups including non-governmental organizations, this document provides comments about the potential risks of hydraulic fracturing to Porcupine Caribou Herd ecology and distribution. Background on the Porcupine Caribou Herd The Porcupine Caribou herd (PCH) is a barren-ground herd that ranges between Alaska, Yukon, and NWT, which numbered approximately 197,000 animals in 2013 (PCTC 2014). During recent land use planning the herd was deemed the most important and valued ecological and socio-cultural resource in the North Yukon (NYPC 2009). The herd is likely one of the best known barren-ground herds. Annual monitoring of various population indicators and distribution that has occurred since the early 1970s has resulted in a rich dataset. The sensitive nature of the PCH is of enough concern that the PCMB worked with all the caribou herd s user groups to develop a harvest management strategy as one means of protecting the herd. It stands to reason that if the traditional caribou users are being asked to alter their harvesting activities, other human activities in the range of the herd need to be altered or even avoided for the good of the PCH. The Board believes the conservation of the herd should be of utmost importance. When the herd is not thriving, the First Nation and Inuvialuit communities that have used the caribou for centuries also suffer. Continuing Porcupine Caribou traditions is critical for healthy communities in the herd s range. The process of hydraulic fracturing poses a significant threat to the herd and, as a result, the process of hydraulic fracturing also threatens to impact the people who rely on the herd. Currently, the most active oil and gas field in Yukon is located in the Porcupine Caribou range. The North Yukon Land Use Plan (NYPC 2009) addresses management of this area and identifies that [i]ndustrial land use activities may create direct wildlife habitat effects including habitat loss, alteration and fragmentation. The plan identifies that avoidance or reduced use of habitat is a key issue along with the potential to increase human and predator mortality from improved access caused by added seismic lines, trails, and winter roads. Below is a brief outline of the impacts of activities based on evidence from research on the Porcupine Caribou and other caribou herds in North America. 1

2 Effects of Intensive Oil and Gas Development on Habitat and Condition of Caribou Regulators where hydraulic fracturing is considered common describe increases in footprint, linear disturbances, vehicle traffic, noise, dust, emissions, odour and light pollution as a common impact of activities (ERCB 2012). As such, these can be considered as the minimum expected sources of impacts on the PCH. The effect on these on caribou and its habitat are identified in detail below. Footprint and Loss of Habitat Footprint refers to roads, pipelines, storage facilities, well pads, drills, camps, sand mining areas, water access, etc. Recent research (Johnson and Russell 2014) has demonstrated that Porcupine Caribou appear to avoid habitat impacted by low levels of development from years ago. Development at that time in the range of the PCH consisted mostly of widely spaced 2D seismic lines that were linear strips 5-10 meters wide. Densities of those seismic lines by today s standards could be considered very low; however, caribou still appear to avoid these lines today, decades after the impact occurred. It is fair to say that a field developed using fracking techniques today would amount to a significantly greater footprint than conventional developments from years ago based on experiences throughout North America. To develop non-conventional fields where hydraulic fracturing would be used, highresolution 3D seismic data would be required. This type of data gathering is extremely intensive ( metre spacing). Although lines have been reduced to meter strips that meander across a landscape, we note that significant access that is 5-10 meters wide is still generally required due to safety concerns, particularly in very cold climates, as evidenced by the recent program in the Eagle Plains area. Based on unconventional field development throughout North America we can also expect that once a development proceeds into production, high densities of road networks are required to support the large number of wells that must be drilled and the development of water and sand sources to feed the fracturing process. Camp numbers and or sizes also expand as the intensive process needs large numbers of workers to undertake the multiple aspects required to carry out the work successfully. Although recently published research indicates we expect the majority of caribou to avoid wintering in large numbers in areas developed for oil and gas in Porcupine Caribou range, inevitably some caribou will decide to winter in or near these areas. This choice may result in caribou with reduced body condition in spring as caribou will spend more time avoiding or watching people than eating. For cows, the direct impact is calves being in poor condition in spring. Calves in poor condition have a lower chance of survival to start with, but for female calves, impacts will also manifest years later when they take an additional year before having their first calf (age 4 vs 3). At a population scale, the combination of effects can have a large impact, particularly if large segments 2

3 of the herd are exposed to disturbances. Recent research on neighbouring herds has suggested this effect can lead to population declines in large migratory herds (Boertje et al. 2012). Linear disturbances For caribou that decide to winter in areas with increased linear disturbances, there are significant bodies of work that have demonstrated that caribou and linear disturbances are not complementary. One primary reason is increased predation due to enhanced access and sight lines in forested habitats by both human hunters and predators such as wolves. Wolves are a primary predator of caribou herds and use linear features to travel and hunt, likely owing to ease of travel and increased encounter rates with ungulates (James and Stuart-Smith 2000, Whittington et al. 2011). Linear features provide easy access for hunters and predators to watch for caribou, and in the case of humans, enhance their success rate due to improved sightlines. In areas where little human use occurs on these features (e.g. seismic lines after they are used), wolves find these attractive to travel on and hunt from (James and Stuart-Smith 2000). As a consequence, the risk of predation or harvest would likely increase for caribou near linear features, particularly where sightlines are extensive. This relationship likely helps explain the avoidance of habitat features by many ungulates, even where predation is not a reality (Gavin and Komers 2006). Vehicle traffic High volumes of traffic are expected to drill and frack a well. Estimates suggest a typical well would require truckloads (US Dept. Energy 2014). Production would require up to 353 loads each year and subsequent stimulation of wells would result in close to 1000 additional truckloads (US Dept. of Energy 2014). Truck traffic can increase direct mortality from road strikes. Direct mortality could occur from multiple sources, including collisions along the length of the Dempster Highway where most traffic will occur, strikes along access roads, and mortal injuries caused as caribou flee disturbances such as helicopters, mulchers, trucks, snowmobiles, etc. In the north, there will also be a desire to construct roads on ridgelines where construction is better. However, caribou use these same ridgelines to migrate. With intensive road networks in these same areas using ridgelines as the principle access, it is expected that there will be direct conflict with caribou when they winter in these areas or migrate through the area to get to preferred habitats. Noise, Light pollution and Odour Noise, light pollution and odour can impact caribou and other species by causing them to avoid an area or alternatively remain in the area but reduce foraging as they become more vigilant. Disturbances such as lights and noise can result in short-term responses from caribou, including startle responses, elevated heart rates and production of stress hormones 3

4 (Creel et al. 2002). Caribou may flee such situations, initiating a flight response at distances out to 600 metres from a disturbance (e.g. snowmobile) and will displace an additional 600 metres from that point (Reimers et al. 2003). Running from disturbances often is accompanied by a general increase in overall movement rate and displacement to security and away from foraging habitats, both of which may result in higher energy expenditures (Bradshaw et al. 1997). Sustained or repeated disturbance can result in avoidance of areas and the reduction in use of suitable habitats (Creel et al. 2002, Sawyer et al. 2006). It is reasonably likely that caribou will be affected by oil and gas activities in many places along the Dempster Highway that will have increased traffic levels. Mitigating disturbances to groups of wintering caribou will likely be challenging as wintering caribou generally, although not always, remain in an area for the duration of winter and only drift as required to access forage or avoid predators. While standard mitigations may work well for some species, it will be challenging for companies to stay 600 meters from foraging or travelling caribou when thousands or even tens of thousands of caribou move into an area. Avoidance in these situations is just not feasible. Cumulative Effects Beyond the direct impacts noted above, an additional growing concern is the cumulative impact of development on habitat. This effect is well-documented and very concerning for a herd like the Porcupine Caribou herd which requires large quantities of intact functioning habitat to maintain its population, and even more importantly, to have the capability to grow again following natural population cycles. Based on recent research, we are also aware that habitat changes brought about by climate change will impact the herd. Conservative projections suggest we could lose up to one-fifth of the herd s winter range to fire within this century (Gustine et al. 2014). After an area is burned, it takes at least 60 years for the habitat to become high quality winter habitat for caribou again. It is also possible that burned habitat will not convert into preferred habitat for caribou (e.g. conversion to a birch-dominated stand from black spruce), and it may also become more likely to burn again due to changes if forest fuels and thermal conditions. In combination with the cumulative effects of oil and gas development, the increase of fires in the range of the herd will reduce the resilience of the herd, thus reducing the ability of the herd to grow following population lows. In combination, it is doubtful that this type of activity could meet land use thresholds determined during planning in the North Yukon and Peel. These thresholds were established to ensure the PCH were not impacted. Exceeding these thresholds would place the herd at risk from significant cumulative impacts. 4

5 Recommendations The Board is not against responsible, regulated oil and gas development within the PCH range. If development of oil and gas basin moves forward, the PCMB recommends that, at minimum, Government of Yukon ensure that development does not exceed the thresholds found in the North Yukon Land Use Plan for each IMA and that developments are considered cumulatively across the range of the PCH. Thresholds in the Land Use Plan were established to ensure the PCH would not be impacted by development within their range. The Board notes that continuing Porcupine Caribou traditions is critical for healthy communities in the herd s range. As such, it is prudent to ensure that future developments are assessed with a view to controlling the overall potential impact to the PCH. Development must be managed in a conservative manner to ensure cumulative impacts do not adversely affect the herd. The Board would like to point out that with hydraulic fracturing, the technique is not used for one or two wells. To successfully use hydraulic fracturing in the development of a field a very high density of wells are required. Experience elsewhere tells us the footprint associated with this level of development is not compatible with caribou conservation. The development of a field of this type is not appropriate in the Porcupine Caribou range. Almost all of the First Nations that form the user communities of the Porcupine Caribou Management Agreement have passed or are in the process of passing resolutions that do not support the use of hydraulic fracturing in their Traditional Territory. We reiterate that although the Board is not opposed to responsible, regulated oil and gas development within the PCH range, it does not support unconventional hydraulic fracturing whatsoever in the range of the herd. The health and sustainability of the Porcupine Caribou herd and its habitat should not be jeopardized for any reason. The potential impact and risks of hydraulic fracturing to the herd, its habitat and the First Nation and Inuvialuit people who rely on the herd should be carefully considered when weighing risks and benefits of hydraulic fracturing with the range of the PCH. 5