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EnCana Corporation (EnCana) proposes to carry out an infill development project (the Project) within the boundaries of its existing developed shallow gas field in the Canadian Forces Base (CFB) Suffield National Wildlife Area (NWA) in southeast Alberta.

The Project is subject to environmental assessment pursuant to the Canadian Environmental Assessment Act (CEAA), due to the need for a permit pursuant to the Wildlife Area Regulations. The administration of the NWA was delegated to the Department of National Defence (DND), thus the regulatory authority (RA) will be the DND. The Project also requires approvals from the Alberta Energy and Utilities Board (EUB), which has a mandate to consider, in the context of its conservation mandate, the environmental effects of the Project in regulating the development of the natural gas. Therefore, a Joint Review Panel (the Panel) has been established by the federal Minister of the Environment (on behalf of Canada), and the EUB (on behalf of the Province of Alberta) to conduct an efficient and coordinated review of the environmental effects of the Project.

The Environmental Impact Statement (EIS), which includes supporting documentation in this and accompanying volumes, has been prepared by EnCana in accordance with the Guidelines for the Preparation of the Environmental Impact Statement issued by the Panel (see Appendix A).

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1.1 Overview of the Project
1.1.1 History
In 1975, EnCana (formerly Alberta Energy Company Ltd. (AEC)) initiated resource development at CFB Suffield. The area was recognized as comprising, a measurable source of sweet natural gas. By the end of 2004, this shallow natural gas Project had produced more than 2.3 trillion cubic feet of natural gas. EnCana has drilled more than 9000 wells at CFB Suffield. Within the area now designated as the NWA there are presently 1145 shallow gas wells.

EnCana's operations at CFB Suffield are governed pursuant to an Agreement dated October 28, 1975, between the Government of Canada, as the surface rights owner at CFB Suffield, and the Government of Alberta, as the owner of the majority of the mines and minerals underlying CFB Suffield (the 1975 Access Agreement). Pursuant to the terms of the 1975 Access Agreement, Canada granted to Alberta, the right of access to, entry upon, and occupation and use of such portions or areas of CFB Suffield as may be required to carry on a program of drilling, production, collection, and transmission of natural gas. In 1975, AEC acquired all of the rights and interests under the 1975 Access Agreement as well as all of its' shallow gas rights within CFB Suffield from the province of Alberta.

In 1992, DND and Environment Canada signed a Memorandum of Understanding, which started the process of designating the eastern 458 square kilometres (km²) of CFB Suffield as a NWA. The NWA was formally declared in 2003. EnCana was recognized and commended in the regulatory impact analysis statement for the creation of the Suffield NWA, for the support it has provided for the creation of the NWA and for its responsible stewardship over the past 30 years that contributed to the NWA designation.

At the time the NWA was created, it was contemplated that ongoing land use in the area, including resource development, was expected to continue thereafter. This ongoing use is specifically recognized in the Regulatory Impact Analysis Statement for the NWA.

1.1.2 The Proposal
EnCana proposes to drill 1,275 infill wells over three drilling seasons (commencing in the fall of 2008) to extract the remaining shallow tight sweet gas from the NWA. Infill drilling is incremental drilling that occurs within the boundaries of an existing, developed gas field. The additional infill wells will serve to effectively produce the remaining recoverable gas reserves in the NWA.

Each well within the Project area will take approximately three days to construct (including drilling, fracture treatment, completion, and tie-in). Wells will be tied in to existing and new pipeline infrastructure by 50.8 mm (2 in.) inside diameter (I.D.) high-density polyethylene plastic pipe (HDPE) which will be ploughed in to minimize surface disturbance. Approximately 40 km of new 101.6 mm, 152.4 mm, and 203.2 mm (4, 6, and 8-in.) I.D. steel pipe will be required to effectively transport the additional gas volumes to compressor stations outside the NWA. Additional infrastructure required for the Project and within the NWA, includes pig launchers and receivers, meters, and isolation valves. Remote sumps for disposing of drilling wastes are anticipated for the Project; however, they will not be within the NWA. Existing access roads will be used; no new roads will be constructed. Whenever possible, existing access routes and trails will be utilized.

The footprint of each well will be minimized, with an exposed wellhead during operation within a well pad area of typically less than five by six metres (m). Production is anticipated to continue for approximately 20 to 40 years (the Operations Phase). During operations, some standard maintenance activities, such as routine well testing, swabbing (water removal), re-completions, and pipeline integrity inspections, will be undertaken to ensure that the infrastructure performs safely and efficiently.

When each well has reached the end of its producing life, it will be secured and abandoned in accordance with EUB requirements (or any and all provincial and federal regulatory and legal requirements in effect at the time) and in consultation with DND. EnCana will employ effective conservation and reclamation measures to ensure land disturbed by the Project is reclaimed to meet the goal of equivalent land capability. Equivalent land capability means restoration of the land by virtue of reclamation and conservation measures so that it is able to support various land uses similar to those that existed before an activity was conducted on the land. Disturbed land will be reclaimed using appropriate site-specific methods determined in consultation with the regulators. The amount of time required for land to be reclaimed will depend on the reclamation technique applied, environmental setting and the specific type of development.

1.1.3 Special Considerations in the Suffield NWA
The NWA is a special native prairie grassland area that is home to more than 1,100 species of wildlife and vegetation. EnCana has been operating in this area for more than 30 years, and has always recognized the need to use special minimal disturbance techniques to mitigate the effect of its activities. EnCana's recognition of the unique aspects of the area is consistent with EnCana's support, throughout the years, for the NWA designation.

EnCana continually strives to minimize the environmental effects of its operations. EnCana undertakes extensive studies of all aspects of the local environment as part of its planning processes. From initial planning, through development and final reclamation, EnCana employs a variety of minimal disturbance techniques, and best practices, that reduce disruption to wildlife and protect native prairie grasslands.

Thorough preparation and Project planning is the first and most important aspect of minimal disturbance practices. To determine the least disruptive locations for access roads, well sites, pipelines, and associated infrastructure, EnCana uses baseline mapping, which identifies and attempts to avoid ecologically and culturally sensitive areas. On-site surveys (Pre-Disturbance Assessments (PDAs))for vegetation, wildlife, wildlife habitat and historical resources are done by environmental specialists prior to construction. Environmental specialists, along with construction and survey crews, determine optimal locations for wells and pipelines, based on environmental and other considerations. Once sensitivities are identified, appropriate measures are taken to reduce potential environmental effects.

EnCana's drilling activities at Suffield are done when ground is dry or frozen, protecting delicate prairie grasses and wildflowers, limiting soil erosion, and helping avoid the creation of vehicle tracks. Construction activities in the NWA will avoid sensitive times for burrowing owl and other sensitive species, such as Ord's kangaroo rat. Protecting the snake population at CFB Suffield is another important aspect of EnCana's environmental protection plans: EnCana takes unique and robustly developed mitigation measures regarding these snakes from May through October when snakes (particularly the prairie rattlesnake) are active. For example, EnCana abandoned an area road in the snake migration area to limit snake mortality.

A new generation of drilling technology and specialized equipment enables EnCana to drill and complete wells in less time and with fewer environmental effects than ever before. EnCana strives to adapt its technology and practices whenever possible to minimize environmental effects. Specialized construction techniques (such as using lighter coil tubing rigs to minimize ground disturbance and ploughing in pipelines where possible rather than conventional trenching that needs a wider right-of-way [ROW]) are used to ensure that the footprint and environmental effects of EnCana's activities in the area are minimized. Ploughing in plastic (HDPE) pipelines is a practice EnCana uses throughout CFB Suffield, when appropriate, to reduce the environmental effects, particularly in sandy soils.

Narrower work areas are required for pipelines (no stripping for HDPE pipelines that are ploughed in), and shallow gas lease site areas are not stripped of topsoil or vegetative cover. Wherever possible, EnCana makes use of existing access that is present on CFB Suffield. All EnCana employees and contractors are required to observe speed limits and road safety guidelines for protecting wildlife.

In addition to planning and operational measures, EnCana supports research in the area to improve its understanding of the ecosystem and to assist in future planning and mitigation. Most recently, EnCana provided funding to support researchers in investigating the seed caches created by the Ord's Kangaroo Rat. The study has improved EnCana's understanding of what these indigenous animals eat and will further assist EnCana's future reclamation practices, by enabling more accurate approximation when conducting reseeding activities and of actual plant mixes that are part of this animal's diet.

The fact that this location was declared a NWA after the drilling of more than 1,100 wells by EnCana is indicative of the minimal environmental footprint of EnCana's operations.

1.2 The Proponent
The proponent of the Project is EnCana Corporation. EnCana was formed in 2002 through the merger of Alberta Energy Company Ltd. (AEC) and PanCanadian Energy Corporation. As of the submission of the EIS, EnCana is the largest natural gas producer in Canada and the second largest natural gas producer in North America. EnCana's primary focus is on the development of unconventional resource plays, which are accumulations of hydrocarbons known to exist over a large areal expanse and thick vertical section, which, when compared to a conventional play, typically have a lower geological and commercial development risk and lower average decline rate. EnCana is among the largest owners of oil and gas rights in onshore North America, and the Company has approximately 6,500 employees and contractors on staff.

1.2.1 Corporate Governance
EnCana's business is overseen by its Board of Directors. EnCana's leadership and executive team are accountable to this Board. EnCana's Board requires that fairness and transparency in decision making and management practices be employed by all levels of management and employees, based on the values expressed in EnCana's Corporate Constitution. EnCana has a rigorous corporate governance structure creating a system of checks and balances which ensure compliance with the Corporate Constitution, as well as the laws and regulations in all jurisdictions within which EnCana operates.

1.2.2 Corporate Responsibility
As articulated in its Corporate Constitution, EnCana functions based on trust, integrity, and respect. EnCana is committed to benchmark practices in safety and environmental stewardship, ethical business conduct, and community responsibility.

EnCana has established business standards that clearly demonstrate expectations of its employees and contractors on a day-to-day, individual level. Policies ensure a common understanding among EnCana's workforce of the business, legal, and regulatory processes the Company follows. Practices outline how EnCana undertakes tasks and procedures. As a result, employees and external parties alike are able to determine what they can expect from EnCana. EnCana's policies and practices can be referenced on its external website.

The Corporate Responsibility Policy commits EnCana to conducting its business ethically, legally, and in a manner that is fiscally, environmentally, and socially responsible, while delivering sustainable value and strong financial performance for its shareholders. This commitment to corporate responsibility applies to everything EnCana does and to everywhere EnCana operates. To ensure that EnCana lives up to its commitments, the Board of Directors established a committee in 2003 to oversee corporate responsibility issues. As well, EnCana reports on its corporate responsibility performance online, in its annual reports, and in a stand-alone corporate responsibility report.

The Corporate Responsibility Policy has eight focus areas - (i) leadership commitment, (ii) sustainable value creation, (iii) governance and business practices, (iv) human rights, (v) labour practices, (vi) environment, health and safety (EHS), (vii) stakeholder engagement, and (viii) socio-economic and community development. The Corporate Responsibility Policy is supported by a framework of management systems, practices, and guidelines providing more specific guidance on key elements of the policy.

EnCana takes its performance and obligations seriously. Employees are encouraged to discuss concerns about integrity with their supervisors or human resources contacts. Those who regularly work or interact with EnCana can report concerns to their primary contact at the company. If, for any reason, these channels are not appropriate, EnCana has established an Integrity Hotline and an Investigations Committee to address any issues raised.

Any sudden and accidental pollution that occurs during operations will be covered by EnCana's excess liability policy, up to US$300 million. In addition, the well control insurance will cover up to US$20 million.

1.2.3 Project Management
The Project will be managed by EnCana's Suffield Gas Property Team within the Medicine Hat Business Unit. As is the case with all of EnCana's activities, the Project will be managed in compliance with all applicable laws, regulations, and standards, and with EnCana's policies and practices, including EnCana's Environmental, Health and Safety Best Practice Management System.

Management plans will apply to the Project and are an integral part of EnCana's Corporate Responsibility Policy framework. These will include a Project specific Environmental Protection Plan (EPP), an Emergency Response Plan (ERP) and an Environmental Effects Monitoring Plan (EEMP). These plans have been or will be developed, updated and adapted as required throughout the life of the Project.

1.2.4 Preparation of the Environmental Impact Statement
EnCana retained independent expert consultants specifically knowledgeable in the environmental issues relevant to the Project area. EnCana also retained environmental consultants knowledgeable in EIS preparation and methodology. Table 1-1 list the consultants who aided EnCana in the preparation of this Application.

Table 1-1 Consultant List
Consultant	Name and Position/Title	EIS – Related Responsibility
Tesera Systems Inc.	Bruce MacArthur, B.Sc.F Principal	Project Management Public Consultation
	Kevin Pettersen, M.Sc.,  MFC Principal	Project Management Information Management
URSUS Ecosystem Management Ltd.	John Kansas, M.Sc., P.Biol. Senior Scientist / Principal	EA Coordination Vegetation Assessment Wetlands Assessment Biodiversity Assessment
	Doug Collister, P.Eng., M.E.Des., P.Biol. Senior Scientist / Principal	Wildlife and Habitat Assessment
RWDI AIR Inc.	Sachin Bhardwaj, B.Sc. Senior Scientist	Air Quality Assessment
Canada North Environmental Services	Peter Vanriel, B.A., B.Sc., M.Sc., P.Biol. Senior Aquatic Biologist	Water Quality and Fisheries Assessment
LandWise Inc.	Ron McNeil Resource Scientist	Soils Assessment
Gartner Lee Limited	Robert C. Dickin, M.Sc., P.Geo. Senior Hydrogeologist	Groundwater Assessment
nhc Northwest Hydraulic Consultants	William Rozeboom, MBA., P.Eng. Senior Engineer	Surface Water Assessment
Bison Historical Services Limited	Thomas Head, MA, Senior Archaeologist	Historical Resources Assessment
AMEC Earth & Environmental	John P. Thompson, MES Senior Resource Economist, Human Environment Group	Socio-Economic Assessment
Cantox Environmental Inc.	Dr. Gordon Brown, Ph.D. Senior Scientist	Human Health Risk Assessment
Patching Associates Acoustical Engineering Ltd.	Richard G. Patching, M. Eng., P. Eng.	Noise Assessment
Jacques Whitford AXYS Ltd.	Steve Fudge Environmental Assessment Project Manager	Technical Review Assessment Methods Document Preparation

 

1.2.5 Contact Information

EnCana's offices: EnCana Corporation

1800, 855 - 2 Street S.W.
P.O. Box 2850
Calgary, Alberta T2P 2S5
Telephone: (403) 645-2000
Fax: (403) 645-3400

Correspondence about this EIS should be directed to the attention of Leanne Campbell:

Principal point of contact: Leanne Campbell

Regulatory Services
EnCana Corporation
421 - 7 Ave S.W.
Calgary, Alberta T2P 2S5
Telephone: (403) 645-8318
Fax: (403) 571-7685
Leanne.Campbell@EnCana.com

Alternate contact: Journey Paulus

Regulatory Services
EnCana Corporation
421 - 7 Ave S.W.
Calgary, Alberta T2P 2S5
Telephone: (403) 645-6258
Fax: (403) 645-6563
Journey.Paulus@EnCana.com

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1.3 Context
1.3.1 Location
CFB Suffield is one of Canada's best examples of successful shared land use. Oil and gas development, military activities and cattle grazing have been concurrently conducted on this 2,690 km² area for more than 30 years. Close cooperation and communication between EnCana, DND, Prairie Farm Rehabilitation Administration (PFRA), regulators and other agencies, and local ranchers have allowed this unique sharing arrangement to work for the benefit of all parties. See Figure 1-1 for the location of the Project.

CFB Suffield is one of Canada's largest military training and testing sites and has been operated by DND since 1941. CFB Suffield is in southeast Alberta, approximately 50 kilometres (km) northwest of Medicine Hat and 250 km southeast of Calgary. In 2003, a 458 km² area of CFB Suffield was designated as a NWA, and currently contains 1,145 shallow gas wells.

Before 1941, the Suffield area was sparsely occupied by ranchers and homesteaders. Only a very small percentage of the land was cultivated, and these lands reverted to prairie as homesteads were abandoned and population of the area declined. Use of the Suffield Block lands for military research began in 1941. CFB Suffield was established in 1971, and it is one of the largest army training bases in the Western world.

Before the initial development at CFB Suffield, AEC conducted archaeological investigations to identify and protect archaeological sites. Archaeologists located 1,692 sites, including five medicine wheels, three bison kill sites, and nine stone cairns, which are now off limits to military and oil and gas activity.

The NWA comprises largely unplowed prairie grassland landscapes of national significance, including sand hills, ancient glacial coulees, and the riverbank and breaks along the South Saskatchewan River valley. The NWA occurs within the Dry Mixedgrass region that dominates the southeast corner of the province. As one of the few remaining large blocks of Dry Mixedgrass Prairie in Canada, the NWA hosts over 1100 catalogued species including 244 vertebrates, 462 plants and 436 invertebrates. Of this rich species assemblage, 14 species are listed by the Committee on the Status of Endangered Wildlife in Canada (COSEWIC) as species at risk, and 78 species are listed in the Status of Alberta Wildlife 2000 as "at risk" or "sensitive".

EnCana's oil and gas activities in CFB Suffield have been inspected annually by the Suffield Environmental Advisory Committee (SEAC) comprised of members from the EUB, Alberta Environment (AENV), and Environment Canada. To date, this committee has been involved in, and made recommendations for, the approval of all development and reclamation activities in the NWA. Cattle grazing has continued within CFB Suffield since the 1960s. In the NWA, grazing occurs only between June and October and is limited to the southern portion of the NWA.

Stringent security and safety protocols are in effect for access to CFB Suffield (including the NWA), which is off limits to the public. There are no communities within the NWA.

The Environmental Setting is described in greater detail in Section 3.

1.3.2 Regulatory Framework
1.3.2.1 Primary Approvals
Natural gas development in the NWA is regulated by several different agencies, and various forms of legislation govern EnCana's operations. The Government of Canada owns the surface rights in the NWA, while the Province of Alberta owns the subsurface rights. Therefore, Alberta (through the EUB) is responsible for regulating the development of mineral resources primarily pursuant to Oil and Gas Conservation Act. Alberta Environment (AENV) has statutory responsibilities related to the Project including approvals required under the Water Act and under the Environmental Protection and Enforcement Act (EPEA).

In order to develop this Project in the NWA, EnCana requires a permit pursuant to section 4 of the Wildlife Area Regulations. The DND is responsible for issuing that permit as administrative control has been delegated for the Suffield NWA to the DND. This federal authorization is included in the Law List Regulations pursuant to the CEAA, and, therefore, an EIS pursuant to the CEAA is required. Minister Ambrose determined on April 24, 2006 that the appropriate process for this EIS was a panel review. On November 16, 2006, a joint review panel was established with two members appointed by the Minister of the Environment and the Chairman of EUB appointing one member.

The following federal departments have self-identified as Federal Authorities (FAs) and will provide specialist advice to the assessment conducted by the Panel:

• Agriculture and Agri-Foods Canada;
• Environment Canada;
• Fisheries and Oceans Canada;
• Health Canada;
• Natural Resources Canada; and
• Parks Canada.

The EUB has statutory responsibilities in relation to the Project, pursuant to the Alberta Energy and Utilities Board Act, the Oil and Gas Conservation Act, the Pipeline Act, and the Energy Resources Conservation Act. The Project will require approvals under those Acts and Regulations.

No provincial environmental assessment is required for the Project. Alberta Environment (AENV) has statutory responsibilities in relation to the Project pursuant to the Water Act and the Environmental Protection and Enforcement Act (EPEA). The Project will require an approval under Section 49 of the Water Act for the use of surface waters (South Saskatchewan River) for the Project. Under the EPEA, AENV also is responsible for regulating the transportation, treatment, and disposal of hazardous wastes.

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1.4 Project Justification
Natural gas is a valuable resource, critical for ongoing consumer and industrial users throughout North America. Besides its obvious economic value, an increasingly important part of this value is the relatively low carbon intensity of natural gas as an energy source. Natural gas has the lowest carbon emissions per unit of energy of all of the hydrocarbon energy sources, generating 41 percent less carbon emissions than coal and 26 percent less than oil per unit of energy. With increasing demands for reductions in carbon emissions, natural gas supply will become increasingly important as natural gas can easily be substituted for other hydrocarbons with higher carbon intensities. Of particular value are natural gas resources that can be developed close to existing infrastructure, with ready access, years of successful experience and low surface impacts. Low carbon intensity energy source developments such as this enables incremental development with minimal environmental effects.

These are the characteristics of what is commonly referred to as southeast Alberta shallow gas, which includes the natural gas targeted by the Project. The Project will make available to North Americans approximately 125 billion cubic feet (bcf) of natural gas - enough natural gas to heat 80,000 homes for a decade. Ultimately, if this natural gas is left in the ground, its energy potential will have to be supplied by some other source of energy.

EnCana has decades of experience and continuous improvement in the development of shallow gas across 1000s of square kilometres in southern Alberta under many different types of surface conditions - cultivated, pastureland, wetlands and native prairie. This experience gives EnCana the expertise necessary to develop within the NWA in an environmentally responsible manner. EnCana and its predecessor companies are leaders in the development of the methods and technologies used today for low disturbance development in the shallow gas fields of southern Alberta - techniques such as minimal ground disturbance drilling, ploughed in pipeline and research into effective reclamation methods.

The economic value to EnCana shareholders and Canadians is based on natural gas being an economically valuable resource of which development and production generates jobs and social economic value through taxes and royalties. However the Project provides additional social value in the development of a low carbon intensity energy source, which otherwise would remain inaccessible. In addition, this energy source can be developed to take advantages of nearby infrastructure and of the sophisticated techniques improved over several decades specifically to reduce the surface disturbance of shallow gas development. EnCana's extensive experience with this type of project throughout southern Alberta and specifically in the Suffield area gives it a unique capability to develop this economically and environmentally valuable resource in a manner that will respect the goals and intent of the Suffield NWA.

1.4.1 Purpose of the Project
The infill development wells are required to effectively produce the remaining recoverable gas reserves in the Suffield area that EnCana holds the rights to under leases with the government of Alberta. Natural gas production in the Suffield area is from vertically stacked, commercially productive zones between approximately 250 m and 650 m below surface. Although productive, the commercial zones are relatively tight, and the remaining natural gas cannot be recovered with the existing well distribution. Moreover, because of the shallow, stacked stratigraphy, directional or horizontal drilling from existing surface locations cannot effectively deplete all of the productive zones. EnCana is confident that only infill vertical drilling will enable the efficient production of the remaining natural gas resource. The production from the Project will be incremental to production from existing wells. The Project is anticipated to fulfill all the infill development necessary in the NWA.

The purpose of the Project is to enable EnCana to efficiently develop the natural gas resources to which it is entitled to under the 1975 Mineral Rights Agreement with the Province, which will benefit EnCana, its shareholders, local economies and energy consumers.

1.4.2 Alternatives to the Project
EnCana considered alternatives to the Project in the context of the need for and purpose of the Project. In doing so, EnCana qualitatively considered environmental, technical, and economic costs and benefits against the following general criteria:

• ability to exercise the rights to the natural gas resource
• ability to efficiently produce the natural gas resource
• ability to maximize the recovery of the natural gas resource
• sustainability of natural gas production from the field
• operational efficiency
• optimization of invested capital
• minimization of environmental footprint
• ability to fulfill policy commitments (including conducting our business ethically, legally, and in a manner that is fiscally, environmentally, and socially responsible, while delivering sustainable value and strong financial performance)

EnCana's view is that only infill vertical drilling will enable the efficient production of the remaining natural gas resource. No other functionally different ways of addressing the need for the Project and pursuing the purposes of the Project were identified. The proximity of the natural gas reserves within the NWA to existing natural gas transportation infrastructure is an important attribute of the Project. Because the Project is incremental to existing operations, it is both capital-efficient and economically viable. Technical performance is reliably predictable, based on over 30 years of operating experience in the area. Moreover, the ability to make efficient use of existing infrastructure and EnCana's low impact drilling and tie-in methods substantially minimize the environmental footprint of the Project.

The alternative of not proceeding with the Project was not considered viable, as the result would be an inability to fully develop the resource, and to sterilize this natural gas resource creating the need for potentially higher impact activity elsewhere.

The infill development is consistent with the EUB's conservation mandate to ensure that reservoirs are developed in a manner that maximizes the recovery of the resource in an environmentally sustainable manner, as well as with the Department of Energy's mission to optimize the sustained contribution from Alberta's energy and mineral resources in the interests of Albertans. This is accomplished by establishing an appropriate well density and pattern to drain the reservoir in an efficient and economic manner. The infill drilling will improve recovery and provide capacity to drain the pool at a reasonable rate that will not adversely affect recovery from the pool, consistent with section 4.040(3) of the Oil and Gas Conservation Regulation. EnCana is currently developing the majority of its lands outside the NWA with infill drilling to 16 wps, in accordance with down-spacing and commingling orders approved by the EUB.

Delaying the Project would not substantively change the environmental costs or benefits, but would have considerable technical and economic implications, including reduced operational efficiency of the field, inability to sustain forecast production levels, failure to meet investor expectations, and the inability to take advantage of the current market demand for clean-burning natural gas.

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