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Reminiscent of the Great Plains that once were, the Middle Sand Hills contain extensive Mixed Grasslands, ancient glacial coulees, sand hills, and over 1,100 native prairie species.

Sage brush in the Suffield National Wildlife Area (NWA). Photo © K. Mihalcheon

Looking across the South Saskatchewan River Valley. Photo © D. Olson

Pronghorn bucks and does in the Middle Sand Hills area. Photo © C. Olson

AWA’s vision for the Middle Sand Hills Area of Concern is to see the remainder of this rare mixedgrass landscape conserved. The ecological benefits of protecting and conserving the Middle Sand Hills and the area’s abundant species at risk outweigh the temporary benefits of developing this important Great Plains region.

The Middle Sand Hills, for which this Area of Concern is named, is just one feature of many found in this grassland area. Located in the north-eastern portion of the Area of Concern adjacent to the South Saskatchewan River, the Middle Sand Hills are rare, desert-like, stabilized and active (un-stabilized) sand dunes. Photo © A. Teucher

AWA’s Middle Sand Hills Area of Concern covers an extensive 2479 km² of Mixed Grasslands in southeastern Alberta. The near-native grasslands, sand hills, ancient glacial coulees and wetlands are reminiscent of the Great Plains as they once were, where the Middle Sand Hills constitute one of two of the largest remaining blocks of Mixed Grasslands in Canada. The area boasts an incredible diversity of flora and fauna, home to 1,100 native prairie species, including 13 federal Species at Risk and 78 provincially listed “at risk” species.

The Middle Sand Hills are located north of the city of Medicine Hat, west of the South Saskatchewan River, north of the Red Deer River and in large part within the Canadian Forces Base (C.F.B.) Suffield Military Reserve. As such, the military is intricately tied to the history, and fate, of this wildland.

Industry also plays a powerful role in the Middle Sand Hills. Once contained within the oil access area in the northwest corner of the military reserve (just outside of the Area of Concern) but now occurring even in protected areas, are thousands of well sites.

Status

There are two protected areas within AWA’s Middle Sand Hills Area of Concern: the Prairie Coulees Natural Area and the Suffield National Wildlife Area (NWA).

The Prairie Coulees Natural Area, in the southeastern corner of the Middle Sand Hills, covers an area of almost 18 km².

The Suffield NWA is a strip of grassland plains adjacent to the South Saskatchewan River, protected as one of 51 NWAs in Canada established by the Canada Wildlife Act. The total protected area within the NWA is 458 km².

Under Wildlife Area Regulations, hunting and fishing, the removal or destruction of plant life, and commercial or industrial activity are prohibited in Wildlife areas. However, the mines and minerals found in Middle Sand Hills Area of Concern are not included in this prohibition. These regulations have not protected the land surface from the impacts of access to the resources underneath. The remainder of the area outside the NWA in the C.F.B. Suffield Military Reserve is not protected.

Management

Managing of the landscapes in the Middle Sand Hills Area of Concern falls under the purview of numerous parties including the Federal Government, the Government of Alberta, and industrial leaseholders within the area, as well as a multitude of Departments and Ministries that operate within or adjacent to the aforementioned government bodies; e.g. the Department of National Defence (DND), Environment Canada, Alberta Environment and Parks (AEP), Alberta Energy Regulator (AER) and the Canadian Wildlife Service (CWS).

Responsibilities over management are as follows:

The Suffield National Wildlife Area (NWA) is under the administrative authority and ownership of the Canadian Department of National Defence (DND), subject to a delegation of authority from the Minister of the Environment to the Minister of National Defence.
The province of Alberta owns the mineral rights to the area, including those found within the C.F.B. Suffield Military Reserve.
Under the 1975 and 1977 Memoranda of Agreement, the Province of Alberta must pay for the cost of range control: specifically, two radio-equipped vehicles and personnel needed to coordinate industry and military activities.
The 1975 Memorandum of Agreement established the Suffield Environmental Advisory Committee (SEAC), which comprised one representative each from Environment Canada, Alberta Environment, and the Energy Resources Conservation Board (later the Energy and Utilities Board). SEAC was charged with reporting annually on its activities to Canada, Alberta, and the Base Commander, and with providing advice when requested. The Base Commander retained final authority for project approvals.
The Suffield Industry Range Control (SIRC) was created to function as the liaison between industry and the Base Commander. SIRC operates under a private company with head office in Calgary. Its operations are funded by the operators – companies with mineral rights on the base. Operators are billed annually based on the percent of the total assets which they own.
- SIRC was authorized by the Partial Assignment Agreement (June 1, 1999) and was charged with controlling and directing industry access on C.F.B. Suffield. However, in October 2007, AWA was informed that SIRC was no longer controlling access on the Base.
- Until 2004 SIRC oversaw environmental review (if any) and mitigation plans (if any) for proposed projects. In 2004, the Base Commander started requesting environmental overviews of proposed projects and began exercising more authority over approving projects.
- SIRC meets with the Base Commander and the CFB Suffield Environmental Advisory Committee (SEAC) once a year at the same meeting. At this meeting SIRC submits general operational plans (Annual Activity Plan) for the next year. The Base Commander may approve in principle or not.
- According to SIRC, SEAC is the appropriate authority to ensure environmental protection at the Base. The Base Commander may only give or refuse approval of any activity, upon the recommendation of SEAC.
- SIRC forwards industry applications to SEAC and G3, the military body responsible for Operations and Training, at the Suffield Base. The Energy Utilities Board (now Alberta Energy Regulator) reviews applications to ensure they meet operational guidelines. Alberta Environment reviews applications, but does not have authority on federal land.
The Grazing Advisory Committee (GAC) comprises representatives from Canadian Wildlife Service, Agriculture Canada, Alberta Public Lands, and Alberta Environment. The GAC guides grazing management on the Prairie Farm Rehabilitation Administration (PFRA) pastures with objectives to maintain the ecological integrity of the grasslands while providing supplementary grazing for local ranchers. The GAC meets annually and makes recommendations as needed to the PFRA pastures manager and the Base Commander.

Area

The Middle Sand Hills are located north of the city of Medicine Hat, west of the South Saskatchewan River, north of the Red Deer River and in large part within the Canadian Forces Base (C.F.B.) Suffield Military Reserve. The C.F.B. presence on the landscapes means that the Canadian Military is intricately tied to the history, and fate, of this wildland.

AWA’s Middle Sand Hills Area of Concern. MAP © AWA FILES: JPG|PDF

Watershed

The Middle Sand Hills fall within the South Saskatchewan River basin. The area is generally well-drained, meaning that surface water is intermittent and in times of prolonged drought virtually non-existent. The area has seasonal marshes and ponds, and three permanent lakes: Dishpan Lake, Whitehorse Lake and Easy Lake. The Middle Sand Hills are also distinguished by their seepage springs located in some of the eroded coulees and badlands areas. C.F.B. Suffield, within AWA’s Middle Sand Hills Area of Concern, contains 294 wetlands and important riparian habitat.

Geology

The Middle Sand Hills area was glaciated tens of thousands of years ago, and is marked by rolling basins and hills and some steep walled dry valleys left by unevenly melting ice. Ancient glacial lake beds can be found in the centre and south of the area. Elevation ranges from 640 meters above sea level where the South Saskatchewan flows out of the area, to 770 metres along the highest uplands in the far south.

Environmentally Significant Areas

Most of the Middle Sand Hills/Suffield area is considered a nationally significant area, as grasslands are one of the most threatened ecosystems in the world, and the Suffield National Wildlife (NWA) is one of only a handful of large unploughed native prairie areas in North America. The NWA is unique because of its location near the northern limit of the North American northern plains, the eolian grasslands that it contains, and its relatively unaltered vegetation. It provides important habitat to at least 15 federally listed species at risk of extinction.

The Middle Sand Hills also hold provincial significance due to the dunes themselves, having highly diverse sand dune habitats and a high concentration of significant sand dune features (Environmentally Significant Areas of Alberta, Vol. 2, 1997). The dune habitat houses a number of rare or vulnerable species including Ord’s kangaroo rats, loggerhead shrike, and plains hognose snake.

AWA’s Middle Sand Hills Area of Concern ESAs. MAP © AWA FILES: JPG|PDF

Natural Regions

AWA’s Middle Sand Hills Area of Concern falls within the Grasslands Natural Region of Alberta and is one of two large blocks of Mixed Grassland remaining in Canada. The entirety of the Middle Sand Hills falls within the Dry Mixedgrass Natural Subregion of Alberta.

AWA’s Middle Sand Hills Area of Concern Natural Regions. MAP © AWA FILES: JPG|PDF

Vegetation

Information collected from the Vegetation Component Report for the Canadian Forces Base Suffield National Wildlife Area Wildlife Inventory, 1997.

There are 29 plant community types recognized within the area, falling within four broad plant community types: grassland, wetlands, deciduous shrub and deciduous trees.

The extensive Dry Mixed Grasslands of the Middle Sand Hills area contain species such as wild rose, sage brush, needle and thread grass, choke cherry, blue grama and silverberry. It’s the Dry Mixedgrass ecoregion that contains the sparsely vegetated Middle Sand Hills, containing sand dropseed, sand grass, Indian rice grass and Canada wild rye. Shrub species like silver sagebrush, willow, prairie rose, and black choke cherry grow in between stabilized and un-stabilized dunes.

Species found within the wetland communities include common great bulrush, cattails, creeping spike rush, water sedge, clasping-leaf pond weed, spike water-milfoil, as well as other species common to wetlands.

There are numerous provincially or locally rare species within the Middle Sand Hills Area of Concern, including Carolina whitlow grass, clamyweed, skeletonweed, long-leaved white water crowfoot, prickly milk vetch, few-flowered rush, annual lupine, shrubby evening primrose, sandhills cinquefoil, among dozens more species.

Wildlife

Information collected from the Canadian Forces Base Suffield National Wildlife Area Wildlife Inventory, 1997.

Where large carnivores once roamed the Great Plains, Grizzly Bears, cougars and wolves have been absent from the Middle Sand Hills and Suffield area for at least a century. In their place, mid-sized carnivores such as coyotes, red fox, swift fox, American badgers, striped skunks, raccoons and bobcats, and small predators, including long-tailed weasels, least weasels and minks are the common carnivores that inhabit the region.

Large ungulates are also a common fixture of the Mixed Grasslands of Middle Sand Hills, including pronghorn antelope, white-tailed deer, mule deer, and elk. Elk were locally extirpated from the Suffield area in about 1960, when the last of a small resident population was poached from the Base. In the years 1997 and 1998, 230 elk were introduced to the C.F.B. Suffield National Wildlife Area from Elk Island National Park. In the absence of natural predators, the population has expanded rapidly.

Raptors such as prairie falcons, merlins, Swainson’s hawk, ferruginous hawks, long-eared, short-eared and burrowing owls, American kestrels and golden eagles have been observed within the area. Reptile species include rattlesnake, bull snake, garter snake, horned toad, tiger salamander, spadefoot toad, and northern leopard frog. Rare rodents observed within the C.F.B. Suffield National Wildlife Area include Ord’s kangaroo rat and olive-backed pocket mice.

Swift fox. Photo © C. Olson

Plains spadefoot toad. Photo © A. Teucher

Ord’s Kangaroo Rat. Photo © A. Teucher

Cultural

As in many other places on the Canadian Prairies, the grasslands of the Middle Sand Hills Area of Concern hold great cultural significance to Indigenous Peoples, who have inhabited the plains since time immemorial. The Middle Sand Hills hold particular significance to the Siksikáítapiiksi (Blackfoot Confederacy). An archaeological survey, conducted within a portion of C.F.B. Suffield in 1985, located 3,712 cultural features, including 2486 stone circles, 1071 stone cairns, 104 stone alignments, five effigies, four medicine wheels, and one bison kill site (Brumley & Dau, 1985).

Middle Sand Hills falls within the traditional territories of Treaty 7.

Oil and Gas

Increasing pressure to find and develop resources has resulted in complex land use conflicts. Thousands of kilometers of pipelines and thousands of gas and oil wellhead sites have deeply disturbed the natural landscape in the Middle Sand Hills. Fragile wetland ecosystems, abundant within C.F.B. Suffield, are at risk of degradation and contamination when drilling occurs in near proximity.

Reclamation efforts for abandoned wells are lacking within C.F.B. Suffield and the surrounding oil fields. Locations and reclamation status of abandoned wells is unknown.

Linear Disturbance

The land in the Middle Sand Hills/Suffield area has been extensively disturbed by the ruts, tracks and roads that make up the short cuts and multiple access routes to wells. These not only fragment the fragile ecosystem, but allow the easy conquest of invasive species.

Invasive Species

With linear disturbance, such as roads and pipelines, come foreign, invasive species that can lead to the conversion of native mixedgrass prairie; of concern in the Middle Sand Hills are crested wheatgrass, Russian thistle (tumbleweed), Russian pigweed (Kochia), downy brome, and leafy spurge.

2023

AWA writes to Minister Schulz, Alberta Environment and Protected Areas, and Minister Wilson, Indigenous Affairs, asking for support for our work at Suffield. The reply states a need to address “many socio-economic and environmental considerations” before promising support.

Through help from AWA, a site visit is arranged for Treaty 7 nations.

A change in base command creates new challenges in our discussion and in Indigenous access to Suffield NWA, as the new base commander is less open to working with AWA.

2022

AWA writes a letter to ECCC and DND describing Suffield as a significant reconciliation and conservation opportunity. The base commander reaches out, and AWA arranges a field trip to the base.

AWA also begins to reach out to Indigenous communities, asking for interest in access to the region. The idea of bison reintroduction is discussed.

2021

AWA would like to see increased protection and more ecologically sensitive management of the larger Middle Sand Hills Area of Concern and would like to be engaged in a management planning process.

AWA has asked the federal government for a management plan for the NWA for almost a decade. While it has been promised many times, there have been no public consultations and no significant movement to release a draft plan for public review. Such a plan offers the best hope that a science–based approach to wildlife protection and management will be implemented with a reasonable measure of public involvement.

2018

The Calgary Zoo launches a program to boost burrowing owl populations within C.F.B. Suffield’s National Wildlife Area (NWA). The program involves adding eight additional owls to the NWA in the spring.

A northern Alberta man is charged $5,000 for hunting elk within the restricted zone of the Suffield National Wildlife Area (NWA). While the man possessed a license to hunt elk as part of the Department of National Defence’s elk herd reduction program, the charge resulted from driving off-road into an off-limits area to collect the hunted elk, despite clear warnings that these criteria are in breach of the license.

2013

In September, the Alberta Government cancels the mineral lease of Crew Energy, which violated provincial legislation by building an active oil well too close to a ferruginous hawk nest.

2012

In December, the seven-group Suffield Coalition applauds the Federal Government’s decision to deny approval of Cenovus’ (previously EnCana) proposal to drill 1,275 natural gas wells and construct associated infrastructure in the Suffield National Wildlife Area (NWA).

The Suffield Coalition comprises of seven groups: Alberta Wilderness Association, Nature Alberta, World Wildlife Fund Canada, Nature Saskatchewan, Southern Alberta Group for the Environment, Grasslands Naturalists, and Nature Canada.

The Government responds to the January 2009 recommendations of the Joint Review Panel that conducted an environmental review of Cenovus’ proposed expansion. It agreed with the Panel’s conclusion that the proposed project would result in significant adverse effects on certain species at risk and would interfere with the conservation of wildlife.

In October, for the first time, hunters are allowed to hunt elk in C.F.B. Suffield. Elk were introduced to the area in the 1990s but, with no natural predators, their numbers exploded. AWA questions the motives for the hunt – intended to deal with damage to surrounding crop lands – questioning whether a hunt is the only, or indeed the best way to deal with this issue.

2011

In June, Cenovus Energy receives approval from the Energy Resources Conservation Board (ERCB) to drill 47 sweet gas wells in C.F.B Suffield. This is despite the objections from the Department of National Defence. Low gas prices mean that the wells are not likely to be drilled immediately.

2010

In November, Harvest Operations Corporation is fined $125,000 for a 2008 leak of approximately 14,500 litres of crude oil which killed at least 300 birds in the southwest corner of C.F.B. Suffield, approximately 48 km from the C.F.B. Suffield National Wildlife Area (NWA). The spill, from an ‘abandoned’ well site, affected 1,200 m² of land and was estimated to have been leaking for three months before it was detected.

The dead birds, according to Environment Canada included migratory birds, songbirds and raptors.

On September 1, the seven organizations in the Suffield Coalition write to federal Environment Minister to express concern about the Department’s failure to identify critical habitat for Burrowing Owl within C.F.B. Suffield National Wildlife Area (NWA). A revised proposed recovery strategy once again failed to identify critical habitat for Burrowing Owl in accordance with the Species at Risk Act.

“There is no scientific basis for the conspicuous exclusions of habitat biologically critical for Burrowing Owls from the current critical habitat designation for Burrowing Owl,” says the Coalition. “While the recovery strategy identifies critical habitat in land currently under federal jurisdiction… the valuable habitat within C.F.B. Suffield NWA is overlooked and the occurrence of the species within the Suffield block is misrepresented.”

In January, the Crown unexpectedly stays the case against EnCana on charges of violating Canada’s Wildlife Act. EnCana is scheduled to be tried on March 19, 2010, almost five years after installing a section of pipeline in the Suffield National Wildlife Area (NWA) without a permit (in March 2005). Numerous adjournments and a preliminary hearing are held in Medicine Hat, but now there will be no trial. The reasons for the Crown’s decision to abandon the case are not fully clear though the many deficiencies in the environmental management of the NWA seem to be part of the reason.

2009

EnCana splits its holdings into two companies. The leases within Suffield now belong to Cenovus, the new company.

EnCana makes an appearance at a Medicine Hat court to answer charges of violating the Canada Wildlife Act. The Court decides that EnCana’s evidence is not sufficient to prevent the case from going to trial.

The Suffield Joint Review Panel releases its report and recommendation regarding EnCana’s proposed shallow gas infill project. The Panel recommends “that certain key requirements must be met before the proposed project or a variation of it could proceed.” The three requirements are as follows:

Critical habitat for two species at risk, the Ord’s kangaroo rat and the Sprague’s pipit, as well as three plant species at risk, the tiny cryptanthe, the small-flowered sand verbena, and the slender mouse-ear-cress, must be finalized.
Once critical habitat is finalized, the proposed project facilities should not be located in the defined critical habitat for these five species, unless otherwise permitted under the Species at Risk Act.
The Suffield Environmental Advisory Committee (SEAC), established under the 1975 Agreement allowing gas production in the present-day National Wildlife Area, is not able to oversee a development of this magnitude at present. Its role must be clarified and it must be resourced adequately by the Governments of Canada and Alberta to be able to ensure proper regulatory oversight of the proposed project.

2008

October 31, 2008 – EnCana Hearing Day 16
The Government of Canada reiterates its position that the evidence provided by EnCana to the Joint Review Panel is inadequate to support EnCana’s conclusion that the environmental effects of the proposed project are not likely to be significant.

The Panel chair then concludes the hearing, stating that the Panel will make a recommendation to the federal Minister of the Environment by the end of January, 2009. The Panel’s report will “set out the rationale, conclusions and recommendations of the Panel relating to the overall Project and the reasons for the decision associated with the three wells.”

October 30, 2008 – EnCana Hearing Day 15
EnCana emphasizes its claim to be a leader of sustainable development, its commitment to working with all interested parties, and its compliance with the precautionary principle in its project application. All of these claims have been disputed by both the Suffield Coalition and the Government of Canada throughout the hearing.

The Suffield Coalition’s counsel reiterates the Coalition’s position regarding the proposed project: “That this Panel should recommend that this application for the 1,275 wells and the 3 wells before the Energy Resources Conservation Board should be denied in its entirety. It is our position that no further drilling should be allowed in the National Wildlife Area – not now, not ever. There cannot be a compromise. A pilot in the NWA is not acceptable. Staging development over a longer period of time is not acceptable. This is an important area and it must be protected. What should be occurring in this area is that it should be restored, not degraded.”

The Coalition also holds that the Joint Review Panel should recommend that a regional cumulative effects assessment of the area be completed and a management plan for the NWA developed. The Coalition is willing to participate in both of these initiatives.

October 25, 2008 – EnCana Hearing Day 14
The Joint Review Panel’s experts present their evidence regarding EnCana’s proposed project. The Panel concludes: “We should consciously, purposely, protect the biological, functional and genetic diversity” of the Suffield National Wildlife Area.” At the same time, he states that “appropriate mitigation” could “lessen the impact” of EnCana’s project and that we should “proceed cautiously.” The Panel’s second expert concludes that “without a formal management plan, it remains difficult now and it will remain difficult in the future to gauge the success of wildlife management in the National Wildlife Area.”

EnCana’s rebuttal follows, with the company’s solicitor giving the floor to EnCana witnesses. They speak to the issues of invasive species and reclamation; snake mortality, habitat fragmentation, and preliminarily assess habitat for SARA-listed species at risk; water resources and use for the proposed project; and EnCana’s track record.

October 24, 2008 – EnCana Hearing Day 13
With the return of the Base Commander of C.F.B. Suffield to the hearing, the Government of Canada panel takes the stand once again for cross-examination, beginning with the Suffield Coalition. In response to questions, the Base Commander and other Department of National Defence witnesses confirm: (1) that EnCana has consistently resisted the authority of the Base Commander over the Base, including the necessity for permits to operate in the National Wildlife Area (NWA); (2) that Suffield Industry Range Control (SIRC; a wholly owned subsidiary of EnCana) has given landowner consent to well applications on behalf of the Base without the Base’s knowledge and against the Base’s wishes; (3) that EnCana has a history of non-compliance in the NWA, including an incident of road rutting/disturbance (summer 2008) that was discovered accidentally by an Environment Canada employee; and (4) that EnCana has resisted discussion with the Base regarding standards for operating on the Base.

The Base Commander emphasizes that the results of this hearing may potentially have significant impacts across the full range of NWAs across the country, and Environment Canada witnesses testify to the critical importance of protecting species at risk and their habitat in the Suffield NWA.

October 23, 2008 – EnCana Hearing Day 12
Cross-examination of the Government of Canada continues. The government’s position is clear: the information in EnCana’s environmental assessment is insufficient to determine whether there will be significant environmental effects if the project goes ahead. When questioned about EnCana’s reclamation plans, Environment Canada states that neither the federal nor the provincial government knows what reclamation criteria, if any, will be applied. During their testimony (and in preceding days of the hearing), the glaring absence of Alberta Environment and Alberta Sustainable Resource Development at the hearing becomes obvious: issues related to water and wildlife are consistently deferred to these two provincial departments, who carry responsibility for these aspects of the project.

Two of three members of the Suffield Environmental Advisory Committee (SEAC) take the stand for the evening session; the Alberta Environment member is noticeably absent. SEAC’s opening statement outlines the confusion about SEAC’s role, the uncertainty about the reporting structure and the authority of SEAC, the lack of clear direction on reclamation standards on the Base, the lack of resources within SEAC, the difference of opinion between the Base and EnCana as to SEAC’s role, and the need for revision of the 1975 Memorandum of Agreement. Cross-examination confirms the extremely weak oil and gas monitoring and enforcement regime on the Base, which leaves wide-open doors for non-compliance, industry self-monitoring, and disregard for environmental concerns in the National Wildlife Area.

October 22, 2008 – EnCana Hearing Day 11
The Suffield Coalition’s counsel continues the cross-examination of the Government of Canada today. The questioning of the Department of National Defence (DND) reveals significant non-compliance issues with EnCana, especially in the area of C.F.B. Suffield just across the river from the National Wildlife Area (NWA). EnCana’s infractions include violations of DND rules as well as of the company’s own Environmental Protection Plan for the “minimal disturbance” project. DND also testifies to problems with regularly occurring gas leaks, lack of capacity to monitor and respond to industry’s infractions on the Base, and EnCana’s abandonment of the Appropriate Dispute Resolution process. The company left the process because they took issue with setbacks for species at risk and for wetlands, the threshold that DND had set for 16 disturbances per square mile, and Base Commander’s authority. Cross-examination also reveals numerous gaps in monitoring and enforcement on the Base.

The questions of Environment Canada focus on the application of the Species at Risk Act (SARA) in the NWA, which contains at least 14 SARA-listed species. Environment Canada stresses the importance of the Panel’s consideration of the preliminarily assessed critical habitat for five of those species, which constitutes more than 90 percent of the Base.

EnCana’s counsel begins cross-examination of the Government of Canada.

October 21, 2008 – EnCana Hearing Day 10
The formal hearing resumes with the completion of the Government of Canada’s opening statement. Following on the Department of National Defence’s presentation last Friday citing “unacceptable risk” from the proposed project and recommending a “precautionary approach,” Environment Canada and Natural Resources Canada both deliver strong critiques of EnCana’s Environmental Impact Statement (EIS), reiterating many of the Suffield Coalition’s points made prior. Environment Canada recommends that the Panel’s decision take into account the department’s preliminarily assessed critical habitat for five species at risk in the NWA, which covers well over 90 percent of the protected area. Natural Resources Canada identifies the deficiencies in EnCana’s assessment of the proposed project’s potential impacts on groundwater quantity and quality.

The Coalition’s solicitor begins cross-examination of the Department of National Defence late, focusing on the heavy workload that oil and gas activity imposes on military personnel, the deficiencies of the permitting and monitoring processes in Suffield, and the issues surrounding access to the Base. “Until this year it was harder for one of my own employees to get access on that Base than for an oil and gas worker,” said the Base Commander. “That was unacceptable.”

October 20, 2008
The Suffield Hearing informal session is held in Medicine Hat to give members of the public the opportunity to present their views about EnCana’s proposed project in the Suffield National Wildlife Area (NWA). Several people, including the Grasslands Naturalists, Nature Saskatchewan, and a local landowner strongly oppose EnCana’s proposed project in their presentations, with the applause clearly showing community support. Two presentations from the petroleum industry support EnCana’s application.

October 18, 2008
The Suffield Hearing informal session is held in Calgary to give members of the public the opportunity to present their views about EnCana’s proposed project in the Suffield National Wildlife Area (NWA). It begins with a presentation by EnCana on the proposed project. The summary once again contains multiple assurances of “no significant adverse environmental effects” should the project go ahead.

Several presentations by concerned citizens follow. Among these presentations are references to passionate defence of the Suffield NWA as a refuge for wildlife; a local farmer’s perspective of the importance of native prairie ecosystems; the importance of denying EnCana’s application so as not to set a dangerous precedent for national protected areas; EnCana’s poor environmental record on the base; and the fact arthropods (spiders and insects), making up 95 percent of wildlife species in the Suffield NWA, were ignored within EnCana’s Environmental Impact Statement (EIS).

October 17, 2008 – EnCana Hearing Day 9
Cross-examination of the EnCana resumes. During the Panel members’ questioning, EnCana commits to extending the project over four or five years, rather than the proposed three, should the Panel so decide, using the first year as a “test” of the Pre-Disturbance Assessment process. EnCana also makes the expected commitments to openness and transparency, should the project be approved. In response, a Panel member cites the Suffield Coalition’s past use of the Freedom of Information process to learn about EnCana’s compliance record on the Base as an example of EnCana’s lack of transparency.

The Joint Review Panel chair reads the Panel’s decision regarding the Suffield Coalition’s request to compel Alberta Environment and Alberta Sustainable Resource Development to take the stand at this hearing because of their responsibilities in and knowledge of Suffield: the issuing of water licenses, knowledge of species at risk, regulation of reclamation, and participation in the Suffield Environmental Advisory Committee. The Panel is not satisfied that, according EUB criteria (Decision 94-2), there is enough reason to compel them to attend and the motion is denied.

In the day’s final hours, the Department of National Defence provides their opening statement.

October 16, 2008 – EnCana Hearing Day 8
For approximately 8 hours, the Suffield Coalition sits under cross-examination by EnCana’s solicitor, counsel for the Joint Review Panel, and the three members of the Joint Review Panel. Through their responses, Coalition members clarify and expand on many of the points brought forward in their opening statements yesterday, once again revealing the numerous deficiencies in EnCana’s Environmental Impact Statement and reservoir analysis. In addition, the Coalition’s responses offer detailed information about the function, sensitivity, and importance of the grassland ecosystems in the National Wildlife Area (NWA), the potential effects of human-created linear disturbances and “edge” on NWA wildlife, the invasion by non-native species that is likely to accompany human disturbance, the difference between reclamation and restoration, and the importance of the latter in the NWA, the purpose of NWAs to protect species at risk and ecological integrity, and the high public costs associated with EnCana’s proposed project.

October 15, 2008 – EnCana Hearing Day 7
Following the Joint Review Panel solicitor’s cross-examination of EnCana, three Panel members had an opportunity to question the EnCana. Several hours are spent asking for clarification regarding a number of aspects of EnCana’s proposal, including the apparent contradiction in the company’s recognition of the importance of the National Wildlife Area (NWA) while proceeding with the same pace of development in the NWA as in the rest of C.F.B. Suffield. When asked about critical habitat for rare plants, a reclamation and plant specialist for EnCana questions the idea of critical habitat, stating that a reduction in human activity, including traffic, might actually be a threat to rare plant habitat. The Panel member who had asked the question replies by asking if he had “disdain for the idea of critical habitat,” EnCana states several times that this project could be beneficial to at-risk species by creating habitat, citing the Ord’s kangaroo rat as one example. The Suffield Coalition points out in their opening statements that recent studies show that human-created kangaroo rat habitat in Suffield is actually “sink habitat,” where mortality exceeds recruitment of animals.

The Suffield Coalition’s three-hour opening statement begins and includes a presentation from each of the seven experts. The joint statement covers all aspects of the project including economics, biodiversity, species at risk, vegetation, cumulative effects, and legislative and policy context for the proposed project. Much of the opening statement focuses on the serious inadequacy of EnCana’s Environmental Impact Statement, which concluded that environmental effects of the project would be insignificant and negligible.

October 14, 2008 – EnCana Hearing Day 6
The Joint Review Panel’s solicitor spends the day cross-examining the project proponent, EnCana, about their calculations and forecasts regarding the amount of incremental gas recovery, should the project be approved and the well density increased from the current 8 wells per section to 16 wells per section. EnCana stated that even if the additional 1,275 wells are drilled, only 43% of the resource could be extracted. The week prior, when asked by the Suffield Coalition lawyer if they would commit to not returning in future to apply for further drilling to extract some or all of the remaining reserves, EnCana’s reply was “No.”

October 10, 2008 – EnCana Hearing Day 5
The Government of Canada (GoC) continues its cross examination of EnCana, particularly the role of the Suffield Environmental Advisory Committee (SEAC). The GoC establishes that there are many gaps in the system and learn that the Alberta Government blocked a formal submission from SEAC to the hearing. At the request of the Environmental Coalition, the panel will decide whether to subpoena Alberta Environment and Alberta Sustainable Resource Development, both members of SEAC, to appear before the court. It comes to light that proper environmental reviews, required under the master agreement between Canada and Alberta for oil and gas operations on the Suffield National Wildlife Area, were not carried out.

October 9, 2008 – EnCana Hearing Day 4
The Government of Canada continues its cross examination of EnCana. During cross examination they confront EnCana with many pictures of damage created by EnCana and they demonstrated that EnCana only has a superficial knowledge of the Species at Risk Act, which is significant given the number of SARA-listed species in the Suffield National Wildlife Area. Essentially, EnCana is asking for the permitted destruction of species at risk.

During cross examination, EnCana admits that wildlife will be killed as a result of the project and that the development will have an impact in the areas outside the NWA in native grasslands. The impact was not considered in their cumulative effects analysis.

October 8, 2008 – EnCana Hearing Day 3
The Suffield Coalition finishes its cross-examination of EnCana early in the afternoon. Key areas include pre-disturbance assessments that improperly locate wells and pipelines in wetland buffers, problems with reclamation, inadequate cumulative effects analysis, and EnCana’s behavior in and around the National Wildlife Area, including the construction of a pipeline without required authorization. The Government of Canada begins its cross-examination of EnCana with significant coverage of the environmental effects of water use for the project.

October 7, 2008 – EnCana Hearing Day 2
The second day of the hearing for EnCana’s proposed shallow gas infill project in the Suffield National Wildlife Area (NWA) is largely taken up with the Suffield Coalition’s counsel cross-examining EnCana and their environmental consultants who prepared portions of the Environmental Impact Statement for the proposed project. The Coalition lawyer’s questioning focused on the sensitivity of the soils in the NWA to oil and gas disturbance, and on the introduction and spread of non-native species in the NWA. A lawyer, landowner and member of Grasslands Naturalists (one of the seven Coalition groups) cross-examined the project proponent, challenging EnCana’s analysis of the projected incremental gas production from the proposed project. Counsel for the Suffield Environmental Advisory Committee (SEAC) questioned EnCana regarding their proposed expanded role for SEAC, should this project be approved.

October 6, 2008 – EnCana Hearing Day 1
The first day of the high-profile hearing in Calgary for EnCana’s application for a large shallow gas project in the Suffield National Wildlife Area (NWA). Anyone can attend the hearing and anyone can present to the Joint Review Panel, time permitting.
Most of the morning is taken up with EnCana’s opening statement, in which the company assured the federal/provincial Joint Review Panel that the project would have “insignificant” impacts on the area and its wildlife. The Suffield Coalition’s lawyer then cross-examined the company representatives for the rest of the day (AWA is one of the seven conservation groups making up the Coalition.) Much of the questioning focused on the amount of disturbance the project would create, both in the construction process and the ongoing servicing of wellsites, and on the weaknesses of EnCana’s Environmental Impact Statement. When asked if the company had done studies of rare plants, including three listed endangered or threatened by Canada’s Species at Risk Act, and of a number of sensitive and endangered wildlife species such as the burrowing owl, Ord’s kangaroo rat, and Sprague’s pipit, EnCana’s answer was consistently “no,” along with the assurance that those studies would be part of the Pre-Disturbance Assessments. PDAs are conducted AFTER the approval of a project.

On September 18, EnCana appears in court for the eighth time on charges of violating the Canada Wildlife Act and a preliminary hearing is set for April 20-24, 2009.

On August 26, during EnCana’s seventh appearance in court on charges of violating the Canada Wildlife Act, a court date for September 18 is set. A trial date will be determined at the next appearance.

On August 12, EnCana appears in Medicine Hat Court for the sixth time on charges of violating the Canada Wildlife Act and enters a plea of Not Guilty.

On June 26, EnCana appears in Medicine Hat Court for the sixth time on charges of violating the Canada Wildlife Act. The case is adjourned to August 12, 2008. EnCana has not yet entered a plea. “This is the third counsel in a row who has come on with respect to these matters,” said Judge Legrandeur, when EnCana changed lawyers once again. “They’ll certainly require more time to review the disclosure.”

On May 29, EnCana appears in Medicine Hat Court for the fifth time on charges of violating the Canada Wildlife Act. The case is adjourned to June 26.

On April 24, EnCana appears in Medicine Hat Court for the fourth time on charges of violating the Canada Wildlife Act. The case is adjourned to May 29.

On April 22, Nature Canada appears at the EnCana AGM in Toronto on behalf of the Suffield Coalition. During the question period, Nature Canada makes a statement about EnCana’s proposal to drill in the Suffield National Wildlife Area and asks the following questions:

Why is EnCana planning to drill in a National Wildlife Area (NWA)?
If EnCana is confident that their operations do not, and will not, impact the NWA negatively, why does the Annual Report not include this project application and EnCana’s current operations under wildlife stewardship?
What is the risk that the permit will be denied?
What are the mitigation and restoration costs for this project?
What is the risk to EnCana’s reputation of seeking to drill in a protected area with so many species at risk?

On March 4, EnCana appears in Medicine Hat Court for the third time on charges of violating the Canada Wildlife Act. The case is adjourned to April 24, 2008.

On March 3, the Joint Review Panel announces that it is granted EnCana’s request for a delay of the hearings, which are now scheduled to begin on October 6, 2008.

On February 22, in response to the Joint Review Panel’s request for comments on EnCana’s request for a delay in the hearings, the Suffield Coalition’s lawyer lists a number of reasons to deny the request, concluding: “It is unfair to the Coalition to grant EnCana extra time to attempt to bolster a deficient EIS [Environmental Impact Statement] through an IR [Information Request] process and is an abuse of the process.”

On February 21, EnCana requests a delay of the Suffield hearings, currently scheduled to begin on March 10, proposing September 29 as the start date. The company claims that it needs time to ask for clarification on the submissions of the Suffield Coalition, of which AWA is a part, and the Government of Canada.

On February 18, the Suffield Coalition – comprising AWA and five other conservation groups – files its submission opposing EnCana’s development to the Joint Review Panel. The Coalition’s submission contains a wealth of information, including cumulative effects assessment, footprint, soils and vegetation, economics assessments, policy analysis and impacts on grasslands birds, among other topics.

On February 13, AWA initiates a FOIP request, asking for the amount of EnCana’s original payments (going back to Alberta Energy Corp.) for the mineral leases within the Suffield National Wildlife Area. AWA also requests information about the total amount paid by EnCana (since 1975) in surface access fees/compensation in the National Wildlife Area since Alberta Energy Corporation’s first exploration of the NWA.

In January, EnCana appears in Medicine Hat Court for the second time on charges of violation the Canada Wildlife Act. The case is adjourned to March 4.

2007

On December 6, EnCana appears in Medicine Hat Court on charges of violation the Canada Wildlife Act. In 2005, the company constructed a 265-meter pipeline within the SNWA without a permit. EnCana is also being investigated for disturbing an endangered plant, the sand verbena.

AWA, as a part of a coalition that includes Federation of Alberta Naturalists, Grasslands Naturalists, Nature Canada, Southern Alberta Group for the Environment, and World Wildlife Fund, asks the federal government to prohibit all new industrial activity in the Suffield National Wildlife Area.

2006

On October, the Coalition receives $140,430 from the Participant Funding Program set up by the Canadian Environmental Assessment Agency. The funds are to be used by AWA, Nature Canada, and Grasslands Naturalists to review guidelines for the Environmental Impact Statement (EIS), to the review the EIS itself, and to participate in the public joint federal-provincial hearings.

In August, a coalition of conservation groups, including AWA, file a petition with Federal Environment Minister asking her to protect the tiny cryptanthe and small-flowered sand verbena. Both of these grassland species are at immediate risk of extinction, yet Alberta has no endangered species legislation in place to protect them. The coalition gives the minister 60 days to recommend federal protection for these two endangered plants, or face a lawsuit aimed at compelling the minister to take action.

In April, after being pressured by AWA and several other environmental groups, the federal Minister of the Environment announces that an independent panel will review the EnCana proposal to drill as many as 1,275 gas wells, with associated infrastructure, in the National Wildlife Area.

In January, the C.F.B. Suffield Base Commander states, “There should be no further oil and gas activity in the National Wildlife Area… This is one of the last vestiges of untouched prairie that exists in Western Canada. To me, it’s a national treasure” (Edmonton Journal, “Skirmish over Suffield’s Sanctuary”).

A Suffield Training Area Management Plan notes that oil and gas activity is having significantly more impact than military training. Impacts include habitat fragmentation, spread of invasive species, poor reclamation practices, and a lack of recovery in most areas. Military activity has not occurred in the National Wildlife Area since 1971 because of the area’s sensitivity, yet industry use continues despite a litany of environmental impacts documented in the government record.

2005

In December, AWA meets with EnCana representatives. AWA is informed that CEO Gwyn Morgan has said that if the science says EnCana should not drill in the National Wildlife Area, they won’t (WLA, December 2005).

In October, the Canadian Environmental Assessment Agency announces the commencement of a federal Environmental Assessment (EA) to review the EnCana shallow gas infill project proposal in the Suffield National Wildlife Area.

EnCana proposes to drill 300 to 400 new shallow sweet natural gas wells each year for the next three years, totaling 1,275 wells, in the Suffield National Wildlife Area. This will result in 16 or more wells per section and 220 kilometres of additional pipeline, doubling the number of wells in this area. This development means significant new infrastructure, including new access roads, water development, areas for disposal of drilling fluids (sumps), and increased compressor capacity. In response to this proposal, Canada’s Department of National Defence, as the responsible authority, declares its intention to undertake a comprehensive study and provide opportunities for public participation.

In September, on the eve of the strict deadline set by the Base Commander, EnCana removes the well drilled the previous year in a wetland area, on the threat of being barred from the base.

2004

In October, EnCana drills a well in a wetland area in Nishomoto Flats in the Middle Sand Hills Area of Concern. Federal policy on wetlands stipulates no industrial activity in wetlands on federal land, and provincial guidelines require a minimum distance of 100 m from wetlands. The Base Commander immediately requests the removal of the well, to no avail.

The Base Commander implements a drilling moratorium. More than 1,100 wells now exist in the Suffield National Wildlife Area.

2003

The C.F.B. Suffield National Wildlife Area (NWA) is formally established. Land-use activities – including resource extraction, agricultural development, and water management projects – will now be subject to approval and mandatory environmental screening.

2002

Alberta Energy Company (AEC) merges with Pan-Canadian to form EnCana.

Late 1990s

Alberta Energy Company (AEC) requests that the Alberta government put the mineral dispositions to deeper formations under CFB Suffield up for auction. In order to do so, some of the surface access rights assigned to AEC under the 1975 and 1977 MOAs have to be transferred back to the provincial government. The amendment, called the Partial Assignment Agreement (PAA) is signed in 1999 by the Province of Alberta, AEC, and a new entity, the Suffield Industry Range Control Ltd. (SIRC).

1997-1998

A herd of elk is introduced to the C.F.B. Suffield National Wildlife Area from Elk Island National Park. Elk ceased were locally extirpated from the area after 1960 due to poaching.

1994

1,200 feral horses are removed from Middle Sand Hills/Suffield area.

1992

The Department of National Defence and Environment Canada sign a Memorandum of Understanding to reserve approximately 458 km² of the military base as a National Wildlife Area under regulations of the Canada Wildlife Act. Public and military access to this portion of land is prohibited.

1991

AWA proposes that an area on the east side of the South Saskatchewan River, stretching north to include a portion of the Red Deer River and south almost to the Trans-Canada Highway, be designated a biosphere reserve as a part of the UNESCO Man and Biosphere program. Unfortunately, discussion of this proposal is terminated by National Defence Headquarters.

1984

In March, Environment Canada releases a proposal to create a 25,000 ha Suffield Cooperative Wildlife Management Area in the northeastern corner of the military reserve that would include the Middle Sand Hills as well as a 47 km length of the South Saskatchewan River valley.

AWA requests a detailed assessment of the Suffield military reserve’s ecological resources and urges public involvement in management of the reserve.

1982

The Prairie Farm Rehabilitation Administration (PFRA) grazing lease expires. AWA proposes that the lease be cancelled as of the expiry date and a new system of grassland management be implemented.

1977

A Memorandum of Agreement (MOA) between Alberta and Canada allows for access to oil in Suffield. This and the 1975 MOA identify Alberta Energy Company Ltd. (AEC) as Alberta’s assignee to develop oil and gas in Suffield. As the sole operator, all mineral leases are granted to AEC.

The Department of National Defence signs a Memorandum of Understanding (MOU) with the Prairie Farm Rehabilitation Agency (PFRA) allowing cattle to graze between June and October in areas not normally used for military practice and experimentation. There is no grazing in the Middle Sand Hills themselves.

In a report entitled “Effects of Livestock Grazing on Mixed Prairie Range & Wildlife in PFRA Pastures, Suffield Military Reserve,” the Canadian Wildlife Service and Alberta’s Fish and Wildlife Division conclude that grazing on C.F.B. Suffield has negatively affected vegetation and species of avifauna.

1976

The Prairie Farm Rehabilitation Agency (PFRA) closes pasture land in light of the absence of drought conditions and in order to allow for regrowth. Though the military enforces the grazing ban, many instances of trespassing and illegal grazing are reported.

1975

A cursory examination by the Canadian Wildlife Service (CWS) reveals that the land in the Middle Sand Hills is greatly overused, if not overgrazed. CWS requests that grazing be terminated and the impact of grazing studied in detail.

The Prairie Farm Rehabilitation Agency (PRFA) again operates summer pasture to help alleviate the strain of drought conditions on local ranchers. Heavy usage has resulted in range deterioration and in insufficient forage, shelter, and cover for wildlife.

The Range-Wildlife Study Committee meets at C.F.B. Suffield on November 3 and 4 to discuss the impact of the PFRA livestock grazing on the Middle Sand Hills/Suffield area. The report finds that “preferred climax grasses were inconspicuous while unpalatable shrubs and forbs comprised most of the standing crop. Soil movement, hillside terracing and sand blowouts were evident while natural spring areas were being damaged.”

A Memorandum of Agreement between Canada and Alberta allows development of gas reserves. Before development proceeds, Alberta Energy Corporation (AEC) must identify archaeological sites in the Suffield Block so that protective measures can be taken. Oil development, production, and transmission for the South Saskatchewan River Bank Zone must be limited to wells recommended for approval by the Suffield Environmental Advisory Committee (SEAC). No oil development in the Middle Sand Hills Zone is allowed until completion of an Environmental Impact Assessment.

Representatives from various national and provincial environmental agencies form the Suffield Environmental Advisory Committee (SEAC) advise the Base Commander on the environmental impact of development.

In March, AWA presents ideas to the Alberta Land use Forum. The AWA believes that exploration and exploitation of oil and gas is acceptable so long as damage to the fragile vegetation cover is minimized; and that cattle grazing must be ended when drought conditions subside.

1973-1974

The Prairie Farm Rehabilitation Agency (PFRA) operates summer pasture to help alleviate the strain of drought conditions on local ranchers.

1973

An agreement is signed between the Department of Regional Economic Expansion (DREE) and the Department of National Defense (DND) allowing grazing in the sensitive areas of Suffield.

The Canada Wildlife Act is passed in order to protect significant wildlife habitat.

1972

The military reserve is transferred back to Canadian Armed Forces.

A Resource Evaluation of the Suffield Block is prepared for the Province of Alberta. The evaluation, describing the area in detail, suggests the conservation of various tracts of land and that the absence of a temporary management plan should not preclude the initiation of oil industry activity.

1971

In August, the Government of Canada releases a report entitled Environmental considerations on the use of the Suffield Military Reserve for tank and artillery training. The report suggests that three natural reserve areas (a Middle Sandhills Natural Area, a Mixed Grasslands Natural Area, and a one-mile River Buffer Strip) be created for the protection of ecologically valuable areas.

In June, the Canadian Wildlife Service (CWS) publishes an Ecological Appraisal for Suffield.

In October, AWA receives a letter from Jean Chretien, Minister of Indian Affairs and Northern Development, acknowledging receipt of AWA correspondence and agreeing that the Suffield area possesses national park potential. However, Chretien states that until the land becomes surplus to the needs of the Department of National Defence, there is no possibility of creating a national park.

The Canadian Forces Base (C.F.B.) Suffield is established as a live fire training area. However, sensitive areas, including the Middle Sand Hills, are declared off-limits to the military.

1961- 1964, 1968

The Prairie Farm Rehabilitation Agency operates summer and winter pasture to help alleviate the strain of drought conditions on local ranchers.

1947

The Middle Sand Hills area is transferred to the Canadian Research Board for chemical and biological weapons testing. The specific nature of this activity is classified and any possible effects are not known.

1942

Suffield is designated Federal Crown land.

1941

A large portion of the area is expropriated by the Dominion Government in order to secure the area as a chemical warfare testing ground for the British, who lost access to lands in Algeria following the German occupation of France.

1938

Recovering populations of pronghorns result in the closure of Wawaskesy National Park (House of Commons Bill 154). In this same year, the area is declared unfit for agriculture under Alberta’s Special Areas Act.

1926-1941

Drought conditions result in the consolidation of small farms into large ranches.

1922

The antelope sanctuary is officially designated Wawaskesy National Park, although this land is also initially used for livestock grazing. When livestock pushes out the population of pronghorns, measures are taken to limit the numbers of livestock.

1915

140 km² of the Middle Sand Hills area is designated as a pronghorn antelope sanctuary.

1906-1907

Canadian pronghorn populations are decimated by severe winters. To speed the recovery of pronghorns, refuges are established on federal land in both Alberta and Saskatchewan.

Early 1900s

The Canadian government promotes settlement and cultivation on the Canadian plains. A first wave of homesteading occurs in 1911 and 1912, a second wave occurs in 1915, and a third wave begins with the return of World War I veterans in 1919, who are given land under the Soldier Settlement Plan. Many homesteads in this area are dry and unsustainable, and are abandoned over time.

1883

The coming of the Canadian Pacific Railway leads to the establishment of the nearby town of Suffield and surrounding ranches.

1880

Cattlemen begin to settle the area.

1860-1880

Bison decline rapidly and are virtually exterminated.

1877

Treaty 7 is signed at Blackfoot Crossing approximately 150 km west of the Middle Sand Hills. With Treaty 7, the Blackfoot Confederacy unknowingly signs lands over to the Dominion of Canada and is forced to move onto reservations.

1850s-1860s

Captain John Palliser explores the Middle Sand Hills area.

August 1, 2010

Continuing Failure to Protect Burrowing Owl Habitat in Suffield

Wild Lands Advocate update, October 2010, by Nigel Douglas 201010_ar_wla_update_burrowing_owl.pdf

May 25, 2010

News Release: Suffield Coalition Concerned About Delay in Government Response. National Wildlife Areas Needed to Help Fight Extinction

The Suffield Coalition today expressed concern about the failure by the Government of Canada to…

March 12, 2010