Pierre River Mine Project

WATER AENV SIRS 15 – 43
Question No. 41
Section 12.1
provided as required for operational purposes after project approval and will
follow the applicable regulatory guidelines.
Request Volume 2, SIR 342, Page 22-9.
Shell indicates that fish and benthics are critical or important key indicators, and
that aquatic health is assessed in relation to fish populations and other aquatic
life (invertebrates, algae, aquatic plants).
Subsequent to this statement, however, Shell notes that no data were or are being
collected on algae and plants and that such data on algae may even be unreliable
in this context. Shell states that algae and aquatic or wetland plant species are
excluded as KIRs because fish and benthic invertebrates are sufficient
representatives of aquatic health. Shell states that a healthy aquatic ecosystem
refers to a diverse and functioning aquatic ecosystem, which is typically reflected
by a healthy fish community.
41a Clarify if an important key indicator is, in fact, algae, and if so, what direct or
indirect measures of algae are appropriate for indicator tracking and
measurement purposes.
Response 41a Algae is not being considered as a key indicator resource (KIR) for fish and fish
habitat for the purpose of assessing project-related effects on fish and fish
habitat. See the response to AENV SIR 41b for the rationale of not including
algae as a KIR.
Request 41b Provide a rationale for excluding algae and aquatic plant species when they are
important components of fish and benthic invertebrate habitat and form the basis
of the food chain for a healthy aquatic ecosystem.
Response 41b The rationale for selection of key indicator resources (KIRs) for Fish and Fish
Habitat, as described in EIA, Volume 4, Section 6.7.2.4, considered previously
established KIRs for oil sands EIAs and recommendations of regulatory agencies
and stakeholders. The KIRs for the fish and fish habitat component are key fish
species or guilds, benthic invertebrate populations and their respective habitats.
The selected KIRs were considered to be suitable as sentinel species for the
aquatic ecosystem. Algae were not specifically included as KIRs since benthic
invertebrates were selected as representative of the lower trophic levels and are
generally considered a better indicator of changes to fish habitat than algae, as
described in the May 2009 Pierre River Mine, Supplemental Information,
Volume 2, SIR 342.
April 2010 Shell Canada Limited 12-61
CR029