Pierre River Mine Project

WATER AENV SIRS 15 – 43
Question No. 39
Request Volume 2, SIR 456c, Page 23-124.
Section 12.1
Shell is confident in its ability to reclaim the development area to self-sustaining
ecosystems that will meet equivalent land capability at closure.
39a Explain how the principles of equivalent land capability are consistent with the
replacement of high productive and diverse wetlands (that support a wide array
of plants and animals such as moose) with pit lakes.
Response 39a The principle of equivalent land capability is to reclaim to land uses with an
equivalent pre-disturbance capability, but is understood to mean not necessarily
to the same land use, or on the same footprint. An example is peatlands where
such wetlands cannot currently be reclaimed with confidence, and therefore,
other land types, such as marshes, having equal or greater capability for a wide
range of uses, are reclaimed.
Reference
Pit lakes are a necessary closure feature recognized by regulators and designed to
perform water quality remediation functions. The functions of pit lakes could be
considered of high value for the reclaimed landscape.
Further, Shell is not claiming that pit lakes are a substitute for highly productive
and diverse wetlands. Not all pre-disturbance wetlands should be considered
highly productive and diverse unless there is data and a rating system to
substantiate such claims. Pre-disturbance wetlands are not rated according to
their individual capabilities to facilitate comparison of equivalent land capability
after reclamation.
Reclamation land capability is determined using the land capability classification
(AENV 2006) which was designed to rate uplands for forest capability. Class 5
capability includes lands with such severe limitations for successful forest
potential that it is not feasible to “correct” the limitations. Thus, waterbodies (pit
lakes), wetlands (marshes, shallow open waters including littoral zones) and
other wet lands (shrublands) are collected together in the lowest class rating of
‘5’.
Table 6 (EIA, Appendix 5-2, Section 2.3.1) indicates that lakes will make up
1,920 ha of the closure landscape. Areas classed as littoral zone, refer to marsh
and shallow open water wetlands types and are planned to comprise 254 ha at
closure. Class 5 soils will cover 1,020 ha of the closure landscape and refer
specifically to shrublands (Sh2 and Sh3) prescriptions.
AENV. 2006. Land Capability Classification System for Forest Ecosystems in
the Oil Sands, 3rd Edition. Volume 1: Field Manual. Prepared for
Alberta environment by the Cumulative Environmental Management
Association. 53 pp + appendices.
April 2010 Shell Canada Limited 12-59
CR029