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March 20, 2018

Alberta Energy Regulator
Suite 1000, 250-5th St SW
Calgary, AB
T2P 0R4

Re: Repsol Oil & Gas Canada Inc. Clearwater River Water Diversion Licence Application

Please find enclosed an application under the Alberta Water Act for licence to divert a maximum of
1,800,000m3 per year of high-quality non-saline water from two diversion points in the Clearwater River,
to be used in hydraulic fracturing and related activities for a gas field development program within a
contiguous geographic area.

Maximum
Licence Locations (PODs) Total Volume
Rate
Clearwater River Licence for Diversion of NW-12-038-07W5
1,800,000 m³/y 0.30 m³/s
Water NE-15-038-07W5

This application is consistent with the Directive for Water Licencing of Hydraulic Fracturing Projects –
Area of Use Approach effective February 22, 2018. Repsol Oil & Gas Canada Inc. has included a
demonstrated need for water, with annual reporting to the Alberta Energy Regulator (AER) to show
transparency of annual intended water use and enable the Alberta Energy Regulator to utilize
temporarily unused portions of the water allocation for other purposes through the issuance of
temporary diversion licences (TDLs). The term requested is consistent with the Directive: ten years.

Please contact the undersigned if you have any questions regarding this application at
jvolk@repsol.com, or (403) 693-2293.
Repsol Oil & Gas Canada Inc.

Sincerely,
Repsol Oil & Gas Canada Inc.

___________________________
JoAnne Volk, P. Eng.
Water Lead

2000, 888-3rd St SW, Calgary, Alberta, Canada T2P 5C5
Tel. +1 403 237 1234 - Fax. +1 403 237 1902
Repsol Oil & Gas Canada Inc.
Clearwater River Water Diversion
Licence Application
1.0 Executive summary
In this application under the Alberta Water Act, Repsol Oil & Gas Canada Inc. (ROGCI) is applying for one
licence to divert surface water from the Clearwater River for consumptive use to support the company’s
Development Plan in the Duvernay area.

Maximum
Licence Locations (PODs) Total Volume
Rate
Clearwater River Licence for Diversion of NW-12-038-07W5
1,800,000 m³/y 0.30 m³/s
Water NE-15-038-07W5

This application is consistent with the Directive for Water Licencing of Hydraulic Fracturing Projects –
Area of Use Approach effective February 22, 2018. ROGCI has included a demonstrated need for water,
with annual reporting to the Alberta Energy Regulator (AER) to show transparency of annual intended
water use and enable the AER to utilize temporarily unused portions of the water allocation for other
purposes through the issuance of temporary diversion licences (TDLs). The term requested is consistent
with the Directive: ten years.

ROGCI has performed a risk assessment of the Geographic Area, and will show the Geographic Area is
home to numerous stakeholders, no Indigenous Settlements, has a large volume of water available for
allocation, features relatively low industrial activity (energy as well as non-energy), and is not a location
of significant planned municipal growth.

ROGCI has examined numerous conservation options to reduce the consumption of high-quality non-
saline water. Although many alternative water sources, such as recycled municipal effluent or industrial
wastewater, were found to be not economically feasible, ROGCI will be able to reduce the consumption
of high-quality non-saline water by recycling hydraulic fracturing flowback water once enough wells are
operating to produce sufficient volumes for completing future wells, subject to mind restrictions on
storing hydraulic fracturing flowback water. Furthermore, ROGCI is reducing its consumption of high-
quality non-saline water by employing alternative technologies and practices, such as hybrid hydraulic
fracturing. This combination of slickwater and cross-link gel techniques has provided a 20% to 40%
reduction over slickwater techniques alone.

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To reduce cumulative environmental effects, ROGCI plans to utilize existing cleared land (Freehold land)
to access diversion points. Furthermore, ROGCI is in discussion with local operators in the area to
develop ideas for conservation options and shared infrastructure.

In this application, ROGCI has committed to annual reporting including the following information:

water use data
comparison of water use to estimates submitted in the Application
alternative water use data
environmental impacts and adverse effects, if any
complaints received, if any
continual improvement activities on alternative uses and technologies
three year outlook on water use
changes to mineral tenure in the Geographic Area
changes to the well density

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Table of Contents
1.0 Executive summary ............................................................................................................................... 1
2.0 Definitions ............................................................................................................................................. 5
3.0 Introduction .......................................................................................................................................... 5
3.1 Project description................................................................................................................... 6
3.1.1 Diversion of water .......................................................................................................... 6
4.0 Context risk assessment ........................................................................................................................ 6
4.1 Geographic Area ...................................................................................................................... 7
4.2 Water availability risk .............................................................................................................. 9
4.3 Industry activity risk............................................................................................................... 12
4.4 Stakeholder and Indigenous community interest risk........................................................... 13
4.4.1 Stakeholder identification ............................................................................................ 14
4.4.2 Indigenous community identification ........................................................................... 14
5.0 Conservation options .......................................................................................................................... 15
5.1 Alternative source assessment .............................................................................................. 15
5.2 Alternative technology and practice assessment .................................................................. 22
5.2.1 Alternative fracturing technologies .............................................................................. 22
5.2.2 Flowback and produced water treatment technologies .............................................. 23
5.2.3 Multi-operator water plans .......................................................................................... 23
6.0 Development Plan ............................................................................................................................... 23
6.1 Demonstrated Need for Water .............................................................................................. 23
6.2 Points of Diversion.................................................................................................................. 27
6.3 Point of Use Area .................................................................................................................... 27
7.0 Operational risk assessment and mitigation measures ....................................................................... 27
8.0 Communication ................................................................................................................................... 29
8.1 Stakeholders .......................................................................................................................... 29
8.2 Indigenous communities ....................................................................................................... 30
9.0 Monitoring, reporting, and performance management ..................................................................... 30
9.1 Progress and continual improvement reporting ................................................................... 30

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9.0 Appendices .......................................................................................................................................... 31
A1. Clearwater River Water Licence Project Industry Focus Map ......................................... 31
A2. Clearwater River Water Licence Project Indigenous Settlements and Federal Reserve
Lands Map .............................................................................................................................. 31
A3. Clearwater River Water Licence Project Stakeholder Focus Map ................................... 31
A4. Clearwater River Licence for Diversion of Water Application ......................................... 31
A5. Hydrology and Wildlife and Fish Habitat Assessment in Support of a Surface Water
Licence Application, Clearwater River; Matrix, 2018. ........................................................... 31
A6. Alberta Water Tool Report for Clearwater River ............................................................ 31
A7. Clearwater River Point of Use Area Map ......................................................................... 31
A8. Clearwater River POD Access Maps and Agreements ..................................................... 31
A9. Clearwater River Water Diversion Application Stakeholder Engagement Line List ........ 31
A10. Clearwater River Water Diversion Application Project Brochure.................................. 31

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2.0 Definitions
ACO = Aboriginal Consultation Office
AER = Alberta Energy Regulator
POD = point of diversion
POU = point of use area
ROGCI = Repsol Oil & Gas Canada Inc.
TDL = temporary diversion licence

3.0 Introduction
This application has been developed in accordance with the goals of the Alberta Energy Regulator (AER)
to reduce the consumption of high-quality non-saline water through the use of alternative sources and
technologies, for the benefit of in-stream and aquatic ecosystem needs, as well as the preservation of
drinking water and livestock watering supplies. To help realize these goals, Repsol Oil & Gas Canada Inc.
(ROGCI) has developed their water licence application while adhering to several guiding principles
regarding water conservation and operational review and improvement. For example, decisions about
water conservation should:

Balance the economic success of operations with the expectations of Albertans and Indigenous
peoples, for whom water is an important part of their heritage;
Be made following fair and thorough consultation with stakeholders, Indigenous peoples, and
knowledgeable experts;
Incorporate best practices, past learnings, and best available technologies to promote and
support sustainable development in the short- and long-terms (with consideration of cumulative
effects); and
Minimize risks to environmental and human health through monitoring and contingency
planning.

Other guiding principles include the incorporation of continuous improvement, periodic licence review,
alignment with Alberta legislation, regulation, and policies, and communicating long term certainty for
industry.

Through the improvement of the water licence allocation practice, the AER strives to realize the
following outcomes:

Achieve alignment with Water for Life: Alberta’s Strategy for Sustainability;
Reduce environmental net effects of water use;
Minimize the use of high-quality non-saline water while balancing the needs of energy resource
developers in Alberta, including reliability of supply of good-quality water to support a
sustainable economy, in recognition that conservation measures should be proportional to the
regional water availability and demand;

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Promote water conservation and multi-operator collaboration in areas of high intensity multi-
stage hydraulic fracturing activity, for the reduction of cumulative land and water impacts and
development of partnerships between industry, government, and/or stakeholder organizations
(for research, continued cooperation, etc.); and
Improve communication with local stakeholder and Indigenous communities through accessible
monitoring and performance data.

This application aims to satisfy these outcomes through the implementation of water conservation
practices (including an alternative source and alternative technology/practice assessment), a risk based
environmental assessment approach (including consideration of cumulative impacts), and satisfaction of
all licence application requirements laid out in the Water Act.

3.1 Project description
3.1.1 Diversion of water
This application to the AER is for a licence for diversion of water under the Water Act for diverting a
maximum of 1,800,000m3/y of high-quality non-saline water for 10 years from the Clearwater River to
be consumptively used to support ROGCI’s hydraulic fracturing and related activities. ROGCI’s
development plan involves Full Field Development of a 1 to 2 rig program over 20 years in the Duvernay.
Details, as shown in Table 1, include:

Maximum
Licence Locations (PODs) Total Volume
Rate
Clearwater River Licence NW-12-038-07W5
1,800,000 m³/y 0.30 m³/s
for Diversion of Water NE-15-038-07W5
Table 1: Licence for diversion of water requested as part of Application

ROGCI’s Point of Use Area (POU) map is included in Appendix 7. The demonstrated need for water is
included in Section 6.1 below. Clearwater River licence for diversion of water application is included in
Appendix 4. Associated hydrology work is included in Appendix 5.

4.0 Context risk assessment
To understand the risk of allocating water and the need for conservation practices, contextually specific
information will be provided regarding ROGCI’s Geographic Area. This includes:

A map of the area, which indicates the proximity of nearby communities, Indigenous peoples,
industry activity, and water bodies;
An assessment of present and future surface and groundwater availability, allocation, and use in
the area, which will incorporate energy and non-energy industry demand, as well as demand
from other users; and

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Consideration of stakeholder and Indigenous concerns and interests.

This application proposes a context risk assessment for the Geographic Area. As the subsections below
will illustrate, this area has been identified as Low Risk.

4.1 Geographic Area
The Geographic Area for this application has been carefully selected according to:

ROGCI’s near-term and long-term Development Plan in the area; the areas targeted for
hydraulic fracturing in this project, as well as in possible future expansion, are included;
Reasonable scale; the area is not so large that regulatory and/or water availability changes will
impact the context in only a portion of the area;
Natural boundaries of surface supply sources;
Natural boundaries of groundwater aquifer supply sources;
Similar use/allocation relative to availability;
Land-use planning areas;
Municipality boundaries; and
Location of Indigenous Settlements.

The red box in Figure 1 below shows the Geographic Area of interest in this application, including
existing and future water storage locations, as well as the PODs being applied for in this application. As
will be discussed in Section 6 of the application, the proposed Point of Use area falls within, but is
distinct from, the Geographic Area, which has been used as the basis for assessing risk.

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Figure 1: Geographic Area of Application

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Appendix 1 is a detailed map of the oil and gas industry focus in the Geographic Area, including

Publicly available Duvernay mineral rights by Operator
Locations of ROGCI’s high-quality non-saline water reservoirs (installed and planned) and
location of all POD requests for this application
Other Water Act Authorizations for surface and groundwater withdrawal, valid as of Feb 2018
(does not include household and farm use)
Existing roads (public and industry) and leases for all Operators
Hydrocarbon wells licenced Jan 1 2017 or later for all Operators for all formations

Appendix 2 shows the same Geographic Area with Indigenous Settlements and Federal Reserve Lands
overlaid.

Appendix 3 shows the same Geographic Area, overlaid with other Stakeholder’s interests, including

Forest Management Areas, outlined in green
Trapper area boundaries, outlined in orange
Municipal District boundaries, outlined in grey
Recreational areas
Structures in the area (airports, schools, industries)
All water wells for domestic, municipal, stock or irrigation use

4.2 Water availability risk
The risk of water allocation has been assessed using a high/medium/low risk designation by considering
the existing water allocations in all sectors relative to water availability, regulatory triggers, and policy-
based thresholds. Water availability has been determined after reviewing protected environmental base
flows, municipal and commercial allocations, and industrial allocations.

ROGCI is not aware of any plans, guidelines, frameworks or other guidance on water availability risk that
applies to this Geographic Area. Therefore, a desktop assessment method is appropriate to assess
availability, with hydrometric monitoring and extrapolation or Hydrologic Unit Codes used to delineate
above ground areas. Appendix 5 includes a detailed hydrologic review of the Clearwater River. This
review uses the Alberta Desktop Method for Determining Environmental Flow Rates (2011) to ensure in-
stream flow needs are met. The Alberta Water Tool Report (Appendix 6) estimates an average of 13.25%
of flow is available to be allocated (this takes into account 20% of the time when low river flow restricts
withdrawals). The Alberta Water Tool Reports summarize the current water surface and groundwater
allocations (permanent and temporary) upstream of the PODs (at time of print).

Table 2, below, summarizes the current allocations, and shows that with ROGCI’s proposed allocations,
the river is 0.41% allocated at the PODs and ample water is still available for future development in the
area. Figure 2, below, shows a graphical representation of the same data: existing allocations (red),
ROGCI’s request (purple), and remaining water that can be allocated (green). Blue represents the

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86.75% of flow that cannot be allocated, using the Alberta Desktop Method for Determining
Environmental Flow Rates (2011).

Available
Mean
for Total ROGCI’s Total Remaining
Annual
Withdrawal Current Proposed Allocations Allocation
Stream
(million Allocations Withdrawal Including at PODs
Discharge
m3/y) at PODs (million ROGCI’s (million
(million
(approx. (%) m3/y) (%) m3/y)
m3/y)
13.25%)
Clearwater
River 525.1 69.9 0.07% 1.8 0.41% 67.8
(both PODs)
Table 2: Total Current Allocations and Remaining Allocations After ROGCI’s Project

Figure 2: Graphical Representation of Water Allocation for Clearwater River

Appendix 5 includes the aquatic habitat reviews at each POD. Both proposed PODs appear to be
relatively insensitive to the possible effects of flow diversion. POD locations were selected to avoid any
sensitive aquatic habitats. Intakes will be designed to meet the Freshwater Intake End-of-Pipe Fish
Screen Guideline (DFO, 1995) to mitigate the risk of fish impingement or entrainment.

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As discussed in Appendix 5, the two PODs on the Clearwater River are within a Key Wildlife and
Biodiversity Zone. Repsol is committed to protecting key ungulate winter ranges and movement
corridors and following the Alberta Environment and Sustainable Resource Development Recommended
Land Use Guidelines: Key Wildlife and Biodiversity Zone. Both PODs will use existing access, but ROGCI
plans to enhance the approach access and equipment site location. Vegetation clearing will be minimal
and construction activities are not planned during the timing restriction period (January 15 – April 30).
Any other activities (e.g., water withdrawal) that may need to occur during the restricted time would be
within 100 m of the existing road. Although these access points are on Freehold land, ROGCI will use the
same standards and conditions for Public Land surface dispositions, where applicable.

There are potential recreational users of the water at the area of both PODs. Based on discussions with
community residents, the Clearwater River is used for boating, rafting and canoeing. Temporary intake
screens will be located close to shore and will be well marked when in use. Additionally, the pumping
operations will be manned 24 hours per day, allowing ROGCI personnel to direct recreational users
around the temporary intake screens.

The existing water licences from the Alberta Environment and Parks (AEP) database are listed and
summarized quantitatively to indicate the volume of currently allocated water in the Geographic Area
within the Alberta Water Tool report contained in Appendix 6. No new projects outside of oil and gas
development are currently known to the applicant.

Appendix 1 shows the publicly available data of Duvernay mineral rights holdings within the Geographic
Area. In the Geographical Area, ROGCI holds 13% of mineral rights held by Duvernay right holders, Shell
holds 13%, Paramount 10%, various companies under broker hold 35%, freehold is 16%, and other
companies 13%. In the North Saskatchewan Watershed, various companies under broker hold 39%,
ROGCI holds 19%, and Shell holds 22%. The remaining 20% is held by a combination of freehold and 9
other companies. In the North Saskatchewan Watershed, if the three significant Duvernay rights holders
were to develop at the same pace as ROGCI, high-quality non-saline water demand from the North
Saskatchewan Watershed for hydraulic fracturing from this Geographic Area could peak at 7.5 million
m3/y. Based on the water available in Table 2, the remaining allocation in the Clearwater River can
satisfy this demand (assuming all Operators would withdraw from the Clearwater River).

Future water demand for municipal use has been estimated to increase at the rate of population growth
for the area. The only major centre in the area is Rocky Mountain House, and it withdraws water from
the North Saskatchewan River, downstream of the Clearwater River confluence with the North
Saskatchewan River.

Using 2016 census data, the average growth for the main centre downstream of the Clearwater River
(Rocky Mountain House) is -3.9% (3.9% population decrease over 5 years, or 0.8% per year decrease). In
2016, Rocky Mountain House used only about 60% of its allocation. This rate of growth is therefore not
expected to impact water allocations immediately downstream of the PODs.

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Based on the desktop assessment and projections for future growth, the water availability risk in the
Geographic Area is assessed as Low.

The preceding review is for the Geographic Area, to understand the effects of this licence application on
that area. Downstream users will not be affected by this licence application, as Alberta has a priority
system in place which protects their withdrawals. Specifically, ROGCI understands that the users on the
main stem of the Clearwater River and North Saskatchewan River with senior licences have priority over
the licence being applied for in this submission, and during times of water shortages, senior licences
would be given priority over this licence. During times of water shortages, this could result in risk to
ROGCI’s Development Plan. This is a recognized business risk for ROGCI; it will be appropriately
mitigated and does not present a risk to other users or the environment in terms of water availability.

4.3 Industry activity risk
The industry activity risk for this Geographic Area has been assessed based on current and future
societal and environmental cumulative impacts of activities in the energy and non-energy (e.g. forestry,
etc.) industries. For energy industry activities specifically, this assessment includes a review of the
number and density of existing well sites, existing infrastructure (pipelines, roads, facilities, etc.), and
future hydraulic fracturing development. Note that this assessment is activity based; existing water
allocations, recent growth trends, and future water use forecasts are assessed in the Water Availability
Risk assessment above.

Appendix 1 shows the current oil and gas leases and roads in the Geographic Area. Major roads already
exist throughout the Geographic Area, so activities to install major roads in the area are expected to be
low. Some pipelines exist, but development will result in an increase of pipelines to move product to
market. Most oil and gas activity in the area is into tight or shale formations, which results in a lower
overall disturbance for the number of wells drilled (one pad is used for 6-10 wells instead of one pad per
well).

Appendix 1 also shows the publicly available data of Duvernay mineral rights holdings within the
Geographic Area. This map shows all new wells licenced since January 1, 2017 (red dots represent
bottom-hole locations) of all Operators drilling into all formations. Based on the number of wells
licenced, activity within the Geographic Area is demonstrably low.

Forestry is another sector that is active in the Geographic Area, specifically in the North Saskatchewan
Watershed. The forestry activity within this Geographic Area is mainly harvesting, which does not
consume a large volume of water. No allocations are currently held for forestry. It is not expected that
forestry activities in the Geographic Area will increase in the future.

The assessment indicates that this Geographic Area has a low industrial activity risk, based on existing
operations, current uses and applications in the area.

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4.4 Stakeholder and Indigenous community interest risk
The purpose of the stakeholder and Indigenous community interest risk assessment is to understand
and respect the interests and expectations of Albertans, including Indigenous communities, who regard
water as an important part of their heritage. Within the Geographic Area, the risk of stakeholder and
Indigenous community response to additional water licence applications has been assessed based on
the following criteria:

Proximity and number of nearby Indigenous and non-Indigenous communities
Current relationship between these communities and the AER, industry, and their constituent
groups
Communities’ awareness of the issue of water use and applications
Risk to communities’ values and interests potentially resulting from new developments, as well
as their level of concern regarding these risks
Adequacy of communities’ resources for engagement on this project

In the absence of direction from an approved water management plan in the North Saskatchewan River
Basin, ROGCI expects stakeholders and Indigenous communities may have concerns related to
cumulative impacts of water withdrawals, negative impacts to aquatic and land ecosystems, and land
and riparian disturbance in the area around the PODs.

With respect to cumulative impacts, Table 2 of this application summarizes the current
allocations at the PODs (0.07%), ROGCI’s proposed allocations (0.34%), and the total allocation
remaining (67.8 million m3 or 12.84%), based on the Alberta Water Tool Report (included in this
application as Appendix 6). Based on this data, ROGCI has concluded that the risk of negative
cumulative impacts from the withdrawal volumes requested in this application is low.
POD locations were selected to avoid any sensitive aquatic habitats. Intakes will be designed to
meet the Freshwater Intake End-of-Pipe Fish Screen Guideline (DFO, 1995) to mitigate the risk of
fish impingement or entrainment. As discussed in Appendix 5, the PODs on the Clearwater River
are within a Key Wildlife and Biodiversity Zone; mitigation measures (see Table 6) are in place to
ensure ungulates and ungulate habitats are not adversely impacted. Both PODs will use existing
access, but ROGCI plans to enhance the approach access and equipment site location.
Vegetation clearing will be minimal and construction activities are not planned during the timing
restriction (January 15 – April 30). These mitigation measures are designed to address concerns
related to potential negative impacts to aquatic and land ecosystems, particularly threatened
native fish and ungulates, and land and riparian disturbance in the area around the PODs.

A search of the AER’s website did not reveal any statements of concern from stakeholders or Indigenous
communities regarding the impact on water as a result of energy developments in this area. Outside of
the Geographic Area, downstream impacts due to water withdrawal will be minimal based on the
volume requested for diversion.

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The map included in Appendix 3 shows water wells in the area used for domestic, municipal, livestock or
irrigation. The high concentration of groundwater wells provides an indication of the local resident
population and activity. ROGCI conducted open houses in the area (two in 2016 and one in 2017), and
has had discussions with residents regarding their concerns about consumptive water use (one meeting
specifically around water in 2017). ROGCI also operates a Good Neighbour Program in the area and
encourages stakeholders to contact us with their concerns. Each concern is taken seriously, and ROGCI
takes measures to address any concerns that arise as a result of our operations or applications.

The assessment indicates that this Geographic Area has a low stakeholder and Indigenous risk. Pursuant
to this low risk, a stakeholder and Indigenous communities’ engagement strategy is outlined below.

4.4.1 Stakeholder identification
For the purposes of this application, ROGCI used a variety of tools to identify Stakeholders who could be
potentially impacted by approval of this application. A map of Stakeholders is included in Appendix 3.
ROGCI used the Alberta Water Tool Report and the AER database to identify water allocations
downstream of the PODs. Downstream users with allocations within the Geographic Area of the PODs
on the Clearwater River were considered to be Stakeholders. ROGCI identified Forest Management
Agreement holders and trappers within the area of the PODs of this application and included both as
Stakeholders.

ROGCI also reviewed its internal list of Stakeholders and communities to identify those who might be
impacted or have concerns about this application. Community members that have attended ROGCI
community events and meetings who have expressed an interest in water use and water management
have been included on the Stakeholder list. Residents and grazing lease holders within 0.5km radius of
the PODs have been included (based on the potential they may be impacted, possibly by noise, by water
transfer operations). The Town of Rocky Mountain House, and counties within the Geographic Area are
also included. Appendix 9 lists all Stakeholders identified and the Stakeholder interest.

4.4.2 Indigenous community identification
ROGCI relied on mapping of Indigenous Settlements and Federal Reserve Lands to generate a list of
settlements within the Geographic Area that may be impacted or have concerns about this application.
The mapping (see Appendix 2) shows that no settlements are within the Geographic Area. There is one
cemetery present in Township 37-8W5 within the Geographic Area (indicated as “Indigenous
Settlements & Federal Reserve Lands” in the legend), but this cemetery is not close to ROGCI mineral
holdings, so will not be impacted by ROGCI activities. These mapping activities were not intended to
replace consultation. Consultation will be undertaken in accordance with the direction of and processes
established by the ACO. Consultation will be conducted concurrently with the AER’s review of this
application and ROGCI understands the application will not be approved without adequate consultation
with Indigenous communities. ROGCI will include the Indigenous communities consulted as part of this
application in its ongoing stakeholder engagement program.

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5.0 Conservation options
To minimize project specific risks and achieve the AER’s outcomes of minimizing high-quality non-saline
water use and reducing environmental net effects, conservation options were considered. Conservation
options can involve any combination of:

Using alternative sources, such as saline water and recycled water
Using alternative technologies and practices, such as multi-operator systems and advanced
technologies which reduce water use

The use of alternative sources and alternative technologies and practices will be presented in this
application. For each alternative, evaluation includes a quantitative environmental net effects
assessment of air, land, and ecosystem impacts. The following parameters are considered over the
project’s lifetime:

Greenhouse Gas (GHG) and air emissions (e.g. NOx)
Land disturbance
Energy use
Generation and handling of solid and liquid waste
Biodiversity and ecosystem impacts
Contamination risks

In addition to the environmental net effects assessment, each alternative also underwent a review
based on industrial and societal impacts, which are more qualitative.

Each alternative is compared to the baseline water use from an environmental, industrial, societal, and
economic perspective.

5.1 Alternative source assessment
An assessment of alternative sources was performed, keeping in mind the hierarchy of water sources,
which includes (from least preferred to most preferred):

High-quality non-saline water
Alternative non-saline water (e.g. recycled industrial and municipal wastewater, non-saline
water in contact with hydrocarbon deposits, non-saline groundwater which cannot be
economical or technologically practical, to use for drinking water or livestock watering, etc.)
Saline groundwater, flowback water and produced water

This assessment considered the environmental, industrial, and societal net effects, as well as economic
impacts to ROGCI, of each alternative source. It recognized that water is needed to continue developing
energy resources in Alberta, and conservation actions should be commensurate to the risks identified
for the Geographic Area, which are low. Furthermore, this assessment distinguished between
alternative sources which may require a Water Act authorization (e.g. reused municipal effluent, non-

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saline groundwater, etc.) and those which do not (e.g. saline produced water, reuse of hydraulic
fracturing flowback fluid, etc.). In addition to a Water Act authorization, the need for other
authorizations was also considered for each alternative.

All costs and net effects were compared to the baseline case, which is the use of high-quality non-saline
water. The baseline case includes storage (two high-quality non-saline water storage reservoirs on each
side of the Clearwater River), transportation (temporary rental pumping and temporary above ground
hoses used for transport of high-quality non-saline water from the furthest POD to all reservoirs), and
source costs (licencing). Details of the baseline case cost calculations have not been included as they are
confidential. Table 3, below, provides the outcomes of this assessment.

For environmental net effects, comparisons were made against the base case, but no absolute values
have been included to maintain the confidentiality of ROGCI’s expected costs in full field development.

For recycled industrial wastewater, a number of industries could be included (i.e. coal mine tailings
ponds, oil sands tailings ponds, pulp mill effluent, food and beverage wastewater). The distance to
transport the wastewater (by truck or pipeline) represents the majority of the cost, so the closest
industrial site to the closest POU was selected for comparison (Nova at Township 38-25W4, 90km away).

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Source Authorization(s) Activity Environmental Impacts Industrial Stakeholder Cost Water
Water Required (net effects compared Impacts Impacts Compared to Available
to baseline) Baseline Compared
to Baseline
Recycled AEP LOA for Withdrawal of Improved river water quality No anticipated Transport by 2.1* times more unknown
industrial generator, AER LOA treated effluent from removal of effluent, impacts to slickwater truck (noise, dust, cost than high- replacement of
wastewater for user, Water Act from existing same river flow reduction as fracturing operations safety) or install quality non-saline high-quality
Approval change facility (prior to high-quality non-saline water, (gel stage permanent water baseline non-saline
(return flow is in discharge into increased air emissions (NOx compatibility needs pipelines (linear assuming source water, available
generator’s river), transport by and particulates) from to be studied) land disturbance) could be located quantity
approval), contract truck (or pipeline) trucking vs pumping, linear in Red Deer/Joffre unknown
between generator to POU site, store land disturbance if pipeline
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and user in 6300m AWSS used, reduced use of
for use temporary pumps in river
Recycled AEP LOA for Withdrawal of Improved river water quality No anticipated Transport by 1.5* times more 60%
municipal generator, AER LOA treated effluent from removal of effluent, impacts to fracturing truck (noise, dust, cost than high- replacement of
wastewater, for user, Water Act from existing same river flow reduction as operations (proven) safety) or install quality non-saline high-quality
Approval change if facility (prior to high-quality non-saline water, permanent water baseline non-saline
Rocky
return flow is in discharge into increased air emissions (NOx pipelines (linear water,
Mountain 3
generator’s river), transport by and particulates) from land disturbance) 3000m /d
House approval, contract truck (or pipeline) trucking vs pumping, linear available
between generator to POU site, store land disturbance if pipeline
3
and user in 6300m AWSS used, reduced use of
for use temporary pumps in river
Hydraulic AER notification for Collect flowback Reduced air emissions (NOx No anticipated Transport by More cost 8%
3
fracturing 3000m temporary water in AWSS at and particulates) from impacts to slickwater truck (noise, dust, effective than replacement of
flowback storage under D55 generating site, reduced trucking to disposal, fracturing operations safety) high-quality non- high-quality
transport by truck no permanent land (gel stage saline water non-saline
water 3
to POU site, store disturbance for either option, compatibility needs water, 160m /d
3
in 3000m AWSS reduced use of temporary to be studied), can available when
for use pumps in river only store for 3 averaged over
months in temporary year
AWSS, maximum
3
volume in 3000m
3
AWSS is 2300m with
freeboard
restrictions
17
Source Authorization(s) Activity Environmental Impacts Industrial Stakeholder Cost Water
Water Required (net effects compared Impacts Impacts Compared to Available
to baseline) Baseline Compared
to Baseline
Produced AER notification for Collect produced Reduced air emissions (NOx No anticipated Transport by More cost 4%
3
water, same 3000m temporary water in existing and particulates) from impacts to slickwater truck (noise, dust, effective than replacement of
formation storage under D55 facility tanks at reduced trucking to disposal, fracturing operations safety) high-quality non- high-quality
source, transport no permanent land (gel compatibility saline water non-saline
(sweet) 3
by truck to POU disturbance for either option, needs to be studied), water, 80m /d
site, store in reduced use of temporary safety and handling available
3
3000m AWSS for pumps in river risk if produced
use water is sour, can
only store for 3
months in temporary
AWSS, maximum
3
volume in 3000m
3
AWSS is 2300m with
freeboard
restrictions
Produced AER notification for Collect produced Reduced air emissions (NOx Unknown Transport by Unknown 0%
3
water, 3000m temporary water in existing and particulates) from compatibility risk truck (noise, dust, (treatment replacement of
different storage under D55 facility tanks at reduced trucking to disposal, with hydraulic safety) requirements high-quality
source, transport no permanent land fracturing chemicals, unknown at this non-saline
formation 3
by truck to POU disturbance for either option, ROGCI considers this time) water, 0m /d
(sweet)
site, store in reduced use of temporary high risk from ROGCI
3
3000m AWSS for pumps in river operated wells
use in 50km radius
Produced AER notification for Collect produced Reduced air emissions (NOx Would not use unless Transport by Unknown 0%
3
water (sour) 3000m temporary water in existing and particulates) from treated because of truck (noise, dust, (treatment replacement of
storage under D55 facility tanks at reduced trucking to disposal, on-site safety issues safety), potential requirements high-quality
source, transport no permanent land and transport issues, odor issues unknown at this non-saline
3
by truck to POU disturbance for either option, unknown time) water, 0m /d
site, store in reduced use of temporary compatibility risk from ROGCI
3
3000m AWSS for pumps in river with hydraulic operated wells
use fracturing chemicals, in 50km radius
ROGCI considers this
high risk
18
Source Authorization(s) Activity Environmental Impacts Industrial Stakeholder Cost Water
Water Required (net effects compared Impacts Impacts Compared to Available
to baseline) Baseline Compared
to Baseline
Saline water in AER well licence, Drill water well Increased air emissions (NOx No anticipated Transport by 2.1 times more 3%
contact with WAA, agreement into a deep and particulates) from impacts to slickwater truck (noise, dust, cost than high- replacement of
hydrocarbon for non-trespass formation trucking vs pumping, reduced fracturing operations safety) quality non-saline high-quality
from mineral rights (Cretaceous, use of temporary pumps in (gel stage water baseline, non-saline
reservoirs
holder Mississippian or river compatibility needs assuming well can water per
Devonian), to be studied), safety be located within groundwater
3
separator package and handling risk if 10km radius of well, 1600m
for HC recovery, produced water is development area available per
storage at well sour, can only store fracture stage
site, transport by for 3 months in
truck to POU site, temporary AWSS,
3
store in 3000m maximum volume in
3
AWSS for use 3000m AWSS is
3
2300m with
freeboard
restrictions
Non-saline >150m deep, AER Drill water well Permanent land disturbance No anticipated Install permanent 1.5 times more 6%
groundwater well licence, WAA, into Haynes for pipeline, reduced use of impacts to fracturing pipelines (linear cost than high- replacement of
which is agreement for non- member of the temporary pumps in river operations land disturbance) quality non-saline high-quality
trespass from Paskapoo water baseline non-saline
economically/
mineral rights formation, assuming well can water per
technologically
holder pipeline water to be located within groundwater
unfit for reservoir and mix 10km radius of
3
well, 130m /d
human or with high-quality reservoir available
livestock water non-saline water,
transport by
surface hose to
usage site
*closest source to closest Point of Use (POU) selected for cost comparison (shortest distance)
Table 3: Alternative Source Assessment
19
ROGCI has executed many trials and tests for alternative sourcing in their unconventional operating
areas in Alberta in the past five years. A summary of these projects, results, applications, and restrictions
is included in Table 4, below.

Activity Area and Project Description and Results Applications and
Duration Restrictions

Flowback Edson and Flowback recycling has been used in slickwater hydraulic fracturing This flowback reuse
recycle Wild River activities in Edson in ROGCI’s Wilrich development area. A detailed activity was applicable for
Dev Areas, plan and checklists were developed in accordance with D55 slickwater hydraulic
3 fracturing operations; it is
half of addendum for storage of flowback water (temporary c-rings <3000m
not yet proven for hybrid
2014, full and <3 months duration). To minimize risk, restrictions on timing of hydraulic fracturing
year 2015, use were also implemented (for example: not storing flowback water operations. To be
2016 and in c-rings through Christmas break or through Breakup). The plan was successful, this program
2017 created in 2014, and first executed in late summer of 2014. required a steady
completions program so
Results for the first full year of recycling are as follows: flowback the flowback can be
water was reused on 5 wells out of 11 in the Wilrich development area trucked from one location
in 2015. The use of flowback results in a 20% reduction in high-quality to the next within the 3
month regulatory storage
non-saline water use in Wilrich wells.
window. Trucking must be
within 50km to make this
There is a small cost saving associated with this recycling activity option economic.
primarily due to the close geographic proximity to the wells.

Treated South In 2015, ROGCI sought out alternative water sources to minimize our This reuse of treated
Municipal Duvernay – use of high-quality non-saline water resources in support of our South municipal wastewater is
Willesden Duvernay development. ROGCI and the Town of Rimbey in Central applicable to all areas of
Wastewater operation and all types of
Green (in Alberta developed a mutually beneficial agreement, which allowed us
Reuse hydraulic fracturing
the South to utilize its treated and discharge-quality wastewater in our hydraulic operations, but must be
Saskatchew fracturing activities. The operation required transporting water 70 reviewed for economic
an kilometers via truck to obtain water from the Town. In addition, we feasibility for each
watershed installed a temporary above ground surface pipeline to take the application, and for
area) in wastewater to our well pad to minimize impact on residents. impact to local
2015 on 2 stakeholders from the
Total number of truckloads was about 800. Piping was required for the resulting trucking
wells
last 3km. The cost of this fluid using trucking and D56 pressure tested operations.
welded piping on surface was 2.35 times higher than typical high-
quality non-saline water piping operation using layflat hose.

45% of the hydraulic fracturing fluid for the two wells was municipal
treated wastewater. Although no adverse impacts were reported to
the hydraulic fracturing operations as a result of using treated
municipal wastewater, the additional cost of this treated municipal
wastewater (trucking, storage, piping and management) made this
alternative water sourcing solution uneconomic.

Review of South A desktop review of the literature about the geology and This review was specific to
Geology and Duvernay – hydrogeology in the South Duvernay was conducted by Golder the South Duvernay

20
Activity Area and Project Description and Results Applications and
Duration Restrictions

Hydrogeology Ferrier and Associates in 2014 to look for alternative water sources. The summary Ferrier and Willesden
in West Willesden report outlined the following: Green areas.

Central Green areas
2014 Paskapoo-Sunchild member - sandstone, shallow, heavily used by
Alberta local residents – unlikely candidate

Paskapoo-Haynes member - thick medium to coarse grained
sandstone beds , 25-75m thick, few regional users – reasonable
candidate. Project was conducted in 2015 for well in this zone

Basal Belly River – minimal (<5m) to no sandstone with porosity >15%,
gas saturation is present in study area – unlikely candidate

Pekisko – lime mudstone, dolomudstones, net thickness of carbonate
>9% is 5-10m, saline, potential hydrogen sulphide – unlikely candidate

Haynes South Based on the desktop review conducted by Golder Associates in 2014 This project was specific
Member of Duvernay – (described above), ROGCI drilled a deep water well into the Haynes to the South Duvernay in
Ferrier, member of the Paskapoo Formation, which is located at an estimated the Ferrier and Willesden
the Paskapoo Green areas. Two other
2015 depth of 300 to 500 meters. This deep non-saline groundwater source
Water operators have drilled
is located substantially below the domestic water wells and would wells into the Haynes
typically not be used by local residents, due to elevated costs member of the Paskapoo
associated with drilling and pumping, and exceedances of Canadian with similar results (one
drinking water quality standards. well in 60-18W5 in 2015
and two wells in 43-6 and
In November 2015, one source well and one multi-level vibrating 44-5W5 in 2014). Based
piezometer were installed on the lease at 14-19-38-5W5M. The water on similar results from
four wells, it is expected
production rate from the well during development (air lift) was 10-
3 that the Haynes member
20m /d. Due to the low rate, a pump test was not conducted. A fall-off
is unlikely a viable source
test was conducted, which resulted in a calculated hydraulic in ROGCI’s unconventional
-8
conductivity of 1 x 10 m/s. Based on this test, the long term yield operating areas in
3
was also estimated at 10m /d. Groundwater sample collected Alberta.
indicated total dissolved solids of about 1100mg/L, with pH of 9.7 at
the wellhead. No pressure response was observed in the overlaying
Lacombe member, indicating no direct vertical hydraulic connection
between the Lacombe and the Haynes members. Gas was detected
(78% LEL at surface) at the end of the development of the production
well, but not detected during drilling or after the borehole was filled
with fluid. No H2S was detected.

Based on the cost of the project and the very low volume of water that
can be produced, this does not appear to be an economically viable
alternative water source.

Table 4: Alternative Project Work.

21
Flowback and produced water reuse will also be further investigated as soon as the asset is in Full Field
Development. ROGCI is currently in the appraisal stage of development, and without a steady
completions program, the temporary flowback storage duration limitations do not allow for flowback to
be used at this time.

5.2 Alternative technology and practice assessment
In addition to the alternative source assessment, alternative technologies and practices were also
investigated. These technologies and practices are meant to mitigate the environmental net effects
associated with water allocations by enabling reuse/recycling of water, promoting
efficiency/productivity, and/or reducing high-quality non-saline water consumption.

This assessment considered the environmental, industrial, and societal net effects, as well as impacts to
operator safety and economic impacts to ROGCI, of each alternative technology or practice. It
recognizes that the best available technology economically achievable should be utilized, while
conservation actions should be commensurate to the risks identified for the Geographic Area, which are
low. Throughout the assessment, the following factors were considered:

1. Compatibility of source water and flow back fluid
2. Dilution of flow back fluid
3. Water conditioning by chemical addition
4. Water conditioning by physical/chemical water treatment
5. Compatibility of formation and blended source/ flow back water
6. Compatibility of hydraulic fracturing additives and blended source/ flow back water
7. Safe reuse of flow back
8. Need for revision of multi-stage hydraulic fracturing process to achieve reuse
9. Potential for multi-operator and/or multi-facility water sharing plans to reduce cumulative
effects

5.2.1 Alternative fracturing technologies
ROGCI currently uses a hybrid hydraulic fracturing system, and has used this for the past five years. This
hybrid is a combination of slickwater and cross-link gel fluid. Hybrid hydraulic fracturing minimizes water
used to place the same amount of proppant, using approximately 20% to 50% less water than a
traditional slickwater hydraulic fracturing. The choice to run hybrid is a balance between water
reduction and total cost minimization. ROGCI has been continually improving the fracturing design and
is currently (2016) using 20 to 40% less water per tonne of sand than initial hydraulic fractures (2011) in
the Duvernay region.

Nitrogen foam based fracturing is sometimes used in formations that are low pressure or shallow.
Because they are foam, there is less hydrostatic head to help with initiation of the fracture. However,
the Duvernay target formation is deep and over pressured. Therefore, nitrogen foam cannot be used
because of pressure limitations at surface (equipment would need to be rated for extremely high

22
pressure to be able to handle the additional pressure needed in order to execute fracture stimulation
safely).

Carbon dioxide (CO2) based fracturing includes pumping CO2 as a liquid with hydraulic fracturing fluid in
emulsion. Once it starts heating, it flashes and becomes foam (desirable at the formation). However,
when the well is flowed back, the CO2 returns with the production and can cause integrity and corrosion
issues. The pipelines and equipment need to be designed to withstand corrosion concerns of CO2 in the
production volume, and this is interpreted to be cost prohibitive for this Project. Transportation for CO2
to site also makes it cost prohibitive.

5.2.2 Flowback and produced water treatment technologies
ROGCI has used flowback and produced water without additional treatment for slickwater operations in
other development areas in Alberta. ROGCI has not yet determined if treatment of the flowback and
produced waters will be required for the cross-linked gel portion of the Duvernay fracturing. Treatment
technologies are being reviewed, and water quality and quantity requirements and treatment
approaches will be finalized once ROGCI is closer to Full Field Development.

5.2.3 Multi-operator water plans
ROGCI is a member of an Operators Group in a different area of the province, and will use the learnings
from this Operators Group for possible implementation in this area. The operators share ideas for
alternative source identification, including deep non-saline groundwater wells, cost analysis for used
water (including industrial wastewater), reusing plant runoff water, and produced water reuse. ROGCI
also continues to evaluate options for shared infrastructure use and joint projects as a cost effective
method for retrieving water and minimizing surface impacts.

ROGCI has reviewed suspended and abandoned pipelines as a possible means to transport high-quality
non-saline water from the PODs to the reservoirs (whole or part way) but has not discovered any useful
lines. ROGCI uses other County and private road right-of-ways for temporary equipment to minimize
new land disturbances.

6.0 Development Plan

6.1 Demonstrated Need for Water
The preceding assessments of alternative sources and alternative technologies and practices
contributed to the creation of ROGCI’s Development Plan for this application. This Plan not only provides
the strategy for extracting valuable hydrocarbon resources from within the Geographic Area, but it also
incorporates conservation options which mitigate the risks of this development while balancing
economic considerations.

23
The map in Figure 3 below shows ROGCI’s Duvernay lands along with many of the key water
components to support development in the Geographic Area. All of the ROGCI publically available
Duvernay mineral rights (transposed to surface) in the North Saskatchewan River Watershed (shown in
yellow) contribute to the Duvernay resource planned to be developed. PODs, high-quality non-saline
water storage ponds, and watershed boundaries have all been labeled. ROGCI’s Full Field Development
Plan focuses on drilling and completing wells in the Ferrier Area (yellow lands in Figure 3 within the
Point of Use Area). ROGCI is planning to use Clearwater River as the primary water source for the Ferrier
Development Area.

As required by the Directive for Water Licencing of Hydraulic Fracturing Projects – Area of Use Approach,
ROGCI provides the following information in Table 5 to demonstrate the need for water:

Project Area within the North Estimate 71 sections
Saskatchewan Watershed
Total number of wells planned 280
Well Density Estimate 3.9 wells per section
Schedule Estimate pilot/appraisal 2015 to 2020, full field
development (1-2 rigs) 2021 – 2035, see Figure 4
Volume of water required per well Estimate 75,000 m³/well
Number of years to complete the project 18 years
Table 5: Demonstrated Need for Water minimum information

24
Figure 3: Map of ROGCI’s Development Plan and Point of Use Area for Clearwater River licence application

25
Figure 4 below is a graph showing the annual water demand for the Development Plan.

Figure 4: ROGCI’s Development Plan Annual Water Demand

ROGCI currently has 4 wells producing in the Ferrier area (North Saskatchewan River watershed), with 4
additional wells to be completed in 2018. ROGCI is currently in the appraisal stage of development.
Appraisal focuses on land retention and data gathering to help establish type curves for each area. The
full appraisal program consists of 7 more wells and is projected to be completed at the end of 2019. It is
expected that 2020 will be spent evaluating the performance of the pilot wells before moving into Full
Field Development in 2021. Full Field Development will consist of a 1-2 continuous rig program in the
area. The annual water demand is dictated by the number of wells planned to be completed each year.
One freshwater water storage reservoir is constructed on the east side of the Clearwater River. Two
more freshwater storage reservoirs are planned: one on the west side of the river in 2018 and one in
the east side in 2019. The planned storage reservoirs, and any additional reservoirs if required, will be
submitted separately under future applications.

ROGCI is committed to reducing the amount of high-quality non-saline water required by using
alternative sources, such as flowback and produced water, for well stimulation once in Full Field
Development. Due to regulatory restrictions on flowback storage, ROGCI is not able to use flowback for
completions until there is a continuous drilling and completion program (i.e. in 2021 and beyond).
ROGCI intends to start to incorporate deep non-saline groundwater, flowback and/or produced water in
2021 and continue to reduce high-quality non-saline water demand while working through Full Field

26
Development. The total high-quality non-saline water required may increase to the annual water
demand peak if the alternative and reuse opportunities are unsuccessful.

6.2 Points of Diversion
Figure 3 shows two PODs for the Clearwater River licence application. Two PODs are being requested to
develop the mineral rights on each side of the river. NE-15-38-7 will service the west side of the river,
and NW-12-38-7 will service the east side of the river. These locations were selected based on safe river
access, minimal disturbance required, willingness of the landowners to agree to the access, and low risk
to fish and fish habitat (based on studies conducted, Appendix 5). Both PODs are on Freehold land.

6.3 Point of Use Area
As required by the Directive for Water Licencing of Hydraulic Fracturing Projects – Area of Use Approach,
ROGCI has included the POU map for the licence application in Figure 3 (also included in Appendix 7).
The black box in this map indicates the POU, which includes the publically available Duvernay mineral
rights transposed to surface (in yellow), and current and proposed water infrastructure. ROGCI has
included a buffer around the mineral rights transposed to surface for ancillary activities that may require
water, including roads, pipeline bores, dust suppression, and well pads that may extend off the
transposed mineral right area in order to maximize hydrocarbon recovery. The total POU is under the
16 townships outlined in the Directive for Water Licencing of Hydraulic Fracturing Projects – Area of Use
Approach.

7.0 Operational risk assessment and mitigation measures
ROGCI used its internal risk management process to identify operational risks associated with this
Application. This risk management process follows the guidance of ISO31000. The full list of the assessed
risks and mitigation measures is included in Table 6.

ROGCI has reviewed permanent withdrawal stations and permanent underground piping for withdrawal
and transport of high-quality non-saline water to the reservoirs. Temporary above ground surface lines
and temporary withdrawal stations are more economic for the appraisal phase of development and,
with adequate safeguards in place, will have less long term environmental impact. The PODs were
selected to utilize existing cleared land to minimize additional disturbance. Appendix 8 shows the
temporary work areas required for water access at each POD. As required by the Application under the
Water Act for Approvals and/or Licences, Appendix 8 includes the agreements in place with the
landowners for temporary access to the POD work sites.

27
Final Risk
Risk with
Source of Risk Risk Category Mitigation Measures to Reduce or Avoid Risk
Description Mitigations
in Place

High-quality Hydrology study has confirmed the water diversion
Pumping without
non-saline water rate requested is within the allowable allocation set by
screen in place,
pumping Alberta Desktop Method (Appendix 5), ROGCI will use
taking water too
impacts fish Environmental fish screens designed to comply with Freshwater Low
fast, taking water
through Intake End-of-Pipe Fish Screen Guideline (DFO, 1995)
during sensitive
impingent or to prevent fish impingement and entrainment, system
time
entrainment has flow meter and is manned 24h/d during pumping

By installing reservoirs for storage, water will be
Volume of
diverted during high flow which will minimize impact,
withdrawal Taking water too
ROGCI will adhere to IFNs when diverting, hydrology
reduces stream fast, taking water
Environmental studies have confirmed the water diversion rates Low
flow and impacts during sensitive
requested are within the allowable allocation set by
fish or stream time
Alberta Desktop Method, system has flow meter and is
health
manned 24h/d during pumping

Spills from truck
Temporary work access point is defined (Appendix 8),
Contamination driven into water,
procedures in place to situate pump away from the
of water body fuel filling pumps,
stream and within containment, park trucks away
with a pump leaks, Environmental Low
from the stream, implement good fueling practices
deleterious increased
and spill response, and implement erosion and
substance sedimentation and
sediment control measures, if required
erosion

By installing reservoirs, water will be stored for future
No controls in
use, practices in place to release high-quality non-
Withdrawing place to only take
saline water back to the environment when not used,
unneeded high- what is needed, Social and
flow meter on pump to monitor withdrawal rate and Low
quality non- complacency, not Regulatory
volume, site manned 24h/d during pumping, level
saline water knowing content
gauges at reservoirs, process in place for
of licences
communicating licence details to pumping contractors

Dragging screen ROGCI will use fish screen designed to comply with
Accessing water
and hose into Freshwater Intake End-of-Pipe Fish Screen Guideline
has a physical
water, moving (DFO, 1995), screens have a solid bottom and legs to
impact on
screen in water, Environmental minimize river bed disturbance, screens are light Low
stream bank or
vehicle use in weight and can be manually installed, procedures in
bed (fish
proximity to place to minimize disturbances by installing screen and
habitat)
stream placing pump, 24h/d supervision while pumping

Loss of
undisturbed New land
natural disturbance for
Utilize existing land disturbances for access at PODs,
terrestrial POD access and
Environmental utilizing temporary above ground hoses for transport Low
habitat (mature underground
of water, no clearing required
forest and pipelines for
disturbance to transport of water
breeding birds)

28
Final Risk
Risk with
Source of Risk Risk Category Mitigation Measures to Reduce or Avoid Risk
Description Mitigations
in Place

Use of trucks to
No storage
transport high-
available for high- By installing reservoirs, truck traffic will be minimized
quality non-
quality non-saline Social / through use of temporary above ground hoses, truck
saline water Low
water could result Environmental management plan would be in place if trucks are
results in noise,
in needing to use required
safety, and dust
trucks
hazards

PODs and accesses use existing land disturbances and
Impacts on
Pumping during clearings, temporary water intake to reduce footprint,
riparian habitat
winter, clearing Environmental low impact of using temporary hoses on ROW, Low
(fish, birds,
land, noise following best management practices for wildlife
ungulates)
encounters

Licencing process (studies conducted) and meeting IFN
ensures water will be available for other users,
Water not being consultation during Licencing process ensures
ROGCI takes more
available for Social communication, procedures are used for flow Low
than licenced
others metering and 24h/d manned site, phased approach
with water use matching development pace would
allow for water to be reallocated

Risk of water not
being available By installing reservoirs, water will be stored for future
Drought, other
for ROGCI Business use, continuing to investigate alternative sources of Low
water users
development water for hydraulic fracturing
activities

Risk of
Screens will be marked with floating device similar to
disturbing Presence of
Social / Safety diver’s flag and the pumping operations will be Low
recreational use screens in water
manned 24h/d
of river by users
Table 6: Operational Risk Assessment and Mitigation Measures

By committing to the mitigation measures listed in Table 6 above, ROGCI has shown that the risk of this
application is low.

8.0 Communication

8.1 Stakeholders
The Geographic Area is considered low risk due to the few stakeholder concerns, low population
growth, and the absence of established Indigenous Settlements within the boundaries outlined in the
Geographic Area. As a result, a general information brochure will be mailed to each stakeholder listed in
the stakeholder line list included as Appendix 9. A copy of the brochure is included as Appendix 10.
ROGCI will reply to questions resulting from the information brochure.

29
8.2 Indigenous communities
Consultation will be undertaken in accordance with the direction of and processes established by the
Aboriginal Consultation Office (ACO). Consultation will be conducted concurrently with the AER’s review
of this application and ROGCI understands the application will not be approved without adequate
consultation with Indigenous communities. ROGCI will include the Indigenous communities consulted as
part of this application in its ongoing stakeholder engagement program.

9.0 Monitoring, reporting, and performance management
To improve public access to water licence application information, water use reporting, and water
source selection information, ROGCI recognizes that annual reporting will be required throughout this
project. This reporting will indicate environmental performance, demonstrate continuous improvement,
and present usage monitoring and environmental monitoring results. In addition, the water allocation
will be reviewed by the AER at ten year intervals to ensure current technology and practices are being
utilized, to verify continuous improvement, and to gauge alignment between activities and projections
and policy.

9.1 Progress and continual improvement reporting
ROGCI is proposing an annual report to AER including the following:

High-quality non-saline water withdrawn compared to licence limits and use compared to
estimates in Application
% high-quality non-saline water reduced through replacement with alternatives
Environmental impacts and adverse effects, if any
Summary of complaints received, if any, and steps taken by ROGCI to mitigate concerns
Three year outlook on phase of development and projected water use
Any changes to Duvernay mineral tenure in the Geographical Area and the well density

ROGCI also proposes to report on continual improvement annually, including the following:

Description of the alternatives studied or used, including issues that were encountered
A review of water reduction initiatives in hydraulic fracturing operation
A technical review, within the constraints of proprietary information, on the progress of any
pilots, prototypes, or demonstrations, including performance, successes, challenges, and
implications for net environmental effects for all treatment technologies
Other reporting elements as outlined in the conditions of the licence

The report would be submitted to AER annually. The report would be made available to stakeholders
and Indigenous communities upon request.

30
9.0 Appendices
A1. Clearwater River Water Licence Project Industry Focus Map

A2. Clearwater River Water Licence Project Indigenous Settlements and
Federal Reserve Lands Map

A3. Clearwater River Water Licence Project Stakeholder Focus Map

A4. Clearwater River Licence for Diversion of Water Application

A5. Hydrology, Fish and Fish Habitat, and Wildlife Assessment in Support of a
Surface Water Licence Application, Clearwater River at NW ¼ 12-038-07W5M
and NE ¼ 15-038-07W5M; Matrix Solutions Inc., March 8, 2018.

A6. Alberta Water Tool Report Clearwater River; 2017-09-20

A7. Clearwater River Point of Use Area Map

A8. Clearwater River POD Access Maps and Agreements

A9. Clearwater River Water Diversion Application Stakeholder Engagement
Line List

A10. Clearwater River Water Diversion Application Project Brochure

31